Corrective Action Plans

Planned Correction Action: Moving forward grants will not be set up with account #s for use until the funds are received and award letter is issued with actual start date. This will stop any expenses being posted prior to the start date. Name of Contact Person and Completion Date: Jeremy Roche, Assistant Superintendent of Finance and Operations. This plan will go into effect immediately.

2023-001 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: We have controls in place to ensure that costs charged to a grant are incurred within the grant period of performance. This finding exposed a vulnerability that circumvented our controls. We will use this finding to pinpoint the cause(s) and make the necessary corrective adjustments. Name(s) of the contact person(s) responsible for corrective action: Deborah Grupp-Patrutz and Steve Simmons Planned completion date for corrective action plan: Prior to June 30, 2024

FINDING 2023-010 Finding Subject: ESSER (Education Stabilization Fund) – Allowable Activities, Allowable Costs/Cost Principles Federal Programs: Education Stabilization Fund Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed and Allowable Costs/Cost Principles compliance requirement. The School Corporation did not have internal controls in place over payroll disbursements. A detailed report of payroll disbursements paid without evidence of review and approval by a knowledgeable person. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: Develop process and procedures for verifying payroll disbursements from grant funds. On a monthly basis, Payroll coordinator will print payroll disbursements from federal grant funds to be reviewed, verified and signed off by Superintendent/CFO. Anticipated Completion Date: To begin immediately, March 2024

FINDING 2023-006 Finding Subject: Special Education Cluster - Activities Allowed, Allowable Costs/Cost Principles, Period of Performance Summary of Finding: An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Activities Allowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The School Corporation did not have internal controls in place over payroll disbursements. A detailed report of payroll disbursements was paid without evidence of review and approval by a knowledgeable person. Contact Person Responsible for Corrective Action: Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: Develop process and procedures for verifying disbursements from grant funds. On a monthly basis, Corporation Treasure will print expenditure report from federal grant funds to be reviewed, verified and signed off by Superintendent/CFO. Anticipated Completion Date: To begin immediately, March 2024

Corrective Action Planned: The identified payments relate to postage expenditures recorded in the Child Support Enforcement Grant. Postage expenditures are controlled in the State's mailing system through mail codes. Agencies send approved postage budgets to the Department of Administrative Services (DAS), who then creates a new mail code or adds additional funding to existing codes in the system. All mail processed through the mailing system is charged to these individual mail codes. A monthly expenditure report from the mailing system is interfaced with NH First, and the DAS uploads a journal entry to the general ledger to record these expenditures. The review and approvals for these postage transactions occur upfront at the agency level, not through a NH First approval workflow. DHHS and DAS will work together to document adequate evidence of this upfront review and approval.

NHED concurs with the finding identified with the expenditures of $3605. The NHED will have the LEA’s submitting for indirect costs after September 30th upload an invoice and back up documentation into GMS. The NHED concurs with the findings identified with expenditures of $5,172. There were in fact some items that were charged outside the period of performance. This happened prior to us receiving the FY22 audit finding and putting in place new controls to prevent. We have since put into place DOE-OBM-33 to ensure payments are being reviewed closely to the period of performance at multiple times. We have also corrected any items charged to the wrong CAN. The NHED concurs with the findings identified with expenditures of $816. We will look into the district returning these funds or other enforcement actions. In addition to the DOE-OBM-033 process, the Division of Learner Support has created and implemented a transfer of funds procedure.

