Corrective Action Plans

Department of Housing and Urban Development Program Name: Continuum of Care Program Federal Assistance Listing Number: 14.267 Significant Deficiency, Nonmaterial Noncompliance – Period of Performance Finding 2024-002 Criteria: Period of performance is defined in 2 CFR 200.1 as “the time interval between the start and end date of a federal award, which may include one or more budget periods.” Condition: For one award, the 2023 grant award project was not closed timely in the general ledger system and the County erroneously recorded fiscal year 2024 grant costs of $1,059 to the project, which was beyond the approved period of performance of the award. Additionally, for one award, the County recorded grant costs of $28,685 to the project, which was beyond the approved period of performance of the award. Effect: By not having the grant project codes properly closed at the end of the period of performance, the County could potentially request reimbursement for costs incurred and recorded beyond the grants approved period of performance from the Federal government. Questioned Costs: $29,744 Cause: The County did not have a formal policy to ensure grant project codes were properly closed and expenditures were not being recorded beyond the grant award’s stated period of performance. Recommendation: We recommend the County should implement a formal policy to ensure all grants are properly closed and no costs are incurred on grants after their period of performance. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: See below Corrective Action Plan prepared by the County. Following the end of grant term, June 30th, Shelter Plus Care (SPC) program will ensure all final payments are made out of the grant by mid-August to ensure timely reconciliation. • Grant Management /Revenue Reimbursement Team will send final draw for review and approval by SPC Supervisor and upon confirmation, email communication will be made with Accountant III (within the Budget Team) for final review. • Accountant III will provide Purchase Order by Unit report (PD615) report to SPC program to ensure all POs are closed out. • Accountant III will review PD615 report to ensure deactivation. Ongoing review will take place at least 2 months following the 90-day close-out period. •The SPC/Finance Team will work with staff, supervisors and payroll to ensure all applicable payroll is allocated to proper (active) grant unit and respective entries are processed timely. • When new grant is established, the SPC team will ensure that time posted and approved for SPC admin costs in PeopleSoft are for the correct grant unit/ grant fiscal period as well as ensure that funds are encumbered and paid from correct grant/grant fiscal period. In addition to these steps, ongoing review and monitoring of grant will occur monthly during SPC’s Finance Meeting on the 4th Thursdays of the month and during the CSS Grants Meeting on the 4th Tuesdays of the month. Completion Date: June 30, 2025 Responsible Person(s): Adia Robinson, Clinical Supervisor

Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs and Cost Principles Contact: Laura Meloy, VP, Finance Completion Date: June 30, 2025 Corrective Action: The ChildFund Management team has taken immediate action to discuss the importance of proper period end cut-offs with the Accounting and Grants Teams. Moving forward, the Grants and Project Management team will discuss expense cut-offs during the kick-off meetings and the importance of year-end accruals. The Accounting Department will also provide additional training and reminders around year-end cut-offs and the importance of reviewing invoice dates for accruals that are under our normal threshold of $1,000 USD for grants.

Finding 2024-002 A plan has been developed to take corrective action regarding finding 2024-002 in our audit for the year ended June 30, 2024. Condition: Out of 25 students tested, there were 16 students with Pell and Direct Loan attributes incorrectly reported to COD. Cause: The Financial Aid department does not have adequate processes and controls around return of funds to ensure reporting to COD is accurate. Effect: COD reporting was not properly completed for Direct Loan and Pell Grant recipients. Corrective Action Plan (CAP) and Anticipated Completion Date: The Colleague system uses the dates that are entered into parameter screens when the academic year is set up. Those dates from the setup screen are used in setting up the information per student to be sent to COD. It is likely that these preliminary dates were updated as they became more fixed. This would result in differences in individual record dates based on timing of data entry. With the gathering of offices under the Enrollment Management umbrella this fiscal year, greater coordination and control is gained and will control entry and maintenance of system dates. The Registrar will also look at creating a centralized change log for term dates for reference between the two staff areas. The Registrar and Director of Student Financial Aid will oversee these changes under the direction of the Executive Director of Enrollment Management. This will be completed asap during Fiscal Year 2025 but no later than June 30, 2025. Responsible Party for Implementing CAP: Executive Director of Enrollment Management

Finding 2024-001, Significant Deficiency - Reporting In Fiscal Year 2023-24, the Transportation Department submitted reports for the RAISE grant to the NCDOT for four quarters without prior review from the Finance Department. This was corrected with the June 2024 quarterly report, and the grant liaison is now following the City's policy. The liaison prepares the report and sends it to his manager for review and approval. Then it is routed to the Senior Financial Grants Analyst for review. The Accounting Manager reviews and approves the report before it is submitted to the NCDOT. The Transportation Department has been made aware that the City needs to follow the grants policy with all grants. Implemented prior to report date. Greg Venable, Transportation Director, Responsible Person 11/26/24 Bobby Fitzjohn, Financial Services Director 11/26/24

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.

Finding #2023-002 – Statement of Condition: During our testing of period of performance, we noted that one transaction occurred prior to the period of performance beginning Response: Management concurs with the finding and is updating their internal controls around period of performance. The matter was corrected by December 31, 2024

Management agrees with the finding and will implement procedures to ensure reimbursement request documentation and supporting schedules are retained in a centralized location and readily accessible for future monitoring and audit purposes. Anticipated Completion Date: September 30, 2026.

