Corrective Action Plans

Finding 2024-004- Voucher Management System I agree with finding 2024-004 and corrective action has been taken by the Executive Director on March 6th, 2025. VMS has been corrected and since HUD has not reconciled the fiscal year 2024 it will be reconciled correctly. Spoke with the agency’s fee accountant and we will continue to work together to not repeat this finding. VMS data is reviewed after submitted, and Executive Director missed the reporting of additional 14 vouchers in the total. Fee accountant made an error and included the 14 enhanced vouchers twice.

Finding 2024-003- Financial Data Schedule. I agree with finding 2024-003 and corrective action has been taken by the Executive Director on March 6th, 2025 The Agency’s Financial Submission was due November 31, 2024 and was not submitted until January 16th, 2025. Information was given to our fee accountant by the timeline requested. Spoke with the agency’s fee accountant on March 6th, 2024 and he agreed that the late submission was due to the agency’s financials not being done in a timely fashion. The fee accountant will do a better job in getting the monthly financials completed faster. This will allow the submission to submitted on time. We will work together to not repeat the finding. It is also the Executive Directors responsibility to make sure financial data is submitted when required. An extension could have been requested.

2024-001 – Reporting Federal Agency: U.S. Department of Energy Federal Program: 81.042 Weatherization Assistance for Low-Income Persons Responsible Official Jennifer Beloff, Chief Program Officer Plan Detail Action is in the process of enhancing its internal controls over reporting to ensure that only federally related costs and activities are reported within its Federal programs and training its employees on its internal controls. Anticipated Completion Date March 2025

Subject: Corrective Action Plan for Federal Direct Student Loans Program Compliance The University of the Pacific acknowledges the findings outlined in the audit related to the reporting of student enrollment status to the National Student Loan Data System (NSLDS) for the Federal Direct Student Loans Program (Federal Assistance Listing Number: 84.268) for the award year July 1, 2023 - June 30, 2024. We take our responsibility to comply with the federal regulations under 34 CFR Section 685.309 very seriously and are committed to strengthening our internal controls to ensure accurate and timely reporting of enrollment changes. Corrective Action Plan: To address the identified deficiencies and enhance our reporting processes, the University has implemented the following measures: 1. Monthly Reconciliation with National Student Clearinghouse (NSC): The Registrar’s Office will conduct a monthly audit of the NSC transmittal files to verify that all reported enrollment data matches the records in NSC and NSLDS. Any discrepancies will be promptly addressed to prevent inadvertent omissions of student enrollment changes. 2. Enhanced Monitoring and Error Resolution: The Registrar’s Office will review and resolve all NSC-generated error reports within 10 business days of receipt. This process will ensure that discrepancies between campus-level and program-level reporting are corrected promptly to meet the 60-day reporting requirement. 3. Regular Compliance Checks: System-generated reports will be reviewed to align with NSLDS reporting guidelines. Additionally, a designated staff member in the Registrar’s Office on the three-campuses will oversee the timely processing and submission of enrollment status changes to NSLDS. 4. Training and Process Improvement: The Registrar’s Office will conduct periodic training sessions for staff involved in enrollment reporting to reinforce compliance requirements and best practices for NSLDS data submission. Internal reporting procedures will also be refined to prevent delays or errors in enrollment reporting. 5. Ongoing Review and Oversight: The University will establish a formalized review process to assess the effectiveness of these corrective actions. Progress reports will be reviewed quarterly to ensure sustained compliance and continuous improvement in our enrollment reporting processes. The University remains committed to ensuring accurate and timely reporting of student enrollment data in compliance with federal regulations. We appreciate your guidance and support in maintaining the integrity of our Title IV reporting obligations. Please do not hesitate to reach out if additional clarification or documentation is required. Sincerely, Karen Johnson University Registrar

