Corrective Action Plans

Finding 2025-023 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - EGrAMS Security Management and Access Controls Management Views LEO agrees with the finding. Planned Corrective Action For part a., LEO has a process to maintain documentation and support for internal users. For external users, LEO will ask the vendor to upgrade the system so it logs every external user activation, including the approving LEO staff member’s name and the timestamp, rather than overwriting previous external user activation records. For part b., LEO established a user reconciliation process in March 2026 that will be managed by the LEO Grants Division. For part c., LEO will change its policy requiring the disablement of user accounts inactive for over 60 days to comply with SOM Technical Standard 1340.00.020.01 (Access Control Standard). LEO will work with DTMB to complete a system security plan so user accounts will be automatically deactivated after 60 days of inactivity. LEO will also explore options to address the issue of EGrAMS users who typically only access the system every 90 days to complete required system reports. Anticipated Completion Date a. December 31, 2026 b. Completed c. December 31, 2026 Responsible Individual(s) Jason Hamblin, LEO

Finding 2025-021 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - AASHTOWare Security Management and Access Controls Management Views MDOT agrees it did not fully establish effective security management and access controls over the American Association of State Highway and Transportation Officials software (AASHTOWare) users. Planned Corrective Action For part a., the MDOT Office of Enterprise Information Management (EIM), Bureau of Field Services-Construction Field Services Division, and Bureau of Development-Design Division will collaborate and provide oversight to ensure that internal user access for AASHTOWare is reviewed at least annually. MDOT will implement an improved process, which will be facilitated by the designated system security administrators, to ensure an internal user review at least annually. For part b., MDOT worked with DTMB in May 2026 to correct and enhance the auto-disabler function of the AASHTOWare program. In addition, MDOT will continue to monitor this functionality as part of its improved access control process to ensure users who have not accessed AASHTOWare within 365 days for internal user accounts and 18 months for external user accounts are disabled timely. Anticipated Completion Date a. September 30, 2026 b. Completed Responsible Individual(s) Mark Shulick, MDOT Dan Burns, MDOT Kristin Schuster, MDOT Dee Parker, MDOT Lindsey Renner, MDOT Jason Gutting, MDOT Kyle Nelson, MDOT Andy Esch, MDOT

#2025-003 FINDING: Grant Tracking Responsible Individual: Pedro Rosa, Business Manager Corrective Action Plan: The Business Manager will follow the recommendation of the auditors. This expenditure of the Curriculum Subscription was paid for the first year to get started with the material, we did not expense it in the second and third year. A discount was given to pay the three years up front. The prepaid upfront expense was approved by the grantor. The Business Manager will continue to agree that actual expenditures incurred to the general ledger before requesting reimbursement. Anticipated Completion Date: Ongoing

Corrective Action: All vouchers require Town Manager and Finance Director to approve and sign all vouchers prior to payment. Efforts are in place to make this a high priority even in busy times. The number of transactions processed greatly increased relative to Federal dollars, but the Town is committed to internal controls. Anticipated Completion Date: Immediately Contact Person: Elizabeth Draper and Brian Rosso

2025-003: Period of Performance Compliance Action Taken/Planned: Management acknowledges the instances identified in which disbursements were processed after the award's period of performance. While no questioned costs were noted, the University recognizes that timely processing of expenditures and drawdowns is critical to ensuring compliance with federal requirements governing grant periods. To Strengthening Grant Closeout Procedures management will establish a formal grant closeout timeline to begin 90 days prior to the award end date, require principal investigators (PIs) and grant administrators to review all outstanding obligations and ensure timely submission of final expenses and implement a standardized closeout checklist to confirm all costs are recorded within the allowable period To Enhanced Monitoring of Grant Periods management will develop and maintain a centralized tracking system for all federal awards, including start and end dates, generate monthly reports identifying grants nearing expiration (within 90, 60, and 30 days) and distribute reports to Pis, Grants Accounting, and Finance leadership for proactive management. For timely processing and drawdown controls management will require all invoices and expenditures to be submitted within a defined timeframe (e.g., within 30 days of service or project completion), establish internal deadlines for processing disbursements and drawdowns prior to the grant end date and implement a review step within Grants Accounting to verify that expenses fall within the period of performance before payment is released. The grants department will conduct mandatory training for PIs, grant managers, and finance staff on period of performance requirements and federal compliance expectations and reinforce accountability for timely submission and processing of expenditures Management will also put in place for any costs identified outside the period of performance will require, documented justification, review and approval by the Director of Grants Accounting and CFO, and verification of allowability under award terms or sponsor approval, if applicable. Anticipated Completion Date/Date Completed: This will be implemented immediately with an anticipated completion date of June 30, 2026