Individual Responsible for Corrective Action: Linda Fleischman, Registrar Corrective Action: The Registrar’s Office will reach out to Jenzabar to determine what is triggering the incorrect program start date. Beginning with the summer 2024 students, each new student record will be reviewed prior to the initial National Student Clearinghouse submission to ensure that the start date is being reported correctly. Anticipated Completion Date: August 15, 2024

Names of Responsible Individuals: Brandon Rhone, Analyst Financial Aid Systems, Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual to an automated review process. The COA data that was inputted at the beginning of the award year did not match all budget components causing inaccuracies. The Financial Aid office was adjusting the budget components of the COA manually, which resulted in miscalculations. When these calculations were performed COD might not have been updated and therefore the COA could be inaccurately reported. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes. The Financial Aid office will review all student COA calculations to ensure that the COA used for originating and disbursing funds is correct. The Financial Aid office will set up automatic processing of key reports to identify rejected origination records. The Financial Aid office will set up the Direct Loan COD Reject Report (DCRR) and the Pell COD Reject Report (PCRR) to run Sunday night and be available Monday morning to be reviewed by the Financial Aid Advisors. The Financial Aid office will make the necessary corrections and update by the end of the week. The Financial Aid office will run Batch FA Transmittal Register (FATR) to confirm that all anticipated awards have passed all rules and are ready to transmit. Those that don’t pass will be reviewed and students will be contacted for updated/corrected information. COD records will be exported nightly through an automated process to ensure all deadlines are met and that we are not exceeding the 15 calendar day limit. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which will eliminate the need for any manual calculations of COA. This automated process should eliminate improperly calculated COAs. Anticipated Completion Date: June 30, 2024

CORRECTIVE ACTION PLAN March 26, 2024 City of Roanoke, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2023 The findings from the June 30, 2023 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2023-001: Workforce Investment Opportunity Cluster - Assistance Listing #17.258117.259 / 17.277 / 17.278, Subrecipient Monitoring Condition: During our review of subrecipient monitoring, we noted that the City's monitoring was not being performed according to the formal written policy. While monitoring was performed and documented during the second half of fiscal year 2023, there was a lack of evidence of testing and suggestions to the subrecipient during the first half of fiscal year 2023. Criteria: According to 2CFR 200.33l(a) of the 0MB Compliance Supplement, the City should make subrecipients aware of award information. According to the City's Program Participant Monitoring Plan, the City is supposed to conduct subrecipient monitoring on a semi-annual basis which should include desk reviews of payroll, disbursements, and other financial items. Cause: Staff turnover, particularly for the role of grant accountant, caused these procedures to be overlooked. Management prioritized core operating activities with staffing vacancies in lieu of monitoring activities. Management asserts staff went onsite to review key documents, as documented by email activities, but did not document specific items subject to review. Effect: Noncompliance with federal grant requirements with regard to subrecipient monitoring as well as an increased risk of subrecip1ent misusing funds. Questioned Cost Amount: Not applicable. Perspective Information: One out of two awards Recommendation: We recommend performing subrecipient monitoring in accordance with the City's guidelines and following the procedures laid out in the Program Participant Monitoring Plan. Corrective Action: Management concurs with the recommendation and will ensure that follow-up occurs regarding information provided by business owners. Loss of staff in this accountability area resulted in inquiry and reviews conducted by varying personnel the past few fiscal years. The Accounting Supervisor and the Accounts Payable coordinator, in the absence of a Grant Accountant, conducted the first semi-annual visit for fiscal year 2023. A grant accountant was hired in Spring 2023 along with an Accounting Manager, who were able to conduct the second visit in June 2023. Revisions to the policies and procedures were made following the June visit along with developing formalized documentation templates that show what was subject to monito ring. Fiscal year 2024 monitoring in January 2024 has been completed with follow-up to occur in June 2024. 2023-002: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's disbursements related to the program, it was noted that procurement policies were not being followed. In 3 of 25 instances, credit card purchases were not properly approved. Criteria: CSLFRF funds may be used for eligible expenses subject to restrictions set forth in Treasury's Interim Final Rule and Final Rule at 31 CFR Part 35. Also, 2 CFR Part 200 section 303 requires effective control over, and accountability for, all funds. According to the City's procurement policy, department managers and directors are supposed to review and approve credit card purchases on a monthly basis. Review includes ensuring appropriate supporting documentation is included. Documentation should support that transactions are for allowable expenses. Cause: Though the City has controls that push compliance, monitoring and enforcement by Finance is lacking. Additionally, the volume of transactions make monitoring challenging. Some transaction support and approval are routed electronically through US Bank for automation, but there are thousands of monthly transactions. Effect: Noncompliance with federal grant requirements with regard to disbursements. Questioned Costs: Not applicable. Perspective Information: Three out twenty-five transactions Recommendation: We recommend disbursing funds in accordance with the City's procurement policy including a process that requires approval of all credit card purchases. Corrective Action: Management concurs with the recommendation and will ensure that procurement policies including those over credit card purchases will be adhered to. Starting in fiscal year 2023 communication to department directors occurred reinforcing that reviewing and approving financial transactions is necessary under City policy. The City's Department of Finance on a monthly basis is monitoring P-Card compliance and has enhanced communication of internal deadline dates for coding and approving transactions. Follow-up is performed by the Accounts Payable coordinator to address issues with individual users and departments who have unapproved transactions. This practice will continue moving forward with issues of continued non-compliance by users and directors potentially resulting in revoking privileges of using city purchasing cards. 2023-003: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's revenue loss calculation, it was noted that one revenue figure was not supported by the City's transmittal form causing the lost revenue available for the City to claim to be understated by approximately $4.8 million. Criteria: Under the Final Rule, recipients can elect a one-time "standard allowance" of $10 million (not to exceed the recipient's award amount) to spend on the "provision of government services" during the period of performance. Alternatively, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the Final Rule to determine the amount of SLFRF funds that can be used for the "provision of government services." According to the 0MB Compliance Supplement section 4-21.027 section III B, recipients can choose whether to use calendar or fiscal year dates but must be consistent through the period of the performance and must provide auditors with evidence supporting their revenue loss calculation. Cause: The calculation of revenue loss was performed by staff who was new to their role with the City. All figures agreed with the Auditor of Public Accounts (APA) transmittal except for one section. Supervisory review was performed but did not detect the inconsistency in the calculation with reported figures on the APA transmittal form. Effect: Noncompliance with federal grant requirements with regard to lost revenue, understating the available revenue loss the City can utilize. Questioned Cost Amount: Not applicable. Perspective Information: Three out of twenty-five transactions Recommendation: We recommend that a process be put in place that ties out all amounts used on the lost revenue calculation to amounts on the transmittal form. Corrective Action: Management concurs with the recommendation and will ensure that the APA transmittal is used for future calculations as necessary. The calculation will be subject to multiple reviews. A final ARPA revenue loss calculation is planned for the spring that will incorporate the updated revenue loss figures from fiscal year 2023 ACFR and update the reporting figures in the fiscal year 2022 ACFR. The City's plan for ARPA spending currently does not plan to utilize the entire revenue loss funds but instead seeks to spend on specific projects that are ARPA eligible. If the Federal Audit Clearinghouse has questions regarding this plan, please call Andrea Trent, Financial Management Consultant at 540-853-5224. Sincerely yours, Andrea F. Trent Financial Management Consultant