Finding 2024-001 Information on the Federal Program: Federal Program: HIV - Related Training and Technical Assistance - Aids Education and Training Centers Assistance Listing: 93.145 Federal Agency: U.S. Department of Health and Human Services – Health Resources and Services Administration (HRSA) Grant Award Number:6 U1OHA30535-08-01 Award Periods: July 1, 2023 through June 30, 2024 Pass-Through Agency: Columbia University Grant Award Number: U1SHA46532 Award Periods: September 1, 2023 through August 31, 2024 Corrective Action Plan: Department of Health and Human Services – Health Resources and Services Administration (HRSA) updated the award template utilizing a new federal format. Modification of this federal award template has allowed HRSA to indicate/flag (item 18 in the Notice of Grant Award - R&D “no”) whether the federal program is R&D in a manner not previously recorded or visible. This indicator flag now indicates AETC is non-R&D, therefore, we have reflected it appropriately in the FY24 SEFA. We will strengthen our controls for monitoring the cluster to ensure appropriate classification paying attention to any indications in the Notice of Grant Award. Paula Yarbrough, VUMC Director – Grants and Contract will be responsible for the implementation by fiscal year-end 2025.

2024-004 Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.033 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Campus One The Winter 2024 Start of Term Enrollment report was delayed due to technical difficulties, which prevented timely reporting of Fall 2023 graduates as withdrawn before their subsequent graduation status could be recorded. Corrective action will be for coordination to occur between Information Technology Solutions (ITS) and the Registrar’s Office when a delay such as this is unavoidable to 1) ensure resolution is a top priority and 2) manual updates are completed if required. We will maintain enhanced communication between Information Technology Solutions (ITS) and the Registrar’s Office when data files are not sent by intended deadlines. Meetings will occur to determine cause, timing for resolution and potential impact to reporting timelines. It will be determined what escalations need to occur for resolution and if manual data entry is required, and if so for which populations. Increased communication practices and timeline discussions have been implemented as of March 15, 2025. We will evaluate the National Student Loan Data System (NSLDS) Enrollment Reporting requirements to determine if we are prescribed to a specific date logic or if the date is determined by campus procedure. Once we know what date is expected for reporting effective dates then we need to determine how the reporting needs to change. We will investigate the data flow from Banner, to NSC to NSLDS to determine at what point the effective dates between the Campus level information and the Program level information are being stored differently. Additionally, we will review NSLDS Enrolment Reporting to document expected data points/definitions in data output from Banner and reporting within National Student Clearinghouse (NSC) and NSLDS. Data will need to be evaluated at each stage to determine where the misalignment occurs. This will start with evaluating the output from the Ellucian delivered NSC enrollment and degree files. If the error is determined to be at this stage, the campus will engage with Ellucian to determine how to correct the error. If the error is not at this stage, the next stage is to evaluate NSC’s retrieval and storage of our data file in their database. If the error is determined to be at this stage, the campus will engage with NSC to determine how to correct the error. Although it is not believed that the error is with NSLDS, that will be the last evaluation to ensure the data is accurately represented throughout the full data sharing process. Both the evaluation of reporting requirements and the data flow analysis described above will be completed by June 30, 2025. For inquiries regarding this finding, please contact Bracken Dailey at bracken.dailey@ucr.edu. Campus Two The cause and remediation plan for the two exceptions noted are as follows: 1) It has been identified that a summer graduate was not reported as Withdrawn or Graduated status within 60 days due to the timing of the fall reporting to NSC and when they reported the student’s status to NSLDS. Currently, we don’t begin fall reporting until a few weeks after the start of fall term and it missed the date of when NSC reported the status to NSLDS until after the next submission. Thus, only the Graduated status was submitted to NSLDS. Additionally, the Graduated status for summer term is not available until late October since it takes 6 weeks to finalize degrees once grades are submitted. Summer is not a required term. The summer term begins in June and ends in September with many different end dates available for student instruction. To rectify the issue, we will start fall reporting earlier by scheduling the first submission on the first day of fall term for the upcoming academic year. Starting the fall reporting earlier will likely result in a higher number of errors for Registrar staff to manually correct as there will be more students who will not be enrolled for fall by that time. However, this will capture a Withdrawn status for the students who have completed summer coursework (ending in early August) within the 60 days of their last status. The submission schedule is an automated process. We changed the business rule in our production scheduling on March 10, 2025. Our enrollment reporting schedule for academic year 2025-2026 will be finalized in NSC’s online application by August 1, 2025, such that the new, additional First of Term enrollment file for Fall will execute on the first day of the quarter, Monday, September 22, 2025. 