Corrective Action Plans

Higher Education Emergency Relief Fund (HEERF) Earmarking Planned Corrective Action: Funds are to be returned. Person Responsible for Corrective Action Plan: Gary E Estes, Director of Accounting Anticipated Date of Completion: June 2024

2023-003 Reporting (Financial) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: OSFP was notified of the error in reporting the correct cost of attendance to the Common Origination and Disbursement (COD) system and the code was changed to prevent the error from reoccurring. The correct cost of attendances are now being reported to COD. A testing plan has been developed that includes confirmation that all system start and end dates align with the University’s published academic calendar. Anticipated Completion Date: Completed

Finding 2023-006 Period of Performance Condition: Northern Illinois University (the University) charged an expenditure to the grant whereby a portion of the expenditure had a service period extending beyond the grant's period of performance, and the University’s controls did not detect the error. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) The University will provide additional training on cost allocation to staff. 2) University is taking immediate steps to resolve the questioned cost. Individual(s) Responsible for Corrective Action: Sponsored Programs Staff Anticipated Completion Date: June 30, 2024

Finding 2023-002 – Significant Deficiency Assistance List Number: 97.039 – Hazzard Mitigation Grant Pass-through Agency: California Governor’s Office of Emergency Services, FEMA-4344-DR-CA. Compliance Requirement: Reporting. Condition: The District did not provide project closeout materials to the pass-through agency within 90 days of the end of the period of performance so the pass-through agency could prepare the closeout reporting within 120 days of the end of the period of performance. Criteria: The Notice of Funding Opportunity indicates: “In addition, pass-through entities are responsible for closing out their subawards as described in 2 C.F.R. § 200.344; subrecipients are still required to submit closeout materials within 90 calendar days of the period of performance end date. When a subrecipient completes all closeout requirements, pass-through entities must promptly complete all closeout actions for subawards in time for the recipient to submit all necessary documentation and information to FEMA during the closeout of the prime award.” Cause: The District’s staff were waiting for a requested extension for the period of performance from the pass-through agency and assumed the closeout reporting would not be necessary. Effect: The District is not in compliance with the terms and conditions of the federal award. Recommendation: We understand the District provided the information necessary to complete the closeout reporting to the pass-through agency on November 30, 2023. Views of Responsible Officials and Planned Corrective Actions: As indicated in the recommendation, the District provided the information necessary to complete the closeout reporting to the pass-through agency on November 30, 2023. Furthermore, on March 22, 2024, the District heard from the pass-through agency that FEMA received the requested extension, and it is in the queue for final approval and signature. The corrective action has been completed.

Views of Responsible Officials: Grant funds received pursuant to a period of performance or an approved drawdown or reimbursement request will be expended as specified in the request. When Federal grants are funded in advance, rather than on a reimbursement basis, the Foundation will minimize the time elapsing between the receipt of Federal grant funds and disbursement of such funds for their approved purpose. We will implement procedures to ensure that expenses are recorded or accrued properly.

The Corrective Action Plan in a continuous basis will be as follow: 1.Employment and Educational Fairs for the Youth Program are being developed to recruit out of school Youth and promote work experiences activity. 2. The Promotion and Dissemination staff began an aggressive campaign in different advertising media to recruit out of school youth. 3. The program area has already planned for the month of May and June 2024 to carry out work experience activities coordinated with private companies and municipalities. It is planned for young people out of school and in school. 4. Both the program staff and the fiscal agent will be continuously monitoring the expense and obligations to the work experience activities to comply with the 20% expense. 5.The youth committee attached to the Northwest Local Board will comprise a representative from finance, budget and planning staff (youth program and executive) who will measure the achievement of the 20% benchmark on a quarterly basis. 6.This committee will take appropriate actions in order to verify the correctness of the expenditures according to the 20% expense requirement mentioned above. 7.This committee will provide to the Executive Director, recommendations to the operational areas in order to comply to the goal of expenditures required under sections 20CFR 681,590,681,600(a)(3) and681.600 of WIOA. 8.A report will be issue to the operational levels in accordance to the recommendations adopted by the Executive Director. 9. The public policy for the implementation of the work experience element of the youth program gave the opportunity to increase 2% of youth services. 10.The Northwest Local Area has established strategies for the dissemination of services for the youth program. This is done through the integration of social networks (lnstagram and Facebook), radio, signs, press, television and official internet page. 11.The youth area, together with the promotion unit, established an itinerary of visits to the municipalities that comprise our area in order to carry out campaigns(Work Fairs)to guide our services and recruitment. 12.We will continue to join efforts through mass campaigns with an effective strategic plan to outreach the youth program. LEAD PERSONS ACCOUNTABLE FOR ACTION ITEM COMPLETION Executive Director, Area Executive, MIS Director and Finance Director