FINDING 2023-002 – Special Tests and Provisions-Enrollment Reporting- Significant Deficiency Over Internal Controls Over Compliance Recommendation: We recommend the University develop additional procedures to monitor the accuracy of information reported to NSLDS. One additional monitoring control could be to review a sample of students within NSLDS after each roster file response to ensure that the enrollment status is accurate and that permanent address changes were processed. Each institution has access to correct information directly within NSLDS at any time. Corrective Action Plan: The University will contract with a third-party servicer the National Student Clearinghouse to ensure accuracy and timely reporting of the Enrollment Reporting function also known as the SSCR Report to NSLDS. The National Student Clearinghouse will work with both the Executive Director of Financial Aid and Registrar to ensure accuracy of student status reporting and dates needed for reporting (including but not limited to effective dates and graduation dates) that will be reported on behalf of the California University of Science and Medicine. In collaboration with the National Student Clearinghouse, we will change the file roster schedule to every 30 days immediately to report within the 60-day requirement as recommended. The Registrar moving forward will have access to NSLDS and receive the appropriate training on how to use NSLDS and update and enter student permanent addresses. Responsible Party Contact: Regina Maldonado National Student Clearinghouse Senior Implementation Coordinator rmaldona@studentclearinghouse.org Anna Cosio California University of Science and Medicine Executive Director of Financial Aid Anna.cosio@cusm.edu (909) 490 -5906 Don Nguyen California University of Science and Medicine Registrar Don.Nguyen@cusm.edu (909) 966- 5085 Expected date of corrective action: The corrective action will be implemented in April 2024