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. Name of the contact person responsible for corrective action: Lyn Elliot, CEO Planned completion date for corrective action plan: 7/1/2026

Findings #2025-004 and #2025-006 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, 93.566, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Passed through Texas Office for Refugees: 10/01/24 – 09/30/25, FFY2025-27946V-ASA RSS, 10/01/24 – 09/30/25, FFY2025-27946V-AUSAA-RSS, 10/01/24 – 09/30/25, FFY2025-27946V-CMA, 10/01/24 – 09/30/25, FFY2025-27946V-RSS, Passed through United States Conference of Catholic Bishops: 10/01/24 – 09/30/25, 25RSI13A, Passed through U. S. Committee for Refugees: 10/01/24 – 09/30/25, RHP-2025-YMCA-Houston TX-03, 93.567, Refugee and Entrant Assistance Voluntary Agency Programs, Passed through U. S. Committee for Refugees and Immigrants: 10/01/24 – 09/30/25, 2502VARVMG, 10/01/23 – 09/30/24, 2402VARVMG, 93.676, Unaccompanied Alien Children Program, Passed through U. S. Committee for Refugees and Immigrants: 01/01/25 – 12/31/25, 90ZU0630-02. Condition and context: During our testing of the accuracy of accounts payable cutoff and the testing of allowable costs charged to major programs, the following exceptions were identified for expenses recorded in the incorrect period: 3 of 19 subsequent disbursement transactions tested were recorded in the incorrect accounting period. Refugee and Entrant Assistance State/Replacement Designee Administered Programs (ALN 93.566) – 3 out of 40 transactions tested were recorded to the incorrect accounting period. Unaccompanied Alien Children Program (ALN 93.676) – 1 out 40 transactions tested was recorded in the incorrect accounting period. Refugee and Entrant Assistance Voluntary Agency Programs (ALN 93.567) – 1 out of 40 transactions tested was recorded in the incorrect accounting period. Recommendation: Policies and procedures should be enhanced for proper identification of the period that expenses relate to so that expenses will be recorded in the correct accounting period for financial statement reporting and for billing allowable costs to federal programs. Planned corrective action: Management acknowledges the deficiency identified related to the precision of procedures to ensure expenses are recorded in the appropriate accounting period. Processes were in place and operated to identify and record expenses in the correct period, and management’s review procedures are designed to capture all material items for financial reporting and program compliance purposes. The exceptions identified through audit testing represent a limited number of timing differences in a high-volume environment, primarily related to the timing of invoice receipt and processing, and were not material individually or in the aggregate. These items were recorded in the subsequent period in the normal course of operations and do not reflect a systemic breakdown in controls. In response, management has reinforced month-end cutoff procedures, including enhanced review of subsequent disbursements and clearer expectations around accrual identification and invoice timing. Management will continue to monitor cutoff procedures to ensure expenses are recorded in the appropriate period with an appropriate level of precision while maintaining timely vendor payment practices. Responsible officer: Lauren Rome, VP of Financial Operations/Interim CFO. Estimated completion date: June 15, 2026

