Corrective Action Plans

The teaching and learning department provided training to involved parties beginning with the 2023-24 school year. Trainings will continue to occur as adequate processes have been developed.

Management View and Corrective Action Plan Finding Number: 2024-001 Grantor: Department of Education Program Name: Federal Pell Grant Program Award Year: 7/1/2023 - 6/30/2024 Award Number: P063P230300 Assistance Listing Numbers: 84.063 Management concurs that it made an overpayment in the amount of $1,335 in the Federal Pell Grant Program. The following controls will be added to ensure that overpayment does not occur in the future. 1. Training will be provided to individuals involved in the process to ensure that changes made to financial aid packages are appropriate and in accordance with requirements. 2. The R2T4 checklist used for all students with federal aid who withdraw mid-semester will be updated with a reminder to check the Pell Offered/Accepted/Paid amount prior to locking the funds to ensure the amounts are the same. 3. The Office of Financial Aid (OFA) will explore the possibility of developing a report that will check all Pell recipients, within a given year, for discrepancies between Offered/Accepted/Paid Pell amounts in Banner on a monthly basis. If a discrepancy exists, OFA staff will review and adjust as necessary in a far more timely manner. Management expects to implement these controls during the Spring 2025 term. Kelli Perry Associate Vice President for Finance and Controller

The District has made changes in the way that food purchases are recorded in the General Ledger, in accordance with standard procedures and the California School Accounting Manual (CSAM). Moving forward, the District will follow all regulations in order to remain in compliance with how expenditures are recorded, so that indirect costs can be ppropriately calculated in the Cafeteria Fund.

All funds have been refunded to state agency and expense reports amended appropriately.

NSLDS Reporting Errors Planned Corrective Action: Management agrees with this finding. The Registrar's Office has already resolved the system issues that were created by a new process for SP24 that created errors and resulted in students left off enrollment reports. The Registrar has successfully implemented a process to ensure consistency in reporting that can be shown through our submitted reports post Fall of 23'. Prior to each submission, the Registrar now performs a spot check by pulling a SIS enrollment report which helps to cross-reference and confirm the data. Additionally, the Registrar will select 10 random records from the enrollment file for detailed verification of accuracy, and correct any necessary records prior to submitting to NSC. The Registrar has identified some discrepancies between what is reported to NSC and what is pulled by NSLDS and are in the process of collaborating with CIU's IT team to investigate and resolve these issues promptly. Person Responsible for Corrective Action Plan: Elizabeth Haselden, Registrar; Joy Brown, Degree Audit and Data Specialist Anticipated Date of Completion: May 31, 2025

Planned Corrective Action: This issue has already been resolved. This goes back to budget year 2019-2020, when Provider Relief Funds issued to the county were not properly reported. The current administration was notified of this issue in November 2023, and immediately responded to the information, but was still required to pay penalty and interest, which was done in January 2024.

Condition: Total federal expenditures for the year ended June 30, 2024 amounted to $1,095,663. Prior to the performance of financial statement audit procedures, the Organization had determined that federal expenditures during the year ended June 30, 2024 did not exceed the threshold of $750,000. Recommendation: We recommend that all funding contracts are carefully reviewed to determine whether the amounts awarded represent federal funding and whether they should be classified as contractor payments or as subrecipient payments. If there is any uncertainty, we recommend that the Organization contact the funding source for clarification. We recommend that a schedule of expenditures of federal awards is prepared on an annual basis to determine if total expenditures exceed the threshold which would require a Single Audit. Name of Contact Person: Kristen Genovese, CEO Phone Number: 602-652-0163 Anticipated Completion Date: June 30, 2025 Views of Responsible Officials and Corrective Actions: notMYkid, Inc. will establish procedures to review all contracts and, if necessary, to communicate with funding sources to ensure that receipts of federal funding are properly classified as subrecipient versus contractor arrangements to ensure completeness of the Schedule of Expenditures of Federal Awards. notMYkid, Inc. will also prepare the Schedule of Expenditures of Federal Awards on an annual basis to determine whether the threshold for a Single Audit is exceeded.

Due to staff turnover and key vacant positions, we were unable to locate some supporting documentation. However, procedures have been developed and implemented to ensure all reports and supporting documentation will be kept on file for a minimum of three years in a location accessible by all employees.

The District has submitted the Capital Expenditure Pre-Approval Application and is waiting for a response from the California Department of Education. Although the form was not submitted timely for approval, all other requirements were met.