2) It has been identified that a Medicine student’s Leave of Absence (LOA) status was not reported within 60 days. We use two branches to report Medicine students in NSC: students in their first three years of the program are reported under branch 82 and students in their final/fourth year are reported under branch 81. Typically, the NSLDS Roster process sends NSLDS only the most currently certified record for each student on the Rosters at the time the Roster is received by NSC. However, if a student is reported in two or more branches at the same time and both active statuses, NSC’s system uses a hierarchy that sends NSLDS the higher status. This student was entering their final year and was actively enrolled in two different branches at the same time. In branch 82, the student was reported as Full-Time via an online update certified on 8/23/2023. Concurrently, the student was reported under branch 81 as LOA certified on 8/14/2023 and 9/5/2023. When NSC received the 9/1/2023 Roster, the latest certified record of Full-Time status was sent to NSLDS. By the time the 9/19/2023 Roster was received, the LOA status had a later certification date but since the student was still Full-Time status in branch 82 and the Full-Time status is a higher status than LOA, NSC’s system sent NSLDS the Full-Time status on the 9/19/2023 Roster. It wasn’t until 9/23/2023 that the student was reported as Withdrawn from branch 82. At that point, the higher status was LOA and was sent to NSLDS on 10/2/2024. To prevent this issue from occurring in the future, we will create a report that captures Medicine students whose status changes from spring to summer terms. The report will generate every time there’s a change in status between the last day of spring and the first day of summer. Registrar staff will manually update the information in NSC for those students in the previous branch before they move into the next branch. Then when the regular enrollment reporting occurs for Medicine summer term, NSLDS will receive and process the changed status. This report will be implemented by June 1, 2025. Spring semester 3rd year Medicine ends on June 13, 2025. Summer term for ending 3rd/advancing 4th year Medicine begins on June 16, 2025. Students whose spring status changes to a lesser status for summer will be identified and manually updated directly with NSC, such that students under branch 82 (years 1-3) would be reported timely to NSLDS. For inquiries regarding this finding, please contact Kate Jakway Kelly at kjakway@registrar.ucla.edu. "Campus Three For enrollment reporting, we will request a dedicated analyst at the National Student Clearinghouse to minimize enrollment reporting errors. We have two campuses we report on: Main Campus and Medical. The timing of the reports is crucial to NSC accepting the enrollment records. The Office of the Registrar is working with the NSC to request a dedicated analyst be assigned to us, as we have had historically. Effective February 2025, we implemented our plan to manually check the students on the error report to verify when status changes need to be applied to both the campus and program level. This will ensure that updates make it to the campus enrollment level, when applicable, and are not missed as was happening previously. We will continue our communications with the NSC to implement a long-term solution by having a dedicated analyst to reduce the potential of an error like this from happening again and ensure updates are processed accordingly. The Office of the Registrar will work with Financial Aid monthly to spot check student records to ensure that NSLDS is subsequently receiving the enrollment data. The Office of the Registrar will provide 5 PIDs from every degree file and have a 45-day check in place. If the Financial Aid team does not see a “G” in NSLDS 45 days from the date of determination, the Registrar will follow up with NSC. In response to the graduation date, the Registrar and Financial Aid Offices on main campus and Health Sciences are working with the School of Pharmacy to review current practices and address the program conferral date issue which led to the finding. Correcting our process and updating our schedule will ensure our reporting to the National Student Clearinghouse and NSLDS is in compliance with the 60-day reporting requirement. The offices will meet to develop a 5-year plan aligning the graduation conferral date with the last date of the term in the Student Information System. This update to the conferral date will ensure the status change will be included in the Registrar’s regular enrollment reporting schedule, i.e., 15th of each month. The NSC reporting team in the office of the Registrar will work closely with the School of Pharmacy to ensure graduation date is timely in the system and reported correctly with the clearinghouse. To ensure the adjustment to the reporting schedule meets the required timeline, the Registrar’s team will conduct a review of the NSC report to ensure a sample of the Pharmacy graduates are included each year. In turn, the Health Sciences financial aid team will conduct a review of NSLDS to ensure a sample of these students had their enrollment status updated accordingly. A potential challenge may be the aligning of the dates with the monthly reporting schedule should they fall on a non-business day. The offices held their first meeting on March 10, 2025, to discuss the enrollment reporting issue as well as the needs of the School of Pharmacy as it relates to licensure for students. A solution was presented to the School of Pharmacy for the Spring 2025 graduating class. A follow-up meeting is scheduled March 24, 2025, to develop a calendar, along with the responsibilities for the Registrar and the School of Pharmacy teams in order to ensure compliance and mitigate risk. This plan will be in place no later than July 1, 2025, so it is in place for full FY26. For inquiries regarding this finding, please contact Cindy Lyons at cglyons@ucsd.edu. Campus Four We will establish a more structured and timely reporting process for submitting enrollment status changes to NSLDS, with additional tracking and reminders to ensure compliance. We will review and revise procedures to ensure consistent and accurate alignment of status change dates at both the program and campus levels, with additional staff training. Through collaboration with our third-party servicer, we will address the data error issue, ensuring any discrepancies are promptly identified and resolved. We will implement a more proactive approach to follow up on discrepancies, ensuring that all identified errors are appropriately addressed, even if they are not required for immediate submission. Regular staff training on NSLDS reporting and error resolution will be conducted, along with periodic internal audits to ensure continued compliance and accuracy. Actions already taken to address this finding include consultation with the analyst at NSC regarding the findings, with the analyst looking for these specific findings in addition to the standard errors reported by their system. After the initial data load, they notify the Office of the Registrar staff of any data errors related to these findings and a corrected enrollment file is submitted prior to the file being finalized. The process change appears to be effective in correcting the findings but will require additional assessment to verify that the changes with NSC persist to NSLDS. Implementation of the ad hoc process based on NSC's error reporting is already in place. Review and Assessment of our approach to enrollment reporting should be completed by June 30, 2025, with development, implementation, and training of new processes completed by August 31, 2025. For inquiries regarding this finding, please contact Anthony Schmid at anthony.schmid@sa.ucsb.edu."