Finding 2025-003: Period of Performance – Significant deficiency in internal controls over compliance and compliance finding. Management Response The agency has added another level of review for Requests for Reimbursement (RFRs) to improve internal controls. Effective 10.01.2025, grant expense charges are processed as follows: 1. Finance Assistant creates grant Request for Reimbursement (RFR). Upon completion of the RFR, theAssistant signs the RFR as completed, then submits completed RFR along with supportingdocumentation to the EVP of Finance. Formerly, the creation of the RFR was being done by the EVP of Finance, with the addition of staff, we were able to relocate those duties to Finance Assistance in the Fall of 2025. 2. The EVP of Finance reviews the RFR for correct calculations and if the appropriate supportingdocumentation is attached. The EVP of Finance signs the RFR, then presents it to the ChiefOperating Officer for final approval. 3. Chief Operating Officer receives RFR from EVP of Finance, reviews RFR and approves for submissionto the Grantor or sends back for corrections. Adding a staff member in the Finance department allowed us to add another level of approval. In addition, notations have been made on all internal grant tracking documents, as to the start of each grant period. A payroll pay calendar is accessible to verify the exact dates covered on a pay period.

The Organization filed the required reports in 2026.

DWIGHT WAY HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Dwight Way Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.181. Program –Supportive Housing for Persons with Disabilities Significant Deficiency Dwight Way should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Unanticipated staff shortages created gaps in performance of annual recertifications at this location. New staff has since been hired in the Regional Manager role and the Director role. Both new employees are providing greater oversight and visiting the property regularly to track progress. In addition to our permanent staffing efforts, we have deployed a Property Operations Specialist to bring recertifications current at Dwight Way. This specialist is focused specifically on compliance tasks and critical deadlines. Additionally, senior leadership at the John Stewart Company has implemented enhanced tracking of recertifications across the full portfolio and now conducts monthly progress meetings with management team to monitor compliance, identify risks early, and ensure accountability. We are confident that these corrective actions will result in sustained improvement and ongoing compliance. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

As required by the OMB Uniform Guidance, we have provided our response and corrective action plan addressing the finding in the Schedule of Findings and Questioned Costs for the year ended August 31, 2025. Finding 2025-001: Allowable Costs – Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Management’s Views – Management agrees with the finding. LAJH acknowledges that payroll reimbursement calculations submitted under the federal program were prepared using subsequent employee pay rates rather than the contemporaneous pay rates applicable during the grant performance period and that certain duplicative expenditures were included in error. Management recognizes that these errors resulted in overstated costs totaling $79,825. Corrective Action Plan – LAJH will implement enhanced internal control procedures over the preparation and review of payroll costs charged to federal awards. Specifically, management will require all payroll reimbursement calculations to be supported by contemporaneous payroll registers and employee pay rate documentation applicable to the period during which services were performed. Person Responsible for Corrective Action: Robin Ray, Corporate Controller Anticipated Completion Date: May 31, 2026

Finding 2025-002 Federal Agency Name: Department of the Health and Human Services Program Name: Rural Healthcare Services Program Federal Financial Assistance Listing #93.912 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Period of Performance Finding Summary: BHD, LLC did not retain documentation of the review and approval of all direct expenditures allocated to the program. Responsible Individuals: Valarie Howard, CFO Corrective Action Plan: We have begun generating a report each pay period identifying any timecards that remain unapproved at the processing deadline. Payroll will proactively follow up with the responsible managers to obtain approval for any outstanding timecards identified in the report. Payroll will disburse a document to the responsible managers who must document why the approval was not made by the payroll deadline and that they approve the time that was presented on the timecard and paid out. Anticipated Completion Date: Action plan has been implemented immediately after finding was communicated to management (May 2026).

