Corrective Action Plans

Recommendation: CLA recommends that the University review the requirement and implement a monitoring control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the University should return the funding to the U.S. Department of Education.

Explanation of disagreement with audit finding: There is no disagreement with the audit finding.

Action taken in response to finding: The University agrees with the auditors’ recommendations of corrective action needed to ensure unclaimed Title IV federal funds are resolved within 240 days of disbursement date. The University has reviewed existing processes and identified improvements that will be made to internal procedures to ensure proper compliance is met.

Name(s) of the contact person(s) responsible for corrective action: Delora Shoop, Director of Accounts Receivable

Planned completion date for corrective action plan: 12/31/2023

Caseworker will check task for Ex parte task and work case within 3 days. Caseworkers will received additional training on documentation, NCFAST evidence, resource calculations and countable/noncountable resources to remind workers of the procedures and policies that should be followed at time of application and recertification process. Supervisors will conduct second party reviews on applications and recertification’s to determine that the correction is being taken. Workers will be retrained on NCFAST evidence for resources to ensure procedures are being followed for evidence on dashboard to match the supporting documentation used as verifications. Supervisors will review cased to evidence and supporting documentation match and cases show consistency. Supervisors will review cases to ensure evidence is inputted correctly and accurate needs units in eligibility is used in determination of benefits. Proposed Completion Date: January 31, 2024

The Finance Director will make sur charges are allowable when expensing infrequent or unusual transactions to federal grants and use the Uniform Guidance Selected Items of Cost section when something may be in question. This plan is implemented effective 2/12/2024. The Finance Director will work with the Executive Director and the Director of Performance Management to ensure clear guidance is reflected in policy and procedures on the allowable use of federal awards and included in our current Policies and Procedures with approval of the WECA Finance Committee. If there are any questions regarding this plan, please call Candace Duerst at 608-729-1024.

Identifying number: 2023-002 Significant Deficiency Federal Emergency Management Finding: Procedures were in place to identify and report eligible employee costs but not appropriately followed or reviewed which resulted in certain questioned costs. Action taken or planned: In fiscal year 23-24 the City moved all grant administration to a designated grant department. The duties of the grant administration department are to track, vet and confirm compliance with applicable guidelines on the grants the City applies for. Additionally, the grant administration department will actively assist with submission and seek new grant opportunities and will be available to train City employees on proper grant documentation and substantiation. The City engages outside consultants to review grant submission and the City is engaging this outside consultant to review the grant submissions more often throughout the year than previously engaged to allow more time to adequately review and obtain all necessary information for grant compliance. Any questions regarding this plan should be directed to Kathy Panas, Finance Director at 405.359.4521.

Planned Corrective Action - The BCSD will require the Davis-Bacon Act provision clause in future contracts for federally funded contracted services. The wage rate clause will be required along with requiring weekly payrolls to be submitted to the district finance office to ensure the federal wage rates established by the United States Department of Labor are followed. The BCSD will report questioned costs or corrective action needed to the FDOE. Anticipated Completion Date - 1/31/2024 Responsible Contact Person - Shannon Rodriguez, Director of Finance

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to track students who both received a loan and have dropped classes within Western Seminary’s SIS. From the Spring 2024 semester, we require attendance to be tracked in all classes, including in-person classes. We historically already track attendance of online courses. Financial Aid and the Business Office will have access to regularly scheduled reports to quickly identify when students stop attending class to determine whether an R2T4 form is required and should be processed. Person Responsible for Corrective Action Plan: Jonathan Gibson, CFO Anticipated Date of Completion: June 30, 2024

The Clinton Township Housing Commission Board has been reeducated, by our Fee accountant about the proper use of HUD Funding. The CTHC board understands that HUD funds CANNOT be used in to provide any type of Bonuses to staff and or any of its affiliates. All Commissioners will attend Commissioner’s training to insure proper education on their roles and expectations.

2023-002 Crime Victim Assistance – Assistance Listing No. 16.575 Recommendation: WON should implement a process to complete time and effort certifications and reconcile those certifications to ensure the costs reported to the grantor are accurate. All additional amounts paid contain documentation that they are properly authorized. All employees should have timesheets to support the hours worked and charged to the grant. These timesheets should be formally approved by a supervisor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Women of Nations has updated its payroll policies and procedures to ensure that time and effort certifications are completed correctly and approved in a timely manner by supervisors. Name(s) of the contact person(s) responsible for corrective action: Charles Nelson Planned completion date for corrective action plan: June 1, 2023

The District will review the expenditure reports and compare to the general ledger to ensure agreement before the reports are submitted.

