Corrective Action Plans

2022-003- Education Stabilization Fund - Prevailing wage rate requirements Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts, subject to wage rate requirements, a prov1s1on that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance ( certified payrolls). Condition: There was one Education Stabilization Fund construction project performed by a subcontractor. Grant expenditures for the project paid by the Education Stabilization Fund totaled $212,979. There was not a prevailing wage clause in the contract and certified payrolls were not received. Cause: The District was not aware that wage rate requirements applied to the construction project until after it was completed. The District did verify that prevailing wage rates were paid by the contractor during the project; however, they did not obtain certified payrolls. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $212,979 Auditor's Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Grantee Response: The District will comply with the wage rate requirements for the Education Stabilization Fund going forward. Contact Person: Ashley Dake Anticipated Completion: June 30, 2023

The District will implement internal controls to monitor and ensure that the appropriate time and effort documentation of those employees paid in whole or in part with federal funds is on file to support the amount of time an employee works on a federal program. Compliance will be achieved by: 1)Develop a set of internal controls for time and effort documentation which provides reasonable assurance that charges are accurate, allowable, and allocable. (CFO/Treasurer) 2)Require time and effort documentation be filed in a timely manner with the CFO/Treasurer and maintained for records. (CFO/Treasurer ? Superintendent ? Direct Supervisor) 3)Require Direct Supervisor of employees to maintain time and effort documentation in accordance with District policies and procedures, as well as federal laws and guidelines. (Direct Supervisor) 4)Periodically monitor time and effort documentation in relationship to the percentage of time the employee spends on a federal program vs. non-federal. (CFO/Treasurer ? Superintendent - Direct Supervisor)

93.767 Children' s Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Reporting 2022-026 Ensure Compliance with Reporting Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: DOM Concurs. DOM identified this issue during reporting of the March 31, 2022 federal expenditures. Per 45 CFR ?95.1, DOM has two years (seven quarters following the occurrence of the expenditure) to make adjusting entries to claim additional expenditures. DOM Does not Concur. DOM has fully corrected finding 2021-041 on the Schedule of Prior Year Findings. This finding is based on OSA's belief that DOM should be using state tax data to determine eligibility of applicants. However, DOM does not have statutory authority to access this information. DOM utilizes all available tools, in accordance with the CMS approved state plan, to evaluate the eligibility of applicants; thus, this finding is Fully Corrected as DOM is complying with all CMS regulations and the approved state plan. Further, DOM performed training and made operational changes for all other issues noted in finding 2021-041. There are internal controls in place to limit the number of errors and annual training is conducted that includes examples of issues noted, along with preventive and corrective solutions. Human error is a part of any manual process and cannot be completely eliminated. DOM Corrective Action Plan: a. DOM made adjustments to the costs identified in this audit finding in the June 30, 2023 federal reports. In addition, a reconciliation has been added to the spreadsheets used for reporting of federal expenditures to ensure all expenditures are reported properly going forward. b. Christine Woodberry c. Completed July 24, 2023