Finding 2023-202: Multiple Grants – Federal Funds Accountability and Transparency Act Reporting Planned Corrective Action: The DCF Bureau of Finance will review the current FFATA query design and adjust the query to ensure reporting occurs the month following the subaward date. Until the query adjustments are made, the bureau will manually review contracts to ensure timely reporting. Anticipated Completion Date: The bureau will complete manual reviews by April 30, 2024 and will implement query adjustments by December 31, 2024. Person responsible for corrective action: Rachelle Armstrong, Director Bureau of Finance Rachelle.Armstrong@wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-307: Coronavirus State and Local Fiscal Recovery Funds – Unallowable Costs. This is the department’s response.  Recommendation (2023-307): Coronavirus State and Local Fiscal Recovery Funds – Unallowable Costs We recommend the Wisconsin Department of Health Services: • Review its current procedures for approving invoices related to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program to ensure the steps required for approving invoices are appropriate and documented, and that documentation is maintained either in STAR or in a central location accessible in the event of employee turnover; • Take additional steps to ensure that expenditures charged to the CSLFRF program are within the period of performance; • Provide training to staff responsible for approving invoices to ensure staff understand what documentation is required to support approvals and the required period of performance for the CSLFRF; and • Work with the Wisconsin Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs related to the CSLFRF program. Wisconsin Department of Health Services Planned Corrective Action: As CSLFRF programs have matured, DHS has continually reviewed and revised our processes. We will take this opportunity to ensure that procedures surrounding approving of invoices, storing of documentation, and comprehension of the period of performance are updated and understood by our grant administrators, including providing training as necessary. DHS will work with DOA and US Treasury to resolve the questioned costs. Anticipated Completion Date: September 30, 2024 Person responsible for corrective action: Christina Isenring, Director Bureau of Operations, Division of Public Health christinam.isenring@dhs.wisconsin.gov

FINDINGS - FEDERAL AWARDS AND QUESTIONED COSTS MATERIAL WEAKNESS 2023-001 - CONTROLS OVER PERIOD OF PERFORMANCE Recommendation: The auditors recommend the Association implement internal controls and procedures to ensure expenditures are recorded in the proper period. Actions Taken or Planned: During the fiscal year end closing process, invoices will be closely examined to determine proper cut-off procedures are applied and invoices will be matched and recorded in the period that the service is performed and/or the goods are received. In addition, education will be strengthened for Grant Principal Investigators to aid in the determination of recording invoices in the correct fiscal year. Person(s) Responsible: Grant Principal Investigators, Controller, Director of Financial Reporting and Compliance and the Chief Financial Officer. Estimated Date of Completion: The plan will be incorporated into our processes immediately to allow for ample time for education and refinement. The plan will be fully implemented by August 31, 2024.

2023-007 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate student programs and program beginning dates reported to NSLDS. The financial aid office cross references program information within the student information system. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

Corrective Action Taken or Planned: The University has experienced changes in staffing for personnel involved in enrollment reporting and system irregularities with multiple programs with the National Clearing House. These inconsistencies have caused delays in processing and response to enrollment reporting changes. Antioch University has hired a new Director of Records Administration with a primary responsibility for NSLDS reporting. The University will implement a comprehensive training plan for new individuals and teams, including improved documentation of procedures, increased clarity regarding the process for the necessity of error resolution, and a review of system processing to help reduce errors in reporting and increase efficiency. In addition, internal reviews and control audits will be performed throughout the year to ensure accuracy in NSLDS reporting and alignment with the National Clearing House guidance. Person Responsible for Corrective Action: Maureen Heacock, the Registrar and Katy Stahl, Executive Director of Financial Aid & Scholarships are responsible for executing the corrective action plan. Anticipated Completion Date: Fiscal year 2024