Finding ldentification: 2024-001 Federal - ESSA: Title l, Part A, Basic Grants Low lncome and Neglected #50000 Name of contact person: Tara Campanella, Chief Business Officer Corrective Action: The District will make sure the school site council at Wasuma is comprised of the correct ratio of community members and school staff for the current 24-25 school year and going fonruard. Proposed Completion Dale: 7 I 1 12024

Corrective Action Plan In the event that our health system experiences such an extraordinary occurrence in the future, any related expenses will be excluded from claims associated with this type of event. FMOLHS incurred more qualifying expenses than the amount of funding received and included in the claim. Therefore, there is no concern regarding any overstatement in the total claim amount. Anticipated Completion Date June 30, 2024 Name of Contact Person for Corrective Action Amanda Hymel, Corporate Controller

Views of Responsible Officials and Planned Corrective Actions: The deposits will be made as cash flows permits. The collection of tenant receivables and subsidy payments will improve as new property management team stabilizes operations by reducing turnover and increasing use of new property management system once fully implemented.

Views of Responsible Officials and Planned Corrective Actions: The planned corrective action did not take place as cash flow issues persist. The deposits will be made as cash flows permits. Inglis is in process of billing prior year amounts that are now in compliance and current year amounts.

Finding Reference Number: 2024-004 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; U.S. Department of Education, Teacher Education Assistance for College and Higher Education Grants, ALN #84.379) (Repeat Finding: 2023-005) In accordance with 34 CFR 668.165(a)(2), when a University credits a student’s account, the University must notify the student or parent of (i) the anticipated date and amount of the disbursement, (ii) the student’s or parent’s rights to cancel all or a portion of that loan or disbursement, and (iii) the procedures and time by which the student or parent must notify the University that he or she wishes to cancel the loan or disbursement. This communication must occur no earlier than 30 days before, and no later than seven days after, crediting the student’s ledger account at the institution if the institution does not obtain affirmative confirmation from the student. During the 2024 audit, it was noted that 13 of 38 students, or 34.2%, who had received Direct Loan funds and/or TEACH grant funds did not receive disbursement notifications due to a system failure. The failure was not noticed to be able to remedy the situation timely. The University should ensure system functionality periodically, specifically entering periods in which disbursements are concentrated, such as the beginning of the semester, to prevent lapses in mass. The University should also create a process to verify that disbursement notifications have been distributed as intended, so that any missed notices can be remedied timely. Entity’s Corrective Action Plan Corrective Action Plan Summary: The University has taken a comprehensive and proactive approach to address this issue through two key initiatives. First, we have instituted a robust audit process designed to ensure the integrity and functionality of the system responsible for documenting sent emails. This process enables us to systematically verify that the system is operating as intended. Second, we have deployed advanced software solutions that serve to mitigate the risk of similar issues arising in the future. These combined measures reflect our commitment to ensuring operational reliability and preventing recurrence. Anticipated Completion Date: October 1, 2024 The corrective action plan has been implemented to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Rocky Christensen, Director of Financial Aid

Finding Reference Number: 2024-003 Initial Fiscal Year: 2024 Summary of Finding: 2024-003 Significant Deficiency: Direct Loan Limits (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) In accordance with the Federal Student Aid Handbook, Volume 3, Chapter 3, you must determine an undergraduate student’s Pell Grant eligibility before originating a Direct Subsidized or Unsubsidized Loan for that student, and you must package Campus-Based funds and Direct Subsidized Loans before Direct Unsubsidized Loans. In addition, you must determine an undergraduate student’s maximum Direct Subsidized Loan eligibility before originating a Direct Unsubsidized Loan for the student. The student’s maximum annual loan limit increases as the student progresses to higher grade levels. During the audit, it was noted that the University did not fulfill maximum award of students’ Direct Subsidized Loan eligibility prior to awarding Unsubsidized Direct Loans for 3 of the 32 applicable students tested, which is a 9.4% error rate. This finding is monetary in nature. In the instances noted in testing, the total error is $5,983 in under-award. Extrapolation of this monetary error estimates a total potential error of $54,614. The University should institute processes and controls to ensure that the student eligibility is assessed properly based upon grade level progression and that maximum Subsidized Direct Loans are awarded prior to Unsubsidized Direct Loans, as this practice is more beneficial for the student. Entity’s Corrective Action Plan: Corrective Action Plan Summary: The University has determined that this finding was caused by a deficiency in the software’s calculation of the subsidized award. Specifically, the software failed to update the student’s records following changes in circumstances that impacted the calculation of financial need. In response, the University has conducted a thorough evaluation and implemented new software designed to address this issue and ensure accurate calculations in future cases. Anticipated Completion Date: November 1, 2024 The corrective action plan has been implemented to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Rocky Christensen, Director of Financial Aid.