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2022-025 Strengthen Controls to Ensure Compliance with Eligibility Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: DOM acknowledges OSA's concern regarding the initial review of case files and the prompt action to select and provide a new sample of cases. Historically, DOM has provided a hardcopy of the actual beneficiary case files to OSA. Since those cases were active, an inventory control process, which included a notation in the electronic beneficiary file of the request to send the physical folder to the central office, was implemented. Likewise, upon arrival in the central office, notation of receipt of the files are added to the system prior to providing said files to the auditor. Occasionally, there are multiple files depending on the office with whom a beneficiary communicates, and multiple individual files associated with a family case. Additionally, cases in the sample may also be undergoing redetermination. To ensure that OSA has all the documentation needed for their case review, DOM staff reviews the files prior to sending them to central office. If an adverse eligibility determination is discovered, DOM has an obligation to correct at the time of discovery. As such, changes to the files are noted in the case history, which is available to the auditors. DOM will be transitioning to a paperless environment, which should alleviate any concerns during future audits. Use of Tax Return Resources DOM Does Not Concur. OSA compared eligibility data to state income tax returns. DOM is prohibited from accessing state income tax records per Mississippi Code Annotated ?27-3-73 and currently, does not have access to federal income tax records. DOM maintains that for determining eligibility, it has complied with the CMS-approved state plan. Using the approved CMS MAGI Based Verification plan in effect during the audit time period, the state sought to verify the reported income to the standard of reasonable compatibility, as defined by CMS, through all available electronic data sources. Further, DOM is required to accept the information provided by the applicant and utilize the available verification methods as detailed in the CMS-approved state plan to evaluate the accuracy of the information provided. If an applicant does not report self-employment income, and the tools available to DOM do not reveal such, DOM has performed its due diligence in the eligibility process and complied with the requirements of CMS, DOM's federal regulatory and oversight agency. OSA questioning DOM's determinations based on information that DOM was not provided nor have access to is shortsighted and does not align with the federal regulations that are imposed on this agency. While DOM is only required to use tax return information in certain circumstances, the agency continues to pursue the authority to review state and/or federal tax return information. To date, DOM has not been provided statutory authority to access Mississippi Department of Revenue tax information and is still awaiting IRS approval of the Safeguard Security Risks document. DOM plans to continue to follow the approved federal/state plan for eligibility determinations and will utilize additional resources as they become available. One MAGI beneficiary - DOM did not use taxable unearned income reported on tax return DOM Concurs. The application on file states neither parent has earned income. Although, the unearned income was not included in the initial calculation, adding it did not result in the beneficiary being ineligible. One MAGI beneficiary - self-employment income was reported to MDOM, but MDOM did not request a tax return from the beneficiary. DOM Concurs. The tax return was not requested for this particular beneficiary. This was an oversight, and the issue has been corrected. Two of the 180 MAGI beneficiaries - income was not verified through Mississippi Department of Employment Security DOM Concurs. There were multiple transactions associated with each of the beneficiaries identified. As a result, DOM's eligibility vendor is investigating to determine the reason the MDES search was not performed. One of the 180 MAGI beneficiaries - the beneficiary's case file did not contain an application or verification of income. DOM Concurs. This file could not be located. One of the 300 beneficiaries - auditors were unable to verify that any eligibility redeterminations have been performed since 2018. DOM Does not Concurs. A redetermination was not completed prior to the PHE. During the PHE, DOM was not allowed to performed redeterminations, which would have allowed DOM to update this file. Nine instances - resources were not verified through AVS at the time of redetermination. DOM Does not Concur. This is a prior finding from OSA 2021-041. Please note that all redeterminations in question occurred prior to the OSA audit period (FY22) and were suspended due to the public health emergency from March 2020 to June 2023. The eligibility system was updated in June 2022, after finding 2021-041, to include automatic asset checks within the system processing workflow to eliminate the manual request process and facilitate asset verification through AVS. Again, each instance identified above occurred prior to this implementation. In addition, AVS was checked on the 9 instances OSA sited, which resulted in no change in the eligibility determination. One instance - the beneficiary's case file did not contain a current level of care decision. DOM Does not Concur. DOM disagrees with this finding as redeterminations for the category of eligibility in question were suspended due to the public health emergency from March 2020 to June 2023. The date in question is from July 2021, which falls within this timeframe, and the child would have been eligible regardless. Seventy-three beneficiaries were not included on all of the required quarterly Public Assistance Reporting Information System (PARIS) file transmissions for fiscal year 2022. Of the 73 beneficiaries, six beneficiaries were not included on any quarterly PARIS file transmissions during fiscal year 2022. DOM Does not Concur. Per an amendment to DOM's CMS-approved State Plan, DOM is only required to verify Title XIX applicants and individuals eligible for covered Title XIX services. The above members were covered in Family Planning, which is not considered Title XIX, and did not receive Title XIX services. Therefore, these members should not have been included on any of the PARIS file transmissions. DOM Corrective Action Plan: a. All issues identified will be reviewed with regional office staff. Further, examples of these issues will be included in annual training sessions performed by Eligibility. DOM will continue to work with the vendor to ensure that income is verified through MOES, as applicable, and to implement controls that will limit this issue in the future. Further, DOM is implementing an electronic storage system to house all documents associated with applicants/beneficiary files. b. Cindy Bradshaw c. December 31, 2024