Finding: The District's fiscal year 2023 Single Audit reporting package was not submitted to the Federal Audit Clearinghouse within the required time period. The Single Audit reporting package for the District's fiscal year ended June 30, 2023 should have been submitted to the Federal Audit Clearinghouse by November 30, 2023. Corrective Actions Taken or Planned: As part of the policies and procedures update, the Business Office has included a section on compliance, with the creation of a compliance calendar to ensure all filings are completed on a timely basis including auditor and auditee certifications for the Federal Audit Clearinghouse. The Business Office will continue to follow internal policies and procedures, including deadlines for fiscal year-end process. Contact Person: Douglas Ogarek, Assistant Superintendent and Chief School Business Official Anticipated Completion Date: March 31, 2025

Finding 2024-001 Student Status Changes Condition The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 6 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The College has updated its policies and procedures to ensure notification to the National Student Loan Data System are performed timely. All members of the responsible team continue to undergo formalized training to ensure their knowledge and proficiency regarding all applicable rules and regulations are kept up to date. Name(s) of Contact Person(s) Responsible for Corrective Action: Thomas Camillo, Registrar Kevin Thomas, D.O., Assistant Dean of Institutional Enrollment Management Anticipated Completion Date: 6/30/2025 Policies & Procedure update was completed during FY24 Software training for existing staff continued through the summer of 2024

Condition: The System obtained a loan from the Department of Housing and Urban Development ("HUD") during their fiscal year June 30, 2021. The proceeds of the loan were used to repay a loan with another financial institution during that same year. The HUD loan includes continuing reporting requirements, which require the loan to be reported on the Schedule until it is repaid. The System improperly excluded the HUD loan balance from their Schedule in previous years. The beginning of the year loan balance has been reported on the System's Schedule for the year ended June 30, 2024, in accordance with 2 CFR 200.502(b). Planned Corrective Action: Management will put procedures in place to identify federal reporting requirements for federal loans and grants. Contact person responsible for corrective action: Michael Haynes, CFO and Debbie Caldwell, Controller Anticipated Completion Date: 06/30/2024

Our recommendation is that procedures be implemented to ensure the Project is aware of all external reporting requirements and timely filing can be met.