Finding Reference Number: 2024-001 Initial Fiscal Year: 2023 Summary of Finding: Significant Deficiency: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) (Repeat Finding: 2023-001) In accordance with 16 CFR 314.4, a University shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue and must contain all of the elements that are further described in 16 CFR 314.4 During the audit, it was noted that the University’s Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. An updated policy was put into place in July 2024, which addressed several of the deficiencies noted in the existing policy, but not all. The University should continue to update their Gramm-Leach-Bliley Act Policy to be in accordance with the requirements and put in place effective controls and practices to ensure the policy is monitored in a way to ensure it is administered effectively and timely. Entity’s Corrective Action Plan: The Johnson University IT Department has consistently worked to improve compliance with GLBA regulations since July 2023. The leadership of Johnson University has taken a proactive and measured approach to GLBA compliance that ensures a balance between reaching compliance quickly and reaching compliance with long-term strategic planning. This has led to a GLBA implementation that will take 2 or more years but will set up the university for long-term excellence in compliance and security. The University understands the importance of GLBA requirements and is committed to ensuring student data is protected from all foreseeable threats. It will continue to iterate on its GLBA corrective action plan to ensure proper compliance for long-term security. The Johnson University IT Department has developed a plan to address deficiencies in GLBA compliance in each of the following areas: Requirement 1 - Qualified Individual: 16 CFR 314.4(a) Johnson University has designated Tim Fisher as our Qualified Individual. Tim Fisher is an employee of Johnson University, serving in the IT Systems Analyst role, and will work alongside Johnson University’s IT Director to oversee the information security program and its implementation. While Tim has over 15 years of on-the-job cybersecurity experience, additional training resources have already been provided to Tim Fisher to pursue the CompTIA Security+ certification. Tim Fisher expects to complete the training and gain the certification by the end of 2025. This was deemed sufficient for GLBA compliance in the audit report provided by Blackburn, Childers & Steagall, PLC dated November 6, 2024. Note from 2024 audit report: “Both the existing policy and the newly implemented sufficiently address this attribute.” Requirement 2 - Risk Assessment: 16 CFR 314.4(b) Johnson University partnered with HORNE, a cybersecurity company, to conduct a risk assessment in November 2023. The assessment covered several topics and recorded inherent risk levels, existing mitigating controls, and the residual risk levels of each topic covered. Residual risk levels, the level of risk existing despite the existing controls, were found to be considered high in termination procedures and review of security logs. GLBA policy development and implementation decisions were based heavily on this initial risk assessment. A more comprehensive cybersecurity company with experience serving customers in Higher Education, DeapSeas, has been selected for ongoing cybersecurity assistance and will be conducting future risk assessments. Additional risk assessments are planned to be performed every 2 years to reexamine reasonably foreseeable risks and to account for changes in cybersecurity controls. The next risk assessment shall be completed by the end of 2025. Note from 2024 audit report: “This attribute was addressed in the existing policy but was not considered to be sufficient; the newly implemented policy does sufficiently address this requirement. Requirement 3.1 - Access Controls: 16 CFR 314.4(c)(1) Johnson University policy ensures that employee supervisors dictate appropriate access for each employee to the IT Department when they are hired or change positions. Supervisors are responsible for ensuring employees have appropriate access to locations where sensitive information is stored, such as file servers and Jenzabar (Student Information System) software access. The IT Department processes permission changes and does not provide permissions without explicit request from the employee supervisor. Auditing existing permissions is a weak spot that has, in the past, taken hours of manual work. We have purchased software, AD Manager, to assist with access reviews. We expect this software to be ready to audit necessary permission groups by the end of 2024. This should significantly reduce the time it takes to audit permissions through additional reporting and easy remediation features. Note from 2024 audit report: “This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement, instituting a continuous monitoring process undertaken at periodic intervals. The University has contracted with a new software to assist with this, which is expected to be live by December 31, 2024. Note from JU IT: Requirement 3.1, access control reviews, is complicated as each department supervisor is responsible for setting access permissions. The IT Department will need to engage department supervisors for review and approval. Due to the transition in the I.T. Director position, the expectation to be live should be adjusted to March 31, 2025. Requirement 3.2 – Data Identification: 16 CFR 314.4(c)(2) Informal identification has been completed by the IT Department through generalized asset inventory procedures. DeapSeas, our selected cybersecurity vendor, has been contracted to conduct a more formal data identification procedure in early 2025. This will identify critical items and analyze risks and responsibilities associated with each party. This procedure will take place through scanning the corporate network and interviewing departments on their data storage procedures. Note from 2024 audit report: “Both the existing policy and the newly implemented policy are silent on this requirement. Resolution to this matter is expected to be addressed and incorporated into the policy by December 31, 2024.” Note from JU IT: For requirement 3.2, data inventory, we’re already under contract with DeapSeas to do this. It will be completed by March 31, 2025. Requirement 3.3 – Encryption: 16 CFR 314.4(c)(3) Johnson University has had encryption in transit for several years but has not had encryption at rest. Johnson University purchased licenses to enable encryption at rest in October 2023 and finished a project to encrypt most virtual machines containing sensitive data using AES-256 and XTS-AES-256 encryption on April 29, 2024. The remaining virtual machines are planned to be encrypted before the end of 2024. Note from 2024 audit report: “This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement.” Requirement 3.4 – Secure Development: 16 CFR 314.4(c)(4) Johnson University does not develop in-house applications for transmitting, accessing, or storing customer information. A combination of the risk assessment, vendor analysis, and penetration testing will assess the security of externally developed applications. The risk assessment has already been completed, but further vendor analysis and penetration testing are planned to be completed by the end of June 2025. Note from 2024 audit report: “Both the existing policy and the newly implemented policy are silent on