ALN Number 17.225 ? Unemployment Insurance 2022-021 ? Strengthen Controls to Ensure Compliance with Matching Requirements for Unemployment Insurance. Cat ? C, Finding Type, A, C1 (MW, MNC) MDES Response: MDES has begun evaluating both the requirements for and the analysis of the recommended system programming changes to implement the suggested controls. MDES has a goal date of October 31, 2023 to complete the recommended corrective action.

ALN Number 17.225 ? Unemployment Insurance 2022-020 ? Strengthen Controls to Ensure Compliance with Special Tests ? Program Integrity ? Overpayments Requirements for Unemployment Insurance. Cat ? N, Finding Type, A, C1 (MW, MNC) MDES Response: MDES respectfully disagrees with this finding because the flexibility to present its interpretations of federal guidance as impacted by state law to DOL for approval remains a cornerstone of the federal-state dynamic of the unemployment insurance system. In addition, the federal pandemic programs that Congress required MDES to institute involved broad, complex, and overlapping processes. MDES worked tirelessly to ensure that we followed all federal guidelines to the best of our ability while promptly enacting the pandemic program. In addition, DOL issued many updates to the federal guidelines including program changes via UIPLs. These UIPLs also referenced prior UIPLs and guidelines creating a high level of complexity when the pandemic demanded swift decisions and rapid implementation of program changes to provide vital assistance to Mississippi?s citizens suddenly thrust into unemployment. MDES will continue to work with DOL regarding its interpretations of federal program guidance as affected by state law. MDES maintains an on-going review of these programs to determine proper and timely payments and offsets under each program and will make necessary programmatic changes to ensure we properly issue payments and make offsets in compliance with federal and state guidelines. On June 19, 2023, MDES implemented an updated process to adjust the offset percentages for these programs.

10.558 Child and Adult Care Food Program Allowable Cost 2022-027 Strengthen Controls to Ensure Compliance with Allowable Costs Requirements of the Child and Adult Care Food Program (CACFP). Response: The MDE does not concur with this finding. The OSA did not identify weaknesses in the MDE subrecipient monitoring process, such as in the selection of organizations, the monitoring cycle, or monitoring procedures. Instead, OSA identified potential errors made by individual participating organizations. The MDE has a robust system of internal controls and subrecipient monitoring system for the CACFP. In addition to meeting USDA requirements for monitoring, the MDE Office of Child Nutrition (OCN) also employs a risk -based process to select CACFP subrecipients for review and to determine the scope of monitoring. The MDE routinely exceeds the USDA requirement to monitor 33.3% of participating organizations annually. For Program Year (PY) 2021-2022, 60.3% of participating organizations were reviewed to provide additional oversight of subrecipients. When the MDE identifies instances of noncompliance, it requires participating organizations to take appropriate corrective action. For organizations that are very high-risk, the MDE employs the USDA Serious Deficiency process in accordance with 7 C.F.R. 226.6. The MDE already has a process to recover funds from an organization if an error is discovered during subrecipient monitoring. In PY 2022, the MDE assessed $132,207 in repayments of USDA funds and required an additional $40,577 in unallowable costs to be returned to local CACFP accounts. Finally, MDE staff was not included in the reviews of subrecipients by OSA, so the MDE was unable to verify the accuracy of the proposed unallowable costs before publication of the report from OSA. MDE staff will need to review documentation from OSA, and source documentation retained at CACFP sites before it can make a final determination regarding the potential unallowable cost determinations against sponsors. Corrective Action Plan: A. The MDE will review documentation provided by OSA of potential questioned costs and review source documentation held by the subrecipients to determine the amount of unallowable costs. If confirmed, the MDE will recover any unallowable costs in accordance with USDA policies. This review will be completed by January 22, 2024. Susie Evans, CACFP Director for the MDE OCN, will oversee the review. B. The MDE will continue to assess its CACFP monitoring and continue to strengthen the process while remaining in compliance with USDA regulations.