The Authority’s Board of Commissioners and management will continue to rely on the use of their outside auditors to prepare the schedule of expenditures of federal awards that were presented in accordance with generally accepted accounting principles. Management will assign a person within the Authority with the skills, knowledge and expertise to review and approve the schedule of expenditures of federal awards.

Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-006 Untimely Review of SSI Termination Name of contact person: Corrective Action: Proposed completion date: Access and review the SSI Medicaid Termination Report daily in NC FAST. Assign staff or a designated point person to monitor and act on SSI terminations flagged in the system. Set up system alerts or reminders in NC FAST to notify staff of pending SSI terminations requiring immediate review. Develop a log or tracker (manual or digital) to record SSI termination cases, including review dates, actions taken, and deadlines. Use NC FAST or a supplemental tool to track cases through the review process, ensuring no cases fall through the cracks. Retrain staff on Ex Parte Reviews for SSI terminations, including the process for reviewing and evaluating ongoing eligibility. Reinforce the importance of timely action to avoid benefit gaps or unnecessary terminations. Provide clear, step-by-step instructions for handling SSI terminations, including where to find relevant information in NC FAST and how to document actions in case notes. Conduct second-party reviews of SSI termination cases to ensure timely and accurate action is taken. Supervisors should periodically audit a sample of cases to identify delays or errors. Contact clients as soon as an SSI termination is flagged, requesting updated information and notifying them of the potential impact on their benefits. Provide clear instructions on what documents are needed to reassess eligibility. Use NC FAST to track follow-ups with clients, ensuring they respond within required timeframes. Ensure staff are completing Ex Parte Reviews as required, utilizing existing evidence and verifications to determine continued eligibility without unnecessary delays. Develop workflow efficiencies to handle SSI terminations more effectively, such as batching similar cases for quicker review. Run O&M and Medicaid reports to monitor the timeliness of SSI termination reviews. Share progress and findings during staff meetings to promote transparency and improvement. Review reports to identify recurring issues or barriers causing delays and address them promptly. By establishing a system of regular monitoring, staff training, and supervisory oversight, the issue of untimely SSI termination reviews can be effectively addressed and prevented in the future. Management monitor daily to track progress of this issue and modify the controls as needed. Tiffiany Walton, Interim Director Anetre Vaughan, Adult Medicaid Supervisor Melissa Castelow, F&C Medicaid Supervisor Section III - Federal Award Findings and Question Costs BUILD YOUR FUTURE ON OUR FOUNDATION 115 Justice Drive  Suite 1  Winton, North Carolina 27986 Office 252.358.7805  Facsimile 252.358.0198  www.HerfordCountyNC.gov 123

The Municipality is in the process of changing to a new accounting system that allows Section 8 Program transactions to be recorded and thus maintain a complete and reliable accounting record.

Management will develop procedures to ensure that reports are submitted timely and any new filing deadlines will be documented and met without exception.

Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I and ESSER III amounts reported for the reports covering the FY22 time period ($22,163 and $409,347, respectively) did not agree to the underlying expenditure records ($3,796 and $404,347 respectively) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER II amount reported for the reports covering the FY23 time period ($131,439) did not agree to the underlying expenditure records ($153,216) for the period of July 1, 2022 through June 30, 2023). We also noted there was no documented, secondary review of the information in the FY23 annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Dr. David Stashevsky Contact Phone Number: 765-378-3329 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The assistant superintendent will manage the grant with the superintendent providing oversight. The assistant superintendent will coordinate the receipts and expenditures of funds with the corporation treasurer. The superintendent will review all financial reports and approve in writing with notification sent to the assistant superintendent and treasurer. Anticipated Completion Date: The correction will be on the next annual report when it is due.

Management agrees with the findings and will take the necessary corrective actions. The Organization will create an internal control mechanism to track Federal Awards throughout the year in order to prevent and detect any potential material misstatements and make it available to the auditors at the end of the year.