this requirement. However, the University does not develop in-house applications for transmitting, accessing, or storing customer information.” Requirement 3.5 – Multi-factor Authentication: 16 CFR 314.4(c)(5) Johnson University has enabled multi-factor authentication on all connections to the server where our student information system (Jenzabar One) is accessed. Multi-factor authentication is also enabled for all logins to Office 365 and integrated applications, such as Zoom videoconferencing, our student/employee portal, Jenzabar Financial Aid (financial aid management system), and Jenzabar Recruitment (admissions software). Multi-factor authentication is also enabled on connections to our administrative systems, such as our network firewall, hypervisor, door access control, and security camera management systems. With multi-factor authentication requirements for all these systems, we believe that multi-factor authentication is enabled on all critical systems to protect student information. Evaluation of low-risk systems, such as our classroom audiovisual systems, for feasibility of multi-factor authentication are ongoing and expect to be completed by the end of 2024. Note from 2024 audit report: “Both the existing policy and the newly implemented policy are silent on this requirement. However, the University utilizes multi-factor authentication on all connections to the server where student information system is accessed, as well as administrative and financial applications.” Requirement 3.6 – Data Retention: 16 CFR 314.4(c)(6) Organizational data retention policies, developed by the Finance Department, are currently in effect. These policies were originally written for other means but have some overlap with GLBA regulations. Evaluation of these policies for effectiveness is ongoing and expected to be completed by the end of 2024. Future evaluations for the effectiveness of data retention policies will take place every other year in a joint venture with the Finance and IT Departments. Note from 2024 audit report: “Both the existing policy and the newly implemented policy are silent on this requirement. Evaluation of organizational data retention policies for effectiveness is ongoing and expected to be completed by December 31, 2024. Note from JU IT: Requirement 3.6, data retention policies, will require collaboration between Finance and IT. Finance’s existing policies on data retention need to be enhanced. This just takes time and decisions from the CFO (how long to retain and when to delete – IT will be enforcing the policy technically). Evaluation will be completed by June 30, 2025. Requirement 3.7 – Change Management: 16 CFR 314.4(c)(7) Change management procedures have been discussed and official policies are being developed. Evaluation of security risk and risk of downtime or other degradation of service are being considered in change management procedures. Official policies should be in place in 2025. Note from 2024 audit report: “This attribute was not addressed in the existing policy; the newly implemented policy does address this requirement. Official policies should be in place by December 31, 2024. Note from JU IT: A change management plan will be completed by March 31, 2025. Requirement 3.8 – User Logging: 16 CFR 314.4(c)(8) User logging is in place for all log-ins to Office 365 log-ins to its services and integrated applications. Microsoft Entra sign-in risk and user-risk policies are in place to enforce stronger security measures during sign-in, force password resets, or deny sign-ins altogether based on risk analysis. Sign-ins to on-premises resources are logged through new software, Log360, implemented in March 2024. Log360 analyses log-ins and sends notifications to IT Department technicians via email for suspicious activity. IT will then process these reports to take appropriate action to resolve the threat unless there is sufficient evidence of a false positive. Note from 2024 audit report: “Both the existing policy and the newly implemented policy are silent on this requirement. Office 365 user logging has been in place; sign-ins to on-premises resources was implemented in March 2024. IT has processes in place for addressing suspicious activity.” Requirement 4 – Security Assessment: 16 CFR 314.4(d)(1) DeapSeas, a cybersecurity vendor, has been chosen to conduct security assessments. A security assessment is planned for early 2025. Ongoing, internal security assessments are planned on an annual basis to be conducted by the IT Department. These assessments will assist in evaluating the effectiveness of existing controls and the ongoing development of the security program. Software has also been purchased and implemented for continuous monitoring of vulnerabilities within organizational software. The software, Vulnerability Manager, provides notice of known vulnerabilities and available patches for software installed on devices within our organization. These notifications are distributed through the software and through email. Automated and semi-automated patches are available through the software to be deployed to organizational devices over the internet. Patching known vulnerabilities within our software portfolio is a priority for us. This system should reduce overall risk and patch effectiveness will be verified with penetration testing. Our first annual penetration test is planned for early 2025. Note from 2024 audit report: “This attribute was addressed in the existing policy but was not considered to be sufficient; the newly implemented policy does sufficiently address this requirement. Requirement 5 – Security Training: 16 CFR 314.4(e) Security training has been made mandatory for all employees beginning in Fall 2024. Security training is done through our online video training platform, KnowBe4. This system allows for video, quizzes, and other learning material to be presented to the employees. KnowBe4 develops this content and ensures accuracy and appropriateness. Johnson University IT Department selects available materials and assigns them to employees. Security training was last updated after the initial risk assessment and will be reviewed every 6 months. Note from 2024 audit report: “Both the existing policy and the newly implemented sufficiently address this attribute.” Requirement 6 – Service Providers: 16 CFR 314.4(f) Collection of SOC2 security reports from vendors that have access to systems with student information is in progress. The collection and analysis of these reports is expected to be completed by the end of 2024. Review of these reports is planned to be conducted annually, with requests for updated security reports every 3 years. \ Note from 2024 audit report: “This attribute was addressed in the existing policy but was not considered to be sufficient; the newly implemented policy does sufficiently address this requirement. Requirement 7 – Security Control Monitoring: 16 CFR 314.4(g) Security controls are being monitored using Log360 wherever possible. Continuous evaluation of these controls is underway and adjustments will be made to security controls as needed. New change management policies and penetration testing will influence the way we evaluate these controls and will likely include changes to monitoring systems and evaluation methods. Note from 2024 audit report: “Both the existing policy and the newly implemented sufficiently address this attribute.” Anticipated Completion Date: Fall 2026 Name and Title of Responsible Person: Luke Edwards, Director of IT.