Period of Performance 2025-002 Plan: The University reinforced the existing procedures related to awards subject to modified or shortened periods of performance, including additional oversight of expenditures charged near revised award end dates. Post-Award monitoring and controls related to award end-date management and expenditure allowability will continue to be evaluated and strengthened, as appropriate. Expected Implementation Date: 07/01/2026 Contact: LaShawnda V. Hall Assistant Vice President for Research Financial Operations Accounting Services for Research Sponsored Projects (ASRSP) Northwestern University 1800 Sherman Ave, Suite 6-6000 Evanston, IL 60201 lashawnda.hall@northwestern.edu Phone: 847.491.4716

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Hockinson School District No.98 September 1, 2024 through August 31, 2025 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort and period of performance requirements. Name, address, and telephone of District contact person: Aaron Villanueva, Director of Business Services 17912 NE 159th Street Brush Prairie, WA 98606 (360) 448-6413 Corrective action the auditee plans to take in response to the finding: Time and Effort - To enhance compliance with Federal IDEA grant requirements, the district is refining its procedures for Annual and Semi-Annual Certifications. At the commencement of the school year, the district will proactively assign eligible Special Education personnel to this grant to ensure all necessary attestations are executed and submitted in a timely manner. In the event of projected expenditures exceeding the federal allocation, personnel costs associated with the overage will be reallocated to the State Special Education Program (2100). Furthermore, the District remains committed to utilizing the tools and best practices provided by the State Auditor’s Office following the 2024–2025 audit to ensure ongoing regulatory alignment. Period of Performance - Historically, the district’s award date for this specific grant has not been restricted in the period of performance to the narrow window suggested. For example: 2023–2024 fiscal year, Grant Award Date March 6, Period of Performance July 1, 2023, through August 31, 2024, allowing the district to claim expenditures for the full cycle. 2025–2026 fiscal year, Grant Award Date November 13th, Period of Performance July 3, 2025, through August 31, 2026, allowing the district to claim expenditures for the full cycle. To prevent future discrepancies, the district has implemented a secondary verification process to cross-reference all Grant Award Notifications (GAN). We will strictly document the specific period of performance dates identified in each award to ensure total alignment with state and federal expectations. Anticipated date to complete the corrective action: Effective Immediately

The BGCNEO accounting staff will closely review expenditures to ensure costs were incurred within the applicable grant period, regardless of when the expenditure was paid.

Finding #2025-003 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges, Assistance Listing #93.332, Contract # NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Affordable Care Act (ACA) Personal Responsibility Education Program, Assistance Listing #93.092, Contract #90AK0075-03-03, Contract year: 09/30/23 – 09/29/25. Condition and context: During our testing of payroll, non-payroll and indirect cost pool transactions, we identified the following exceptions: Controls over allowable cost and other non-compliance: AL #93.092 Affordable Care Act (ACA) Personal Responsibility Education Program. In a sample of 40 non-payroll transactions tested for internal controls and compliance for allowable cost we found one instance of an annual subscription for the term ending May 2026 charged to a grant which ended September 29, 2025 resulting in eight months, or approximately $1,200, charged outside the period of performance. Partial repeat of finding #2024-004. Controls over period of performance and other non-compliance: AL #93.332 Cooperative Agreement to Support Navigators in Federally-facilitated Exchanges. In a period-of-performance sample of 18 vendor transactions with grant charges close to grant beginning or ending dates during the audit period, we found 3 instances or $1,003 of vendor costs charged outside the grant period of performance. Additionally, testing of payroll charged at the end of the grant period revealed that approximately $6,693 was charged outside the period of performance. Recommendation: Emphasize adherence to established policies and procedures to ensure maintenance and review of payroll spreadsheets and general ledger coding for all transactions. Planned corrective action: Management has implemented strengthened procedures related to payroll allocations, grant coding, allowable costs review, and monitoring of grant periods of performance. Corrective actions include: 1) Enhanced review procedures to ensure expenditures are charged to the appropriate funding source and grant period. 2) Review of payroll allocations against approved grant budgets and supporting time and effort certifications where applicable. 3) Monthly review meetings between finance personnel and program leadership to review coding accuracy, budget status, payroll allocations, and grant compliance requirements. 4) Additional staff training related to Uniform Guidance cost principles, allowable costs, grant periods of performance, and GAAP financial reporting requirements. 5) Improved grant expenditure tracking and monitoring procedures to identify coding errors or compliance concerns timely. 6) Strengthened documentation retention procedures to ensure expenditures are properly supported and audit ready. Responsible officer: Anita Bates, Chief Executive Officer. Estimated completion date: Implementation is underway with continued monitoring and expected to be fully operational by August 31, 2026.