Information on the federal program: Subject: Education Stabilization Fund (ESSER) - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the reporting compliance requirements. The School Corporation was not formally reviewing the ESSER reports being submitted by comparing the underlying expenditure detail to the amounts reported for each grant for the reporting period. Context: The School Corporation was required to submit six Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. Crowe noted the following reporting errors for the Year 3 reports (July 1, 2021 through June 30, 2022). The ESSER If amount reported on the Year 3 report ($585,040) did not agree to the underlying expenditure records ($581,468). This is the exact amount reported as the SEA reserve amount on the Annual Data Report. Crowe noted the ESSER Ill amount reported on the Year 3 report ($0) did not agree to the underlying expenditure records ($351,831). Crowe noted the following reporting error for the Year 4 reports (July 1, 2022 through June 30, 2023). The ESSER Ill amount reported on the Year 4 report ($1,062,765) did not agree to the underlying expenditure records ($1,054,618). This is the exact amount reported as the SEA reserve amount on the Annual Data Report. Corrective Action Plan: The School Corporation will implement internal control procedures to ensure the amounts reported in the annual data reports agree to the underlying support and detail from the internal records. A formal review process will be implemented. Person responsible for implementation and projected implementation date: The Corporation's Treasurer and Superintendent will be responsible for implementing the corrective action, which will be implemented immediately.

Recommendation: The Authority should continue to review internal controls currently in place and improve internal controls over financial reporting so that financial statements are in compliance with generally accepted accounting principles. Views of Responsible Officials and Planned Corrective Actions: The Authority will continue to review the accounting system and related financial reporting system to identify and correct material misstatements to the financial statements.

The current year Schedule of Findings and Questioned Costs reported no matters in Section II – Financial Statement Findings and one matter in Section III – Federal Award Findings and Questioned Costs. Current year audit findings: 2024-001 Reporting of Draws to UDS Finding Description: Significant Deficiency – Internal Control over Compliance; It was identified that the UDS report submitted for reporting year 2023 was prepared using the accrual basis of accounting instead of the required cash basis. Planned corrective actions: Staff Training and Education: provide training to finance and compliance staff on UDS reporting requirements; require annual refresher training on financial reporting compliance. Review and Reconciliation Procedures: implement an internal review process before UDS report submission to ensure compliance with reporting standards; assign an independent reviewer within the finance team to verify that financial data is recorded on the correct basis before final submission. Internal Control Enhancements: implement periodic internal audits to assess compliance with reporting requirements and accounting standards. Corrective action taken: Upon discovery of this issue, CHCW promptly reviewed the reporting methodology and identified the discrepancy. The finance team corrected this issue for the 2024 UDS report, ensuring that all financial data was reported using the correct cash basis of accounting. Internal controls have been strengthened to prevent future occurrences of similar issues. Completion date: The correction for the 2024 UDS report has been completed. Staff training was conducted January 16, 2025. Review procedures and internal control enhancements have been fully implemented. Contact person responsible for corrective action: Tamiko Wilkens, Controller – Responsible for training and oversight. Desiree Ashbrooks, Chief Financial Officer – Responsible for reviewing and ensuring compliance.

Finding: For sub-awards subject to the Transparency Act, the awarding entity must enter the award information in agreement with the award contract to the FSRS portal. Management was unaware of the requirement for award information to be input into the FSRS portal for a sub-award that was subject to the Transparency Act. Corrective Action: 1. Review and ensure policies are up to date and comply with the federal awards that are subject to the Funding Accountability and Transparency Act. 2. For new federal awards, identify whether the award is subject to the Federal Funding Accountability and Transparency Act and develop a task list to ensure the reporting requirement is fulfilled timely. 3. Designate the reporting responsibility with respect to FFATA reporting to the accounting manager with oversight from the Controller and CFOO. 4. Establish periodic meetings between programs, compliance and finance to report on the FFATA compliance when applicable.

