Corrective Action Plans

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF COAMO Corrective Action Plan For the Fiscal Year Ended June 30, 2023 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 Fiscal Year: 2022-2023 Principal Executive: Hon. Juan C. García Padilla, Mayor Contact Person: Mrs. Miraisa David Esparra, Finance and Budget Director Phone: (787) 825-1150 Original Finding Number: 2023-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: The Program Director is aware about the compliance requirement. We gave instructions to the Program Director to maintain a dateline control sheet to ascertain that required reports were submitted within the due date. Implementation Date: March 21, 2024 Responsible Person: Mr. Héctor R. Sanjurjo Rodríguez Federal Programs Director

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF COAMO Corrective Action Plan For the Fiscal Year Ended June 30, 2023 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 Fiscal Year: 2022-2023 Principal Executive: Hon. Juan C. García Padilla, Mayor Contact Person: Mrs. Miraisa David Esparra, Finance and Budget Director Phone: (787) 825-1150 Original Finding Number: 2023-003 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: As expressed in the corrective action related to Finding 2023-002, we are going to identify budgetary resources to engage another staff to work with the capital assets subsidiary ledger completeness. Implementation Date: During the Fiscal Year 2023-2024 Responsible Person: Mrs. Miraisa David Esparra Finance Department Director

TOCC RESPONSE TO 2023-001 (Significant Deficiency) Tohono O'odham Community College’s written information security program will be amended immediately to require multi-factor authentication for Jenzabar, the College’s data management system, and for PowerFAIDS, the student financial aid software. Multi-Factor Authentication, now available through Jenzabar’s “Jenzabar 1” upgrade, which is in the cloud, and which TOCC transitioned to in January and February 2024, will be implemented by June 30, 2024. Multi-factor authentication for Jenzabar will be set up using the Microsoft Hybrid Identity Services within the Microsoft Azure Cloud Architecture. In addition, not later than June 30, 2024, PowerFAIDS software, currently the “desktop” edition, will be transitioned to the cloud-based product that accommodates MFA. Dean for Sustainability Dr. Mario Montes-Helu, is responsible for implementation of this plan.

Department of Education 2023-018 Education Stabilization Fund – Assistance Listing No. 84.425C Condition: Property records did not contain accurate information related to certain equipment purchases. Recommendation: We recommend the institutions strengthen its controls and processes related to capturing information relating to equipment purchases and ensure that property records properly reflect the required information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Property Management department has and will continue to double-check the information being entered into the University’s inventory system as it relates to equipment purchases and University property. The Property Management department will also ensure university departments are completing quarterly self-audits, verifying the information of all assets added to their inventory reports. To ensure this the Property Manager will increase communication reminding departments to check for any discrepancies of newly added assets. Name(s) of the contact person(s) responsible for corrective action: Tanya Donnell, Property Manager; Vance Siggers, Interim Vice President of Campus Operations; and Howard Brown, Vice President of Business and Finance. Planned completion date for corrective action plan: September 01, 2024. If the Department of Education has questions regarding this plan, please call Tanya Donnell, Property Control Manager at (601)979-6354.

Department of Education 2023-017 Education Stabilization Fund – Assistance Listing No. 84.425E, F, J, T (MUW) Condition: Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023. Quarterly Reporting: MUW submitted an out-of-date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022. Recommendation: We recommend the institutions strengthen their understanding of the reporting requirements established by the grant and ensure supporting documentation is maintained to substantiate amounts reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grant Accountant will strengthen their understanding of the reporting requirements established by the grant and stay abreast of any changes/revisions to those reporting requirements. They will work in conjunction with the Director of Sponsored Programs. Additionally, the Grant Accountant has created a cover sheet that will be signed by the Vice President of Finance and Administration upon review of the report being submitted. The completed and signed form will serve as evidence that accompanying report has been reviewed. All documentation will be retained in University Accounting. Name(s) of the contact person(s) responsible for corrective action: Rachel Sudduth. Planned completion date for corrective action plan: March 21, 2024. If the Department of Education has questions regarding this plan, please call Susan Sobley at(662) 329-7214. 2023-017 Education Stabilization Fund - Assistance Listing No. Assistance Listing No. 84.425E, F, J, T (MVSU) Condition: Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022. Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023. Recommendation: We recommend the institutions strengthen their understanding of the reporting requirements established by the grant and ensure supporting documentation is maintained to substantiate amounts reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The quarterly reports with supporting documentation have been submitted to the Director of Accounting and Vice President for Business and Finance review prior to the posting deadline. This action started with the quarterly report submitted for the quarter ending June 30, 2023. The deadline for posting this quarterly report was July 10, 2023. Additionally, the annual reports with supporting documentation will be submitted to the Director of Accounting and Vice President for Business and Finance in a timely manner for review and verification prior to the submission deadline. Name(s) of the contact person(s) responsible for corrective action: Samuel Melton Planned completion date for corrective action plan: July 10, 2023 If the U.S. Department of Education has questions regarding this plan, please call Samuel Melton at 662.254.3882.

Department of Education 2023-015 Education Stabilization Fund – Assistance Listing No. 84.425F Condition: The University drew funds in fiscal year 2022 for amounts earned in fiscal year 2022 but were not reported on the SEFA until fiscal year 2023. Recommendation: We recommend the institution review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: University Accounting will review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified. Name(s) of the contact person(s) responsible for corrective action: Rachel Sudduth Planned completion date for corrective action plan: April 1, 2024 If the Department of Education has questions regarding this plan, please call Susan Sobley at 662-386-1403.