Incorrect Pell Calculations Planned Corrective Action: The process for awarding and disbursing summer Pell Grants is being discussed. The new process will involve a thorough review of summer enrollment. Aid will disburse for session 1 and session 2 after the last day to add or drop a course. The director will oversee summer awarding and the senior associate director will assist by providing necessary reports. Person Responsible for Corrective Action Plan: Karen Benfield, Director of Financial Aid Anticipated Date of Completion: This process will be finalized by June 2024.

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University document review of Return to Title IV calculations by an employee that did not prepare the calculations. We also recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and disbursed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial aid personnel will implement Return to Title IV FSA calculation spreadsheet for additional backup support in determining if banner has calculated return amounts correctly. Additionally, financial aid will require all R2T4 calculations to be secondarily reviewed and confirmed in RHACOMM. The scheduled breaks for each semester will be determined by the Director of Financial Aid and given to the Registrar to be input into banner module SOATBRK. These breaks are what banner then uses for Return to Title IV purposes. Update procedures to reflect additional actions. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24

The District will update the annual calculation to include a comparison of the base used for the indirect cost adjustment. Upon identification of the overcharge, the District posted a correcting entry to reduce the indirect costs of the program.

U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individuals: Melissa Sobolik, CEO and David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP and CSFP programs have proper signatures by necessary parties going forward. An electronic signature process has been implemented to make the dissemination, review and storage of this process easier. Anticipated Completion Date: Immediate

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: The University understands and concurs with the incorrect and untimely return of some Title IV funds. In response, the University has taken three (3) immediate steps to address this deficiency in the future. First, the institution has added financial aid staff with significant expertise and experience in the administration of the R2T4 process to periodically review standard and modular students R2T4 to ensure accurate, timely and compliant returns and reporting. Second, the University has identified policy and procedure improvements that align with best practice approaches to R2T4 administration in support of Pell recalculations and accurate return of funds. Finally, the institution has identified professional development opportunities for all financial aid, and associated personnel, to improve theoretical and practical awareness and implementation of the return process i.e., conference/webinar participation, in-house training workshops and discussions, identified liaison/unit champion roles, etc. Person Responsible for Corrective Action Plan: Michael Mathis, Director of Financial Aid Anticipated Date of Completion: January 2024

FINDING 2022 – 003: Repeat of Prior Year Finding 2021-008 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Overaward of Title IV Funds Criteria: Title IV regulations (34 CFR 685.203) states in no case may Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loans were intended, less (1) the student’s estimated financial assistance for that period and (2) the borrower’s expected family contribution for that period. Condition: During testing the auditors noted two instances where the University awarded a Direct Unsubsidized loan to a student that caused the student’s financial assistance received to be greater than the student’s cost of attendance. Corrective Action: At the time of these findings, all Wheeling University Financial Aid processing operations were being conducted manually. The high level of complexity commonly associated with financial aid processing creates an environment, especially when conducted in a manual format, that is error-intrinsic. Packaging and awarding for each of the federal student aid programs are currently conducted by using the student information system, Colleague, which allows the FA office to perform these processing operations in a fully automated manner. Proper use of the “auto-packaging” feature provides significant assurance that student awards will not exceed financial need based on Cost of Attendance (COA) and Estimated Family Contribution (EFC). Previous audit findings have noted a general lack of accuracy, organization, and documentation regarding the final figure for the COA, which can result in packaging and over-award errors. As such, the Acting Director of Financial Aid has completely extensively researched and input data into the system with an accurate, fair, and equitable formula for arriving at a COA while meeting student need and, consequently, reducing or eliminating the potential for over-awards. This data was obtained from state and local cost of living figures, input from other similar state schools, and by use of the higher education organization, the College Board. This data is available as a reference for future documentation and review in a shared electronic file. Anticipated Completion Date: This process was completed in March of 2023 and is ongoing.

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Contact Person: Vanessa Bonfim Anticipated Completion Date: March 6, 2024 Planned Corrective Action: • In order to ensure that correct claim numbers are submitted to AZ Department of Education, the Food Services Department will perform double monthly checks when claims are entered into ADEConnect website, before actual submission. • Claims are entered into ADEConnect by the Food Service Liaison and double check will occur at the same time by the food service supervisor. • Monthly scheduled time will be set once a month to process claims.