FEDERAL AWARD FINDINGS 2022-002 - ALLOWABILITY Recommendation: We recommend that the Council implement controls to ensure that expenditures are properly reviewed and approved before being charged to a federal award and that adequate supporting documentation is maintained. Action Taken: In February 2023, the current Fiscal Officer received formal training from the National Endowment for the Humanities' grants management staff on allowable costs and proper documentation procedures for federal grants and grant-making entities, under 2 CFR 200. The Fiscal Officer and all staff involved with federal grants subsequently reviewed the Council's internal procedures, to ensure that all expenditure paperwork is received, approved, and filed with the grant documentation.

FINDING 2022-004: Untimely Paid Credit Balance A. Comments on Findings and Recommendations: In response to the untimely paid credit balance, Brillare Beauty Institute agrees with the Single Audit Finding 2022-003. B. Actions Taken or Planned: Brillare Beauty Institute had resolved the student account credit balance issue but not in the required time. Brillare Beauty Institute hired an additional Financial Aid Officer in February 2022 to help with administering the Title IV program. The new position gave the institute the ability to have an additional set of eyes reviewing many of our processes to ensure compliance. At the time of this error, training of the new employee was still in process.

Corrective Action Plan For the year ended December 31, 2022 U.S. Department of Housing and Urban Development: The Lehigh County Housing Authority respectfully submits the following corrective action plan for the year ended December 31, 2022. Auditor: Novogradac & Company, LLP Certified Public Accountants 1144 Hooper Avenue, Suite 203 Toms River, New Jersey 08753 The findings from the December 31, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Financial Statement Findings There were no findings relating to the financial statements which are required to be reported in accordance with Government Auditing Standards. Federal Award Findings and Questioned Costs Finding 2022-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? N. Special Tests and Provisions ? Housing Quality Standards Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: Based upon inspection of the Authority?s files and on discussion with management, there were units that were not reinspected within the biennial reinspection period of two (2) years. Finding 2022-001: (continued) Context: There are approximately 1,043 Section 8 Housing Choice Vouchers units. Of a sample size of twenty-three (23) tenant files, five (5) biennial inspections were not completed in a timely manner. Our sample size is statistically valid. Known Questioned Costs: $42,870 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly performed HQS inspections in compliance with program requirements following the expiration of HUD waivers as a result of a software error. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor, and will make the several changes to its inspection process to ensure enforcement of Housing Quality Standards (or any subsequent replacement). Views of responsible officials and planned corrective action: Helen Khouli, HCV Program Coordinator, is responsible for implementing this corrective action by December 31, 2023.

A. Comments on Findings and Recommendations: 2022-001 - Missing Proof of Loan Entrance Counseling. It seems that the student may not have completed entrance counseling. When this student started, MCU was contracted with Weber as its Third- Party Servicer who used to check entrance counseling before processing our students. Since 2020, MCU has been contracted with Campus Ivy whose platform now requires the Financial Aid Department to upload the entrance counseling proof before processing can occur. B. Actions Taken or Planned: 2022-001 - Missing Proof of Loan Entrance Counseling. The student in question has now performed the required Entrance Counseling. Since May 2020, MCU's updated entrance counseling process with Campus Ivy has helped mitigate a risk of gaps with regard to the completion of entrance counseling. MCU will perform an internal review on current students enrolled before May 2020 to ensure entrance counselings are complete.