Finding: 2023-001 Condition: The Organization drew down the FY 2023 Bridge Access Program grant funds in full upon receipt of the award in the amount of $19,507 in advance of incurring federal expenses. The Organization identified allowable expenses which were incurred prior to receipt of the grant award and during 2024, management worked with HRSA to submit and obtain approval for a budget revision, enabling the Organization to apply the funds to the pre-award costs. lndividual(s) Responsible for Corrective Action: Kim Harrison, Chief Financial Officer Planned Corrective Action: 1. For any grant award, the person developing the budget, most often the CFO, will refer to the Grant Allocation file and ensure that any salaries charged to the grant are not covered by another grant for that same time period. 2. The CFO will review the budget with the Controller and Senior Accountant together and ensure the expenses to be charged to the grant and the time period for the grant is clear. 3. Prior to any HRSA drawdown, the CFO will request a list of expenses charged to the grant in question to ensure the money has been expended. 4. The CFO will share the drawdown data with the Controller. Anticipated Completion Date: Some of this is already occurring but the entirety of this will go into effect immediately.

Recommendation: We recommend that the Department review and enhance its procedures and controls to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A correction will be made to reduce the request by the overstated (by 1 day) amount in the 3/31 payroll report. A credit was issued to FEMA for the amount of $19,871.26 on Monday March 13, 2023 in relation to the finding noted. Name(s) of the contact person(s) responsible for corrective action: Angelia Adediran, Deputy Director City of Richmond Fire and Emergency Services

Finding 2023-001 Federal Program Information Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: July 1, 2020 to June 30, 2023 Corrective Action Planned: Management agrees that certain expenses to the COVID department were not reviewed and approved at the order entry level in specific cases. Although evidence of review was not retained for every charge to the COVID department, we believe the appropriateness of the charge was reasonable. Additionally, based on monthly review of departmental expenses and full-time equivalent (FTE) analysis at the facility level, we believe that these expenditures are subject to the appropriate level of review to identify unexpected variances. As it relates to the COVID Activity Code, this code was created as a means to track certain COVID hours worked, but was not configured to calculate the amounts associated with those hours, resulting in the need to make reasonable estimates. Even using the base pay rate at the time the hours were incurred would not have been accurate since it would omit adjustments for shift differentials, weekend hours, and overtime. We performed internal analyses and reviewed the results of samples selected by the auditors and concluded that the risk of a material overcharge to the program was minimal. Further, we have almost $40 million of unused lost revenues after our final PRF submission for Period 5, such that any questioned costs would easily be covered by other eligible uses of PRF funds. We have reviewed our processes related to the retention of expense documentation to improve audit evidence should this program ever be awarded in future periods. Responsible party: Lee Sonne, Vice President of Finance and Controller Implementation Date: Procedures were reviewed and analysis completed along with the Period 5 portal filing in September 2023.

1. Person responsible: Division Chief, Auditor-Controller Accounting Division 2. Corrective action plan: The County agrees with the finding and recommendation. The County will review CSLFRF claims and verify that all claimed payroll expenditures were incurred or obligated on or after March 3, 2021. Payroll expenditures that were incurred or obligated before March 3, 2021, will be removed from the CSLFRF claims. 3. Anticipated implementation date: June 28, 2024