Name of Contact Person: Carolyn Moser, Health & Human Services Director Corrective Action/Management’s Response: Audit Finding Review Training is held with Family and Children's Medicaid to review Audit results and errors found. Verification sheet for F&C Medicaid are reviewed. This form is to be used for every application and recertification. Additional trainings/unit meetings are also held throughout the year. Areas covered are review of: Child Support referrals, income, verification of Social Security Number, tax household, household relationship, reacting to changes, addresses, and OVS. Ongoing trainings continue. Individual conferences are held with each worker with an error. During the conference, the case record is reviewed along with policy, error explanations and steps to take to prevent error from reoccurring. Each quarter Pender County is required to submit to the State a Quarterly Report of cases 2nd party reviewed along with verification of trainings held, agendas and attendance sheets. Pender is required to review over 120 cases per quarter. There are several Medicaid Supervisors. Each month supervisors pull cases from each worker to 2nd party review. Supervisors meet with each worker that they have an error or internal control issue. Errors and internal control issues are discussed monthly at Unit meetings. Policy, manual changes, Admin letters, job aids and other information are also discussed and reviewed monthly during Unit meetings. Proposed Completion Date: Immediately and ongoing.

Finding Number: 2023-007 Finding Synopsis: During the audit, we determined that the District was not properly reviewing Special Education Cluster expenditure reports and were unable to provide documentation showing the specific expenditures being submitted for reimbursement. Action Steps: The District will implement a process to properly track grant expenditures and create an improved review process. Contact Person: Jeffrey Schubert, Chief School Business Official, 779-244-1000 Anticipated Completion Date: 6/30/2024

Finding – Eligibility – Federal Direct Student Loan Program, Assistance Listing Number 84.268 and Federal Pell Grant Program, Assistance Listing Number 84.063; June 30, 2023 Award Year; U.S. Department of Education Criteria or Specific Requirement The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR Section 690.62(a)).The annual maximum loan amount an undergraduate student may receive must be prorated when the borrower is enrolled in a program that is shorter than a full academic year; or enrolled in a program that is one academic year or more in length, but is in a remaining period of study that is shorter than a full academic year. (2022 - 2023 Student Financial Aid Bank Book, Volume 3, Chapter 5, 34 CFR 685.203(a),(b),(c)) Condition Of the 40 students selected for eligibility testing, two students were incorrectly awarded student financial assistance; one student was incorrectly under-awarded a Pell Grant and the other student was over-awarded a Direct Loan. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will implement regular periodic quality control checks, utilizing enhanced reporting and dedicated staff resources to ensure student aid is being appropriately calculated and awarded based upon relevant student enrollment and financial information. Names of Contact Persons Responsible for Corrective Action: Anne-Marie Caruso, Associate Vice President, Student Financial Services Anticipated Completion Date: November 30, 2023

Finding Number 2023-003 • Significant deficiency in internal controls over compliance related to procurement. Federal Agency: U.S. Department of Commerce Program Title: Pacific Fisheries Data Program Assistance Listing Number: 11.437 Award Numbers: NOAA-NMFS-AK-2023-2007663 Award Period: October 1, 2022 to September 30, 2027 Criteria • 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Procurement Standards require that awardees use documented procurement procedures for the acquisition of property or services required under a Federal award or subaward. Condition/Context for Evaluation • IPHC's internal controls over procurement do not include the controls and procedures required by 2 CFR 200. Questioned Costs • Not applicable. Cause • IPHC has not yet modified its procurement policies with the requirements of the 2 CFR Part 200 Procurement Standards. Effect or Potential Effect • As a result, IPHC cannot be certain that procurements were conducted in accordance with the 2 CFR Part 200 Procurement Standards. Repeat Finding • Not applicable. Recommendation • We recommend that IPHC update its procurement policy to include all procurement requirements of 2 CFR Part 200. - Procurement standards 2 CFR 200 Subpart D or 200.318-200.327 - Requirement for documented policies consistent with standards 200.318(a) Contact Person(s): • Executive Director: David Wilson (david.wilson@iphc.int); • Assistant Director: Andrea Keikkala (andrea.keikkala@iphc.int) Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable. Corrective action planned: As this was the IPHC’s first full GAAP Audit, Single Audit of federal grant funds, and also our first year transitioned from a Cash-basis of accounting to an Accrual-basis of accounting, there are a number of policies and procedures that are in the process of being amended. It will take the Secretariat several months to bring our written process guides into alignment with “2 U.S. Code of Federal Regulations (CFR) Part 200”, as well as our Financial Regulations (2021) that will be considered for amendment at the upcoming 100th Session of the IPHC Finance and Administration Committee (FAC100) and subsequent 100th Session of the IPHC Annual Meeting (AM100) in late January 2024. During the 2nd quarter of FY2024 (1 January – 31 March 2024) the IPHC will undertake a thorough review of “2 U.S. Code of Federal Regulations (CFR) PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS” and update our procurement policies and processes accordingly. Anticipated completion date: Deadline: 1 April 2024.