FINDING 2023-005 Finding Subject: Special Education Cluster (IDEA) – Period of Performance Summary of Finding: The School Corporation was a member of the Clark County Joint Services Program (Cooperative) during fiscal year 2021-2022. The School Corporation had not properly designed or implemented a system of internal controls to ensure transactions made from Special Education funds occurred within the appropriate period of performance. Claims for the Special Education programs were paid without an appropriate level of review or oversight to ensure the expenditures charged to each grant were within the allowed time frame. Although the reimbursement requests submitted to the Indiana Department of Education were prepared by the Corporation Treasurer and approved by the Special Education Director, the School was unable to provide tangible audit evidence of this review and approval process, which may have included a review of the costs included on each request to verify they were within the correct period of performance. Contact Person Responsible for Corrective Action: Ashley Compton, Director of Special Education and Allison Vanover, Corporation Treasurer Contact Phone Number and Email Address: 812-246-3375 alcompton@scsc.school avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Silver Creek School Corporation is no longer part of the Special Education Cooperative. The Special Education Director and the Corporation Treasurer have a standing meeting once per month to review expenditures and receipts to prepare a reimbursement. At that time, the period of performance is also checked for accuracy. The Special education director will code initial expenditures to grant appropriation lines and submit to accounts payable specialist. Accounts payable specialist then confirms that the expenditure can be taken from that line in the working grant document for the corresponding grant. Oversight and review of grant allocations and approved totals with grant budgets are reviewed monthly at the time reimbursements are completed. Anticipated Completion Date: March 2024

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

GDOL concurs with this finding: Regarding the pandemic Grants noted that were all under #UI34710-20-55-A-13: • The unemployment insurance (UI) Regular Grant typically provides the amount of available grant funds in advance based on 1.) and estimated number of claims to be processed in the current year (based on the average of two years prior activity) and 2.) the average processing times (based on the average of two years prior processing times). • In contrast, many of the pandemic grants are based on actual claims activity with monies being awarded “after the fact” with no consideration given to the aforementioned criteria as no prior- year basis exists. • GDOL experienced delays in some pandemic allocations due to delays in programing and the submission of the new reports for pandemic activities (Federal Pandemic Unemployment Compensation (FPUC), Pandemic Emergency Unemployment Compensation (PEUC) and Pandemic Unemployment Assistance (PUA)). All late reports have been submitted and we are reconciling grants as deemed appropriate. • With reimbursement based on pandemic claims activity, there was no clear mechanism for GDOL to be able to “forecast” the amount of time and effort needed to process the cyclical and unpredictable number of pandemic claims. As such, best efforts were made to estimate in this regard. • The 3073 FPUC grant is the only grant for which we have been reimbursed at 100%. However, due to the most recent implementation of stop/gain loss, we are no longer being reimbursed at the full amount. • Regarding the Employment Service/ Wagner-Peyser Funded Grants noted, the program period of performance was July 1, 2022 thru September 30, 2025. GDOL received instructions from USDOL on January 19, 2023 requesting a final ETA-9130 report be submitted by February 15th for grants that were being transferred to TCSG and offered technical assistance in completing the reports. The National office was designated to de-obligate the funds remaining and issue new grant numbers to obligate these funds at TCSG; however, several things occurred that caused the process to be delayed: o The required action was to check box 6 as yes (for the final 9130 reports) and 10g (Federal Share of Unliquidated Obligation) had to be zero although there were Unliquidated Obligations in the system. o Although the Wagner Peyer program was transferred to TCSG in January 2023, eligible costs continued. o The need for expenditure reconciliations was discussed with USDOL Regional Office and anticipated funds were drawn in lieu of billing TCSG. o Associated eligible costs were reconciled to the Wagner Peyser Ledger via manual journal entries in lieu of billing TCSG. o In addition, USDOL implemented a new GrantSolutions to replace its legacy grant processing system, E-Grants. USDOL replaced its legacy E-Grants Grantee Reporting System (GRS) by transitioning to PMS for grant recipients submission of the quarterly ETA-9130 financial reports on February 6,2023. o Although training was taken for this process, the overall reconciliation process was delayed, all reconciling items were resolved by the 9/30/23 reporting period.