Diabetes, Digestive, and Kidney Diseases Extramural Research (ALN 93.847) Recommendation: We recommend that the Organization reviews the dates of costs incurred before charging costs to their Federal award and that evidence of this review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented procedure enhancements to its review and processing of grant-related costs to better detect and prevent costs being charged outside of the period of performance. Including: the period charged for costs is based on expected receipt date of the goods or services being charged; a threestep/tiered review process of costs to be charged prior to the processing of such costs; a periodic review of the periods in which costs were charged for proper period alignment. Name of the contact person responsible for corrective action: Mahtab Khan Planned completion date for corrective action plan: May 2026

Condition: The Organization was reimbursed $22,968 under the grant award for amounts incurred subsequent to the performance year of the grant. The control in place to review expenditures was not effective in identifying expenditures that were outside the grant period. Planned Corrective Action: The Organization will implement enhanced review procedures of federal expenditures sought for reimbursement to better align with the underlying accounting treatment. Contact person responsible for corrective action: David Anderson Anticipated Completion Date: September 30, 2026

Management will look to strengthen this control by improving the way they track and submit expenditures related to federal grant expenditures.

Management will include as part of the approval of invoices, a process of follow-up with vendors near the end of the fiscal year to make sure all outstanding invoices or an estimate of costs incurred to date are received. If this is not feasible, management will estimate the unbilled costs at year end using vendor information.

Management will conduct a comprehensive review of existing processes and internal controls related to eligibility determination and documentation to ensure alignment with federal requirements. As part of this effort, management will evaluate the timing and sequencing of required signatures to better reflect operational realities while maintaining compliance.

FINDING 2025-013 Name of Responsible Individual: Assistant Vice President for Pre-Award Corrective Action: Federal awards require that all publications resulting from federal grant support, including conference presentations, promotional materials, agendas, and internet sites, include an acknowledgment of federal support and a disclaimer that the contents reflect the authors' responsibility and not that of the sponsoring agency. As this is a repeat finding, the University has undertaken a comprehensive, multi-pronged corrective strategy to ensure sustained compliance going forward. Responsibility for publication acknowledgment and disclaimer compliance now resides with the Sponsored Programs Office (SPO) Pre-Award, in collaboration with the University Library. Key actions completed to date include: a formal Standard Operating Procedure finalized and approved in November 2025; mandatory publication compliance training with a required 80% passing score, serving as a prerequisite for new award setup effective November 2025; a Principal Investigator (PI) Acceptance Memo requiring signature within five business days of each award kickoff meeting to reinforce PI awareness of publication responsibilities; quarterly compliance communications issued to all federally funded PIs; and a dedicated publication compliance category added to the OOR ticketing system to streamline intake and support documentation. During Award Kickoff Meetings, acknowledgment and disclaimer requirements specific to each award are reviewed directly with the PI. SPO Pre-Award and the University Library conduct ongoing reviews of federally funded publications using available bibliometric tools, with periodic spot checks. PIs who do not meet training requirements are subject to a hold on proposal submissions until compliance is verified. Anticipated Completion Date: June 30, 2026