Finding 2022-008 ? Cash Management ? Untimely Disbursements During the audit, it was noted that Student Aid Portion grant funds were not disbursed within 15 calendar days of the drawdown from G5. The Institution agrees with the finding. The Institute agrees with this finding, the funds were disbursed later than 15 days after drawdown of the funds. The school was aware that the funds were not disbursed in a timely manner due to timing issues within the department that was responsible to release the funds. In the future, the school will better prepare the checks and letters, so that the drawdown will be completed once the school is ready to release the funds.

Finding 2022-003 ? Late Refunds: During the audit, we noted two students who did not have refunds returned to the Department in a timely manner. The Institution agrees with the finding. The Institute acknowledges that the lag time between registration and financial aid did contribute to this issue. Similar to the resolution above, the director will continue to monitor these issues and work between the financial aid and business offices to ensure that refunds are made in a timely manner.

Finding 2022-002 ? Incorrect Refund Calculation: During the audit, one student had an incorrect refund calculation resulting in $1,592 that should be returned to the Department of Education. The Institution agrees with the finding. The erroneous action happened due to administrative oversight, the refunds to the Department have been completed in the amount of $211.00 Pell grant and $1,381 in Subsidized Direct loan funds. The school understands the importance of calculating the Title IV refund correctly, as a new financial aid administrator and director move into these roles, more oversight from the director position will be initiated.

TWIN PORTS ACCESSIBILITY PROJECT, INC. HUD PROJECT NO. 092-11251 CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Twin Ports Accessibility Project, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit Period: June 30, 2022 The finding from the June 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2022-001: SECTION 223(f), ASSISTANCE LISTING NUMBER 14.155 Condition: The Project overpaid management fees to the management company. Recommendation: The management company should repay the $271 to the Project. Action Taken: The Project agrees with the finding. The management company will repay the overpaid management fees as soon as possible. If the Department of Housing and Urban Development has questions regarding this plan, please call Chuck Reuter at 651-645-7271.

We agree with the finding and plan to implement a procedure whereby the

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. Management will submit the forms for HUD?s approval. Completion Date: August 18, 2022

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The funds will be reimbursed in the amounts of $2,089 and $4,034. Completion Date: September 9, 2022

CORRECTIVE ACTION PLAN Finding No. 2022-01: Surplus Cash existing at December 31, 2021 was not deposited into a separate residual receipts account. Recommendation: Management should deposit the amount or request HUD's approval for a waiver. Action Taken or Planned: Due to pending cash requirements, we requested HUD's approval to waive the deposit requirement, however an answer was not obtained. We will again seek w waiver for the current year and, if not approved, we will follow the HUD Account Executive?s instructions on how to resolve the matter. Responsible Person: James Watt, Senior Vice President, Management Company Completion Date: July 31, 2023

2022-02: Significant Deficiency ? Program income compliance and controls Federal Agency: Department of Health and Human Services Program: Certified Community Behavioral Health Clinic Demonstration Grant Assistance Listing Number: 93.829 Management agrees that during the year ended December 31, 2022, Flushing did not have a formal control in place to identify, monitor and report program income collected from providing mental health counseling services to patients under the grant. Management has contacted The Department of Health and Human Services to inform them of this finding. Medisys Health Network, which includes Jamaica Hospital and Flushing, is the recipient of various federal grants, including another grant with program income requirements which was identified as a result of management?s review of the awards and for which controls have been designed and implemented to ensure compliance with the requirement. We believe our oversight of this compliance requirement was an isolated situation because the NoA only included one brief sentence regarding program income. Flushing will implement the following process to formalize controls related to the program income compliance requirement for the grant. 1) Management will review monthly charge/income reports for each clinician hired under the grant to keep track of the program income related to the grant. Management has started reviewing the program revenue and will set up quarterly reviews with the program director. 2) Management will keep track of all program income related to the grant and compare the income to the current expenses, and retain documentation supporting how the program income was used to further eligible project objectives prior to requesting reimbursement from the agency under the grant. 3) These controls and procedures will be implemented by the end of the 3rd quarter of 2023. Management responsible for corrective action plan: Gina Aharonoff, Program Director (gaharono@jhmc.org) Manzar Sassani, Vice President of Finance (msassani@jhmc.org)