Finding Reference Number: 2024-002 Initial Fiscal Year: 2024 Summary of Finding: 2024-002 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063) In accordance with 34 CFR 668.22(f), in the calculation of the percentage of payment period and/or period of enrollment completed, the total number of calendar days in a payment and/or enrollment period includes all days within the period, except that institutionally scheduled breaks of at least 5 consecutive calendar days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period and/or period of enrollment. During the audit, it was noted that the University used the incorrect number of completed days in the payment period or period of enrollment in calculating the percentage of the Title IV aid earned. The audit included a detailed testing of 5 withdrawal student files, of which this significant deficiency applies to 1, indicating an error rate of 20.0%. This finding is monetary in nature. In the instances noted in testing, the total error identified is $1,992 in over-award. Extrapolation of this monetary error was not necessary as the 5 withdrawal students tested as part of the 2024 audit constitute the entire withdrawal population for the period under audit. The University should ensure that the number of completed days in the payment period or period of enrollment are counted correctly utilizing the guidance provided by the Compliance Supplement and the Student Financial Aid Handbook. Entity’s Corrective Action Plan: Corrective Action Plan Summary: The University has determined that this matter constitutes a unique training situation involving the application of procedures related to the Return of Title IV funds. In particular, the University recognizes the need for enhanced training concerning the accurate counting of days when a student withdraws, provides written notification of their intent to attend a future module within the same term, and subsequently withdraws from that second module. The error in question arose from the miscalculation of days, where the University inadvertently counted all days in the initial module rather than counting only the days leading up to the student's initial withdrawal prior to the final withdrawal from the second module. This oversight was attributed to an individual employee, and the University has proactively implemented comprehensive training and procedural safeguards to prevent similar occurrences in the future. Anticipated Completion Date: August 01, 2024 The corrective action plan has been implemented to resolve the prior year finding, helping to ensure that future dates are accurate. Name and Title of Responsible Person: Rocky Christensen, Director of Financial Aid.