2023-003 Cash Management / Period of Performance – Control Deficiency View of Responsible Officials Management appreciates the opportunity to respond to the findings of the audit. The Hawaii State Public Library System (HSPLS) makes every attempt to meet all federal laws and guidelines for funding that is received. Many factors outside our control directly impacted the timely payment of vendors as noted in the audit. Specifically: 1) Federal budget uncertainty; delay in receiving federal funding. For the past several years, Congress has not been able to pass a comprehensive federal budget, and instead has funded the Grants to States fund via continuing resolutions making it difficult to plan out expenditures with any certainty. In addition to lacking the certainty of when and/or if funding will be available, the Grants to States funds have not been released to states in a timely manner, including during the audit period. Instead of at the beginning of the federal fiscal year around October 1st, funding has been received months later, leaving States with a lot less time to procure, process and receive purchases. This means we do not have access to the funding for the full grant cycle and directly impacts if/when we are able to procure goods and services. 2) Supply chain and shipping issues. The State of Hawaii procurement requirements do not allow us to pay for goods and services until we receive the products or the services are rendered satisfactorily. HSPLS continues to face significant supply chain and shipping issues which affects the timely payment of vendors. As an island state in the middle of the Pacific Ocean, there are often delays in receiving an entire shipment on time in full, even post-pandemic. For large products or orders, sometimes the order and/or related parts are not shipped together further delaying completion of the order by the vendor and issuance of the invoice. In many instances, vendors do not send their invoices in a timely manner, preventing HSPLS from dispersing funds in a timely manner. 3) Federal agency guidance. We would also like to note that in the past, we have contacted our funding federal agency and let them know that we have had challenges with supply chain and shipping issues. We were advised that it was understood, and that as long as we had encumbered the funds by September 30, that we would be able to use the funding that was allotted to us even if the invoice is received after the close of the federal fiscal year. Corrective Action Plan We will do our best to continue to monitor and minimize any untimely disbursements of federal funds. Contact Person: Stacy A. Aldrich State Librarian Hawaii State Public Library System Anticipated Completion Date: Ongoing

Federal Agency Name: Department of Treasury Pass‐Through Entity: Equal Justice Wyoming and Wyoming Department of Family Services Assistance Listing Number: #21.023 Program Name: Emergency Rental Assistance Program Finding Summary: The Medical Center was not able to provide supporting invoices for two of the testing selections. An additional selection contained a keying error. Responsible Individuals: Amy Spieker, Director Community Health and Analysis, and Erika Novick, Operations Manager Corrective Action Plan: The Program Director and Operations Manager will ensure all invoices are properly submitted and approved prior to including the expenses in the reimbursement requests. Program Director/Director of Community Health and Analysis will review draws/invoices to ensure amounts on supporting documents agree to the amounts submitted in the reimbursement requests. Finance will also revise Corporate Card Policy by June 30, 2024, to include expense reports being submitted in a timely manner. Finance will review open expense reports with card holder and their supervisor monthly. Anticipated Completion Date: April 1, 2024

FINDING: 2023-004 CONTACT PERSON: Kathy Rivers - Community Development Director / 864-595-5306 / krivers@spartanburgcounty.org CORRECTIVE ACTION: The County will work diligently to make every effort to meet HUD’s time expenditure requirements. PROPOSED COMPLETION DATE: June 30, 2024

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District is conducting a review of its processes for NSLDS reporting to improve accuracy and has provided training to ensure multiple individuals are able to perform the necessary procedures for submitting NSLDS reports. Implementation Date: In Progress

Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: Corrective action has been taken to ensure that when students have a spring start date in the prior academic year, the enrollment start date is updated to the correct enrollment start date. A cross check with a selection set has been added to capture any incorrect records and adjust accordingly. Anticipated Completion Date: January 3, 2024

FINDING: 2023-004 Internal Control and Compliance over Period of Performance Recommendation: We recommend the Partnership establish procedures to ensure the funds are obligated and utilized in the proper period of performance. Action taken: Community Partnership is working with our state association, CAAP, to update internal controls and fiscal policies. Procedures to ensure that obligated funds are spent and utilized within the proper period of performance will be included in updated fiscal policies. Most of these issues resulted from the separation with our previous accounting/fiscal services provider who managed our fiscal and accounting services in the 2022 funding period. CP has worked to satisfy almost all outstanding obligations from this separation during the 2023 CSBG funding period, and currently has no outstanding obligations from the 2023 CSBG funding period. Moving forward, CP staff will work diligently with our selected vendor and board of directors to ensure that all funds are spent down within their designated funding periods.