FINDING 2025-010 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management Associate Director of Loans Systems Analyst, Enrollment Management Assistant Director for Compliance, Financial Aid Loan Coordinator Corrective Action: Beginning with the Fall 2024 semester, Howard University transitioned from using Banner to using Workday as the University’s ERP. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” during Fall 2024 there would be no configuration issues that affect compliance. It is not possible for Financial Aid to fully test the COD disbursement reporting process prior to "go live" due to the inability to send test disbursement files to COD for reporting purposes. Once Howard disbursed loans and was able to send actual disbursement files to COD, the Enrollment Management Systems Analyst worked to identify and resolve outstanding issues. Initial reporting of disbursements to COD began on August 6, 2025. When the first disbursement file was sent to COD, the EM Systems Analyst identified the file schema sending out disbursements from Workday to COD kept rejecting the entire file. The Systems Analyst worked with the University Workday consultants to resolve the rejections and was able to correct the issue on August 28th. The cause of the rejected files between Workday and COD was an underlying Workday system issue that was corrected an updated released by Workday. There were issues in Workday regarding the school code that were identified which delayed a small cohort of students’ disbursements from being reported to COD. The Howard University enrollment school code is 00144800 and NSC required a “dummy” school code to be used for enrollment reporting of Graduate and Professional students. This “dummy” code was 00144880. A small cohort of students had loans that were rejected due to Workday reporting the 00144880 school code to COD instead of the 00144800 school code. Reconciliation identified the students and once the enrollment code sent to COD was corrected in Workday, the loan was accepted. The cost of attendance variance was a result of unfamiliarity with the Workday system. After a student's aid has been originated and disbursed, Workday will not automatically send the disbursement file back out to COD, which was not an issue Howard encountered when using Ellucian Banner. In Workday, when a student’s cost of attendance changes due to cost of attendance increase or the student’s housing status must be adjusted, there is manual intervention required. Students who have a change to their cost of attendance need to have a flag checked off in the origination record. This will allow the updated cost of attendance to be reported in COD when the next disbursement file is sent to COD. The current process is when a student's cost of attendance is manually adjusted, the flag for the record to be sent to COD is checked off in the origination record. The Associate Director for Compliance has completed internal compliance reviews testing whether disbursements are being sent to COD within 14 days. Thus far, no issues have been found in these reviews. Files are transmitted to COD at least four times per week and rejected disbursements are worked to meet the 14-day disbursement reporting timeline. A compliance review has been initiated to ensure the cost of attendance reported out of Workday matches the cost of attendance in COD. Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. The goal of these meetings is to have a constant flow of information on what is working effectively and what is not working effectively within Workday. This process is documented and staff are trained. Anticipated Completion Date: The underlying Workday system issue resulting in the COD disbursement file being rejected was internally resolved on August 28, 2024. The Fall 2024 update released by Workday in late-September/October 2024 corrected the system from the Workday side. The Systems Analyst receives an error when there is a rejected COD file, and the correction of these files is an ongoing process. Howard staff worked with the University’s Workday consultant to resolve the incorrect school code reported to COD, causing individual students’ disbursements to be rejected. This incorrect school code reported to COD was resolved for the 2025-2026 academic year by changing the configuration of disbursements to ignore any school codes other than 00144800. The Associate Director for Compliance sends a list of rejected loan disbursements to the Financial Aid Loans Team so these rejects can be worked on and resolved in 5-7 business days. The cost of attendance variance was identified in Fall 2025 and the change in the process when a student has a manual cost of attendance increase was implemented at that time as well. The compliance reviews for cost of attendance and COD reporting will take place twice per semester and any issues identified will be resolved to avoid future findings.

In response to the Auditor’s recommendations, the Municipality will establish formal procedures to ensure that all required forms, including Form 90-91, are properly completed, maintained, and submitted in accordance with applicable grant requirements. Additionally, all supporting documentation related to the period of performance for each project will be identified, organized, and maintained, including approved project worksheets, grant award documentation, and related financial records. Furthermore, monitoring mechanisms and periodic reviews will be implemented to ensure ongoing compliance with applicable requirements and the timely availability of required documentation for audit and monitoring purposes.

We agree with the finding and we will be reviewing and implementing the recommendations accordingly. We are committed to ensuring no duplication of costs across reporting periods and compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan will be implemented by June 30, 2026.