Finding No. 2023-001

Corrective Action Plan

Name of the contact person responsible for corrective action

Gena Wingfield, Chief Financial Officer

Corrective action planned

During FY23 Arkansas Children’s implemented an automated tool that allows us to monitor and audit general IT controls going forward over logical access to the relevant systems. We have also strengthened our controls around provisioning and deprovisioning through formalization of our policies around privileged access and have implemented continuous auditing of sensitive roles.

As the automated controls were not in place during the full fiscal year, and therefore not tested during the audit, in FY24 Arkansas Children’s implemented temporary manual controls and processes. These controls support the review and approval of expenditures monthly to verify that they are allowable, incurred within the designated period of performance and incurred prior to reimbursement.

Anticipated completion date

2024-01-31 00:00:00

If the client does not agree with the audit findings or believes corrective action is not required, include an explanation and specific reasons

Agree with Finding No. 2023-001

The reference numbers the auditors assigned to the audit findings in the schedule of findings and questioned costs

Finding Number: 2023-001 – Period of Performance Planned Corrective Action: The item in question was a deposit for an event that took place in August 2023. It was made in June 2023. While the $24k payment was a valid payment within the grant terms, it was inadvertently recorded as an expense item in our 2023 schedule of expenditures of federal awards instead of as a prepaid asset. Upon discovery we implemented new procedures whereby payments made at year end will be subjected to an additional review to ensure they are recorded in the proper period. Person Responsible: Stephen Mack, Chief Financial Officer Expected Completion Date: Immediately

The Department will review its procedures and internal controls and update as necessary to ensure that expenditures are incurred within the allowable period of performance for respective awards. It should be noted that during the period of performance for which this audit was conducted there were a large number of personnel changes and shifts. The position that was responsible for the majority of these duties retired in January 2024. We proactively hired for her replacement a year before she retired. Over the course of the year our replacement took over more and more duties. In the process of this replacement, we have completed a tremendous amount of evaluation of our assigned duties, processes, workflow, training, and documentation. Not only in this role, but we are also undergoing a division and business unit wide analysis of our internal controls and workflow. It should also be noted that the UI admin funds are considered ‘formula funds’ from the US DOL. We are expected to run this program year-round with no gaps in service or performance. The funding that we receive from US DOL is based on an antiquated formula that breaks down the amount that is budgeted by Congress between 52 state and territories. We generally do not receive enough funding for the entire year. Also, with the recent trend of Congress to utilize the tool of the Continuing Resolution our funding is often ambiguous until most of the program year is over. We have at times seen our funding cut once a budget had been passed by Congress even though there was only about 3 months left in the program year. We are still expected to run this program and ‘find other sources of funding’. This does make the adherence to the period of performance challenging. However, as we evaluate our internal controls and procedures over the coming months, we will make note of every opportunity to strengthen this function to ensure that all charges applied to program funds are relevant, within the period of performance of the award, and are correctly reviewed and signed. Cameron Wood, UI Director, Cameron.Wood@vermont.gov Scheduled Completion Date of Corrective Action Plan: August 31, 2024

Contact person responsible for corrective action: University Registrar Corrective action: Sacred Heart University implemented a comprehensive corrective action plan in collaboration with the following key stakeholders: Sacred Heart University’s enterprise resource provider (ERP), Ellucian; the Registrar’s Office; and Sacred Heart University’s Department of Information Technology (IT). Sacred Heart University acknowledges the erroneous reporting of graduation effective dates for two students, wherein the effective start date of their first graduate course mistakenly overrode their previously reported correct graduation date. The University took decisive action to address the inaccuracies identified within a summer 2023 enrollment submission to National Student Clearinghouse for Branch 80 and Branch 81. Sacred Heart University conducted a thorough investigation with Ellucian Support to identify the source of these errors. The investigation resulted in a determination by Ellucian Support that the reporting error was caused by a software bug within its software platform, Ellucian Colleague. Ellucian developed a patch, released in October 2023, to rectify the issue. Implementation of this patch by the Sacred Heart University Information Technology department is scheduled for March 2024. Proposed completion date: March 31, 2024