Item 2023.007 – Period of Performance Recommendation The Center should develop written procedures to review all expenditures to ensure they are within the proper period of performance of the grant. Repeat Finding Yes Action Taken Island Health Care will take the following actions to address this recommendation: • Conduct a pre-approval of expenditures, verifying that the expense is allowable under the grant terms and falls within the period of performance • Utilize a pre-approval form that includes details of the proposed expenditure, its necessity, and confirmation in the form of authorized signatures that it is within the grant period. • Require all relevant supporting documentation with the date the expense was incurred, ensuring it falls within the grant's period of performance. This is further reviewed by the CFO who will verify that the expenditure meets all requirements and is then able to record it in the accounting system. • Conduct regular reviews of expenditures to ensure compliance with the grant period and maintain audit trail • Review these procedures annually to ensure they ongoing compliance with the grant's period of performance

Finding No.: 2023-018 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $-0- Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1-2: The Capital Improvement Program (CIP) agrees with this finding that a subrecipient expending $750,000 or more in federal awards during its fiscal year was not adequately verified for compliance with Single Audit requirements, including whether corrective actions were implemented to address prior audit findings. To prevent recurrence, CIP will implement the following: • Update Policies and Procedures o Revise and strengthen written financial management policies to clearly define documentation requirements to substantiate expenditures and ensure costs are within the award’s period of performance for all projects. o Incorporate federal regulation references, including 2 CFR 200.303 (Internal Controls) and 2 CFR 200.344 (Closeout). • Internal Controls and Review Process o Implement a detailed tracking spreadsheet/ checklist for all CIP-funded transactions to ensure details are verified and that costs are incurred within the period of performance. o Require a secondary review and sign-off by the CIP Administrator for all documents pertaining to cost share projects. • Training and Capacity Building o Conduct an annual training for CIP staff on federal period of performance requirements and required supporting documentation standards. o Provide refresher sessions before each audit cycle. • Monitoring and Compliance o Establish a quarterly self-audit of grant files to verify that documentation is complete and properly supports expenditures. o Document results of each review and address deficiencies immediately. Proposed Completion Date: September 30, 2026 Finding No.: 2023-018, continued AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $-0- Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: For Grant Award No. D22AF00298 and D20AP10168, the Office of Grants Management (OGM) is unable to provide a response because the Grant Award # provided cannot be located in the current FMIS, nor does the Division of Financial Services, Federal Section, have records of their existence. Proper searches were conducted in the legacy system and in Tyler-MUNIS but were not successful. We recommend that the auditor provide additional details regarding the specific grant award so that the appropriate responsible office can be accurately identified. Furthermore, we do not know whether OGM is the responsible party to answer on behalf of these non-titled projects. Proposed Completion Date: Ongoing

LARS has implemented the following controls to address each element of this finding: HUD CoC Match Tracking: A grant-level match tracking schedule has been established for the CoC program. The schedule documents required match amounts, eligible match contributions, and cumulative match-to-date, and is updated at each reporting period. The Finance Director reviews the schedule prior to each drawdown and at fiscal year-end. Administrative Cost Limitation Monitoring: Written policies and procedures have been updated to include a procedure for monitoring the HUD CoC administrative cost limitation. The Finance Director calculates the limitation at the beginning of each grant year and monitors actual administrative costs on a quarterly basis. Grant Cutoff Procedures: A written grant financial management policy has been adopted that establishes cutoff procedures for recording expenditures within applicable grant performance periods. The accounting system has been configured to flag transactions with dates outside an active grant period for Finance Director review prior to posting. SEFA Preparation and Review: A formal SEFA preparation procedure has been implemented that requires: • A reconciliation of SEFA amounts to the general ledger and underlying grant records • A documented review of all grants and funding sources including state and local grants to determine proper SEFA inclusion and reporting treatment

Finding 2023-001 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Criteria: The Period of Availability for the SPED PL 94-142 Grant was September 22, 2022 through September 30, 2024. Condition: During our test of controls over compliance it was noted that there are expenditures charged to the SPED PL 94-142 Grant (September 22, 2022 through September 30, 2024) for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Context: During our test of expenditures and review of the general ledger against the SPED PL 94-142 Grant as it is related to compliance it was noted that 8 expenditures charged to the grant had service periods that were completely or partially for services prior to the grant start date of September 22, 2022 and thus would be outside the period of performance and thus would not be allowable costs. Effect: The School Department was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned costs for the expenditures charged to the grant whose service period was completely or partially for services prior to the grant start date of September 22, 2022 was $31,948.58. Cause: A journal entry to charge costs to the grant included invoices that were outside of the grant award start. Recommendation: We recommend the School Department follow procedures to ensure that expenditures charged to the grant are within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Responsible for Corrective Plan: Kathleen Grant Estimated Completion Date: Immediately Action Taken: Updated our procedures to ensure that expenditures charged to grants are within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education.

Reporting The College partially agrees with the finding. While the College disagrees with the auditors’ conclusions regarding the calculation of cost of attendance and Pell award amounts for the students tested, the College acknowledges the need to strengthen its review and documentation procedures over origination records and COD submissions to ensure consistency and completeness of reporting records.

Response: Management concurs with the finding. Corrective Action Plan: NewSpace Nexus will comply with federal employment eligibility requirements by ensuring a Form I-9 is completed for every employee within three business days of their start date. Employees must provide acceptable documentation as required, and completed forms will be securely maintained and retained for the required period. The Financial Analyst will periodically review personnel files to confirm compliance, and any missing or incomplete forms will be addressed promptly with documentation of corrective actions retained. Designation of Employee Position Responsible for Meeting Deadline: Financial Analyst by: January 31st, 2024