Food Distribution Cluster US Department of Agriculture / Oregon Department of Human Services / Farmers Market Fund Federal Assistance Listing Number: 10.565, 10.568, 10.569, 10.182, 10.331 Federal Program Name: Food Distribution Cluster, Local Food Purchase Assistance Cooperative, Gus Schumacher Nutrition Incentive Program OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Starr Yurkewycz, Director of Partnerships and Programs; Nathan Harris, Director of Community Philanthropy; Shannon Oliver, Interim Director of Operations Corrective Action Plan: Finance will assess requirements and establish procedures and internal controls to ensure the consistent application, billing, and reporting of indirect cost rates across all federal awards. This will include collaborating with grant writing staff during the pre-application and pre-award phases to centralize grant preparation and ensure indirect rates are accurately applied in grant proposals and budgets. Multiple dedicated review steps in the grant lifecycle will be developed to both ensure accuracy of the rates charged and address any changes from the Federal Government. Existing strengths, tools, and capacity will be reviewed to support this process, including alignment with subrecipient indirect cost practices. Training will be provided to individuals responsible for these controls to ensure accurate implementation and ongoing compliance. These actions will improve our ability to manage indirect costs effectively and ensure compliance with federal requirements. The anticipated completion date is June 30, 2026.

Food Distribution Cluster US Department of Agriculture / Oregon Department of Human Services Federal Assistance Listing Number: 10.565, 10.568, 10.569, 10.182 Federal Program Name: Food Distribution Cluster, Local Food Purchase Assistance Cooperative OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Rut Martinez-Alicea, Director of Equity People Culture and Administration; Starr Yurkewycz, Director of Partnerships and Programs; Nathan Harris, Director of Community Philanthropy; Shannon Oliver, Interim Director of Operations Corrective Action Plan: Finance will collaborate with key stakeholders to develop and implement a time and effort reporting system that meets federal documentation standards. This plan will identify impacted personnel and tailor reporting processes based on different funding sources. This effort will be cross departmental, roll out may include iterations of testing and refining and require training adoption and monitoring. These actions will strengthen internal controls and ensure personnel costs are accurately recorded and appropriately allocated. The anticipated completion date is: Employee review & certification of time and effort estimates - June 30, 2026 Implementation of software solution for time and effort documentation - June 30, 2027

2024-002 Special Tests (Enrollment Reporting) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P243920 (7/1/2024 – 6/30/2025), P268K253920 (7/1/2024 – 6/30/2025) Contact Person: Catharine A. Punchello, Vice Provost and University Registrar, 609-984-1180, x3135 Corrective Action: National Student Loan Data System (NSLDS) has resolved the issue causing the Error Code 75 (EC75) errors. Our last large batch of 75 errors was received in response to our Student Status Confirmation Report (SSCR) on July 8, 2024. We received one EC75 on September 13, 2024 and two EC75 on November 8, 2024 and none since then. The University continues to monitor NSLDS’ error reports on our SSCRs to ensure we are aware if they return. The University will continue to submit the SSCR responses to the Clearinghouse and ensure we report individual graduations or enrollment if there are error codes that cannot be resolved timely through the Clearinghouse process. Anticipated Completion Date: Completed

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to the National Student Loan Database System (NSLDS) within the appropriate timeframe as required by regulations. University of Maine at Farmington Condition: During our testing of 40 students, we noted four students at the University of Maine Farmington (UMF) whose campus enrollment effective date did not match their program enrollment effective date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: After a similar audit finding in 2022, UMF understood that having the error reports from the National Student Clearinghouse (NSC) would correct this problem going forward. It was subsequently discovered that the internal report used in submitting withdrawals to the NSC pulled the Program Enrollment Effective Date from the wrong location, resulting in instances where the reported date did not match the Enrollment Effective Date. UMF is actively working with UMS IT staff to correct this report. In the meantime, these dates have been updated manually on the NSC website for all withdrawn students, including the four identified in this finding. Name(s) of the contact person(s) responsible for corrective action: Lisa Beane, Assistant Registrar for the University of Maine at Farmington. Planned completion date for corrective action plan: April 2025.

Audit Finding 2024-001 - The tenant security deposits bank account was insufficient to cover the tenant security deposit liability and was not held in an interest bearing account. Response: Funds had been withdrawn due to a shortfall in operating cash which was needed for necessary repairs to the property. Management intends to replenish the security deposit bank account as soon as funds become available. In addition, management is researching the feasibility of finding a bank that will pay sufficient interest to cover any fees charged. Name and Title of contact person responsible for corrective action: Linda Holder Executive Director – Houston Housing Management Corporation - Fulton Gardens - PO Box 1819 - Houston, TX 77002 - 713-526-9470