2022-006 Epidemiology and Laboratory Capacity for Infectious Diseases and Support of Immunization Initiative-Focusing on Childhood Vaccination Programs ? Assistance Listing No. 93.323 and 93.268 ? Allowable Costs Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The public health department is in the process of training new employees that are responsible for payroll and grant allocations. The Finance Manager has begun conversations with the new employee and the public health administrator on documentation and review. It was discussed that no benefit time such as vacation or sick be charged to a grant. If there are allowances within a grant for benefit time to be charged, there must be proper documentation and detailed approval by the public health board. This will be implemented immediately. Name of the contact persons responsible for corrective action: Jill Johnson, Finance Manager, and Department Heads and Elected Officials Planned completion date for corrective action plan: Immediate implementation

2022-005 Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 ? Reporting Recommendation: We recommend the County strengthen its review procedures over reports and ensure the review is documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The American Rescue Plan Act annual report is completed by the Finance Manager. The annual report will then be taken to the finance committee for review and approval for submission. The fiscal year 2023 annual report will be requested for return in order to correct and will be implemented immediately. Name of the contact persons responsible for corrective action: Jill Johnson, Finance Manager, and Department Heads and Elected Officials Planned completion date for corrective action plan: March 31, 2024

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INCIDENCE OF NONCOMPLIANCE ? U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER ? ALN 10.553, 10.555, AND 10.559 2022-001 Internal Control Over Compliance and Noncompliance With Federal Procurement Requirements Finding Summary 2 CFR ? 200.320 requires management to establish and maintain effective internal control over compliance with requirements applicable to federal program procurement requirements. Independent School District No. 885 (the District) did not have sufficient controls in place within its child nutrition cluster federal program to ensure compliance with federal procurement requirements related to the use of sealed bids and quotations. Corrective Action Plan Actions Planned ? The District will review policies and procedures relating to procurement for all federal programs to ensure that bids and/or quotations are obtained when required by the Uniform Guidance in the future. Official Responsible ? Kris Crocker, Director of Business Services. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The District agrees with this finding. Plan to Monitor ? Kris Crocker, Director of Business Services, will assure appropriate internal controls and procedures are updated and in place to ensure compliance for future federal awards expenditures.

Statement of Condition 2022-001 (Assistance Listing No. 14.155): The Corporation did not make the required surplus cash deposit computed at March 31, 2021, in the amount of $12,264 within 90 days of fiscal year end. Recommendation: Management should implement a system to ensure the required deposit to the residual receipts is made within 90 days of fiscal year end. Action(s) taken or planned on the finding: Agreed. Management concurs with the finding and the auditor's recommendation. The Corporation made the required surplus cash deposit on August 3, 2022.

U.S. Department of Education 2022-003: Student Financial Aid Cluster ? Student Eligibility and Awarding ? Assistance Listing Number: Various Recommendation: We recommend that the College implements a process that will ensure all Title IV funds are awarded at proper amounts. Action taken in response to finding: This student was awarded an incorrect amount because a subsequent ISIR transaction was received but the Pell was not recalculated on the basis of the new information. After this discovery, we have taken the following actions in response: ? We examined our ISIR import process to make sure that our means of communicating locked transactions was functioning correctly. We found that our system for monitoring new transactions was deficient; if a set of conditions were aligned, a new transaction could slip by our notice. Implemented by August 2022. ? We added another layer of review wherein the output of both the messages we receive from our third-party verification partner and our internal reports associated with importing ISIRS are examined on a regular basis. New transactions on students with a current locked transaction are reported to staff members for further review. Implemented by August 2022. ? We wrote an ad hoc report that allows us to identify subsequent ISIR transactions and will run it regularly to reduce the likelihood of this issue occurring again. Implemented by August 2022. Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: The corrective action plan was implemented by August of 2022.