CORRECTIVE ACTION PLAN October 23, 2024 Kansas State Department of Education and Kansas State Department of Administration Unified School District Number 374 respectfully submits the following corrective action plan for the year ended June 30, 2024. Medill & Thooft, CPA Po Box 885 Ulysses, KS 67880 Audit Period: June 30, 2024 FINDINGS – FEDERAL AWARD PROGRAMS AUDIT U.S. Department of Education Passed Through Kansas State Department of Education Program Name: Education Stabilization Fund Cluster Federal Assistance Listing Numbers: 84.425U Finding 2024-001 Recommendations: The District should have an employee compare the Board Clerk’s supporting documentation and the Education Stabilization Fund spreadsheet report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Action Taken: We agree with the recommendation. Our targeted implementation date is November 2024. If the Kansas State Department of Education and/or Kansas State Department of Administration has questions regarding this plan, please call Rex Richardson at 620-675-2277. Sincerely yours, Rex Richardson Superintendent

S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs that they did not pay the debt in full at maturity. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2025 S3800-150 Response The Corporation is working with HUD and a local developer to resolve the outstanding loan balance. S3800-160 Contact Person First Name Amin S3800-180 Contact Person Last Name Akbar

S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs that they did not pay the debt in full at maturity. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2025 S3800-150 Response The Corporation is working with HUD and a local developer to resolve the outstanding loan balance. S3800-160 Contact Person First Name Amin S3800-180 Contact Person Last Name Akbar

S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations We concur that the Corporation failed to make the required annual deposits to the reserve for replacement. S3800-130 Response Indicator Agree S3800-140 Completion Date July 1, 2024 S3800-150 Response The Corporation has made the required deposit prior to issuance of the financial statements. S3800-160 Contact Person First Name Carlyle S3800-180 Contact Person Last Name Ackley

Name of Contact Person: Melanie Imholte Finance Director mimholte@soldotna.org 907-714-1224 Finding 2024-001 Reporting – Significant Deficiency in Internal Control Over Compliance Corrective Action The City of Soldotna will revise policies and procedures to ensure review and approval of grant reports being submitted. Expected Completion Date: Fiscal Year 2025

Finding 2024-001: The resident security deposit account did not have adequate funds to cover the security deposits collected at September 30, 2024. Comments on the Finding and Each Recommendation: Management should reconcile the security deposit listing on a monthly basis and transfer funds from the operating cash account to ensure the resident security deposit account is adequately funded. Action(s) taken or planned on the finding: Agree. On October 22, 2024, management transferred $524 from the operating cash account to fully fund the security deposit account.

Finding 2024-001 Condition: Supporting documentation was missing for 6 out of 98 disbursements selected for allowable costs testing during the audit. Without itemized receipts we were unable to determine if the purchases were allowable. However, the projection of the error was less than the $25,000 reportable limit of questioned costs. Cause: The Organization’s controls did not provide for supporting documentation to be adequately retained. Recommendation: We recommend that internal control procedures on recordkeeping and filing should be clearly stated as part of the Organization policy. Management Response: We concur with the finding. Corrective Action: 1. The Finance Committee will review and update the Organization's Policy to more clearly state expectations regarding control procedures on recordkeeping and filing. 2. Administrative staffer is being hired and will be responsible for streamlining supply ordering, setting up store accounts where possible to limit the need for in-store purchases, as well as the collection and filing of receipts. 3. Staff with credit cards will be retained regarding receipt retention procedures. Name of Responsible Person: Beth VanDerbeck

Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2024 Corrective action Sterling College agrees with the auditors finding regarding special reporting. We do not anticipate any issues with future reporting as we now understand the process for the reporting.