Finding Number 2023-002 • Significant deficiency in internal controls over compliance related to allowable costs and period of performance. Criteria • 2 U.S. CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards require that costs must be necessary and reasonable for the performance of the Federal Award, that costs be determined in accordance with GAAP, and that costs be adequately documented including the allocation of those costs. Condition/Context for Evaluation • IPHC’s internal controls over non-payroll charges to the Federal Award did not include review for allowability, accrual in the proper period, or that adequate documentation existed to support the amounts charged or allocated. Three out of 25 nonpayroll disbursements tested did not include evidence supporting one or more of these controls. Questioned Costs • $2,674 Cause • IPHC’s operation of internal controls were not sufficient to ensure allowable costs were charged in accordance with 2 U.S. CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Effect or Potential Effect • As a result, charges were made to Federal awards that were not allowable. Repeat Finding • Not applicable. Recommendation • We recommend that IPHC ensure internal controls include reviewing costs charged to the Federal Award for conformity with 2 U.S. CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for allowability, allocability, and reasonableness. o Allowability 200.403, 200.404, 200.405 o Allowable budget period – 200.403 (h) Contact Person(s): • Executive Director: David Wilson (david.wilson@iphc.int); • Assistant Director: Andrea Keikkala (andrea.keikkala@iphc.int) Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable. Corrective action planned: We acknowledge that the deficiencies identified, while minor in dollar value to the grant, represent areas for improvement. The specific issues identified were: 1. Field office rental: A field office rental statement was partially charged to the incorrect fiscal year. Reason: The landlord submitted the invoice for payment after the year-end close (FY2022) and was subsequently fully charged to FY2023, instead of being split across fiscal years. 2. Postage (2 elements): The IPHC loads postage stamps on a stamps.com account to process missing logbook notices to vessel owners, a function that pertains to a grant. Clear delineation of the cost of the stamps allocated to the grant and the stamps allocated to activities that do not qualify under the grant were not enumerated. The employee that requested the stamps in the procurement software did so because the lead team member was not available. When procuring the stamps the face-value of a stamp was used at $0.60 instead of $0.57, a discount the organization receives due to bulk purchase and stamp.com membership. The cost of this error was $9.96. At the start of FY2023, we used a single operating Fund (Fund 30 – Statistics) to record income and expenses for data related activities that included some grant funds. During the course of the year, we commenced the development of the new 5-year grant application with NOAA Fisheries to cover IPHC’s Directed Commercial Catch Sampling of Pacific halibut in Alaska (IPHC Grant 802) (Grant Number: NOAA-NMFS-AK-2023-2007663) from FY2022-FY2026. During this grant renewal/development process, a decision was taken to split Fund 30 – Statistics into two, with Fund 35 AK Cost-Recovery being created. This new Fund 35 was developed to contain only those expenses and income that were deemed as eligible under the grant rules. Over the course of the year, the Secretariat categorized income and expenses between the two Funds, which involved recoding some transactions coded to Fund 30 at the start of the fiscal year, to Fund 35 later in the year. For FY2024, we will continue to undertake monthly reconciliation and month-end close processes to ensure charges are appropriately coded and attributed. In addition, the year-end reconciliation and close processes will support the attestation of funds spent under the grant within one month of the fiscal year ending. This proactive approach aims to ensure timely completion for the single audit, allowing for comprehensive scrutiny of costs assigned to the grant before incorporating financial statements for review during the single audit process. Further, we will ensure preliminary scrutiny and month-end close of financial reports pertaining to grant funds before loading them to the auditors for review. Finally, our procedures have already been improved to ensure that costs charged to the federal awards are charged to the appropriate activity code and are allowable under federal cost principles. Anticipated completion date: Completed - 1 December 2023, and annually by year-end closeout.