Department of Education 2023-014 Return of Title IV Funds, Assistance Listing No. 84.063, 84.268 Condition: The return of funds was calculated improperly. Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the university was not in compliance with federal financial aid regulations when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date (34CFR section 668.22). We recommend the university review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are accurately completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The R2T4 process has been updated to include placing the requirement for exit counseling as a condition for submission of the withdrawal form. An additional notification will be sent after the R2T4 process has been completed. Name(s) of the contact person(s) responsible for corrective action: Ozie Ratcliff – Director of Financial Aid Planned completion date for a corrective action plan: The updated process will begin on 3/25/2024. If the Department of Education has questions regarding this plan, please contact Ozie Ratcliff at 601-979-3347.

Department of Education 2023-013 The Gramm-Leach-Bliley Act (GLBA)Compliance (ASU) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: The Institution is required to perform Safeguards that address the required areas noted in GLBA 16 CFR 314.4, which are (1) the Institution designated a Qualified Individual responsible for implementing and monitoring the Institution’s information security program, (2) the Institution’s written information security program addresses the required minimum seven elements. CLA identified that the organization does not meet compliance requirements outlined in the GLBA Safeguards Rule. The institution’s policy identifies a qualified individual (such as a CIO, ISO, CISO) responsible for the Information Security program. In addition, the written information security program (WISP) did not address certain required elements. CLA recommends that the safeguards are updated/performed per GLBA requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Center for Information Technology Services is moving towards completion of the GLBA 16 CFR 314.4 requirements: a) Fully Compliant b) Fully Compliant c) Partially Compliant d) Fully Compliant e) Fully Compliant f) Vendor Management policy and program in design g) Fully Compliant h) IR Plan in draft i) Not Completed To address “Qualified Individual”, the university has retained vCISO services of Pileum, reporting to the CIO. Pileum is providing annual risk assessments and assisting with authoring/auditing required controls, policy, procedures, and security program documentation. All in-progress requirements and the published university statement of compliance will be completed by May 31, 2024 Name(s) of the contact person(s) responsible for corrective action: Desmond L. Stewart, Interim Chief Information Officer Planned completion date for corrective action plan: May 31, 2024 If the U.S. Department of Education has questions regarding these plans, please call Juanita Edwards at 601-877-6672. 2023-013 The Gramm-Leach-Bliley Act (GLBA) Compliance (MVSU) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: The Institution is required to perform Safeguards that address the required areas noted in GLBA 16 CFR 314.4, which are (1) the Institution designated a Qualified Individual responsible for implementing and monitoring the Institution’s information security program, (2) the Institution’s written information security program addresses the required minimum seven elements. CLA identified that the organization does not meet the following compliance requirements outlined in the GLBA Safeguards Rule. (b.1b) The institution has been approved by the individual leading the information security program (b.3) The institution’s written information security program and verify the implementation of safeguards b.3.1 to b.3.8. (b.3.5) the institution's written information security program identifies the use of multi-factor authentication for individuals accessing sensitive information across systems. (b.3.7) the institution’s written information security program includes an adopted change management policy with procedures documented accordingly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have engaged with Pileum Corporation, who have given us a Cybersecurity Scorecard. This scorecard evaluated on five NIST controls: 1. Identify, 2. Protect, 3. Detect, 4. Respond, and 5. Recover. The scorecard tells us what is: 1. Effectively controlled, 2. Gaps identified, and 3. Not implemented. According to this report, there are 60% of the items listed that are not yet implemented. One of the main points of interest is the lack of a comprehensive plan which fully addresses: 1. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal and 2. Detecting, preventing and responding to attacks, intrusion, or other systems failures. We are making this a priority to complete by the end of December 2024. Name of the contact person responsible for corrective action: Dameon A. Shaw, Vice President for University Advancement, External Relations and Information Security. Planned completion date for corrective action plan: December 2024. If the Department of Education has any questions regarding this plan, please call Dameon Shaw at 662-254-3790.

Department of Education 2023-012 Direct Loan Exit Counseling Student Financial Aid Cluster – Assistance Listing No. 84.268 Auditors' Recommendation: During CLA testing of Eligibility. CLA noted that the University was not in compliance with the federal financial aid regulations all schools that participate in the Federal Student Aid programs are required to provide exit counseling to student borrowers who withdraw from school. This requirement is outlined in 34 CFR section 685.304. Specifically, exit counseling must be provided within 30 days after the school learns that the student borrower has withdrawn from school. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The R2T4 process has been updated to include better communication between the Director of Financial Aid and the University Registrar to monitor enrollment status changes and ensure that the information used for the R2T4 calculations is accurate. The Director of Financial Aid will review the staff members' processing of R2T4 calculations to ensure accuracy. Name of the contact person responsible for corrective action: Ozie Ratcliff – Director of Financial Aid Planned completion date for corrective action plan: Updated process will begin 3/25/2024. If the Department of Education has questions regarding this plan, please contact Ozie Ratcliff at 601-979-3347.

Department of Education 2023–011 Outstanding Student Refund Checks Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that have not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. CLA recommends that the University review the requirement and implement a monitoring control to monitor the checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Create a policy to address the following: Returned or unclaimed Title IV Refunds will be successfully delivered to recipients (students or parents) or returned to the appropriate federal agency after 180 days outstanding. Additional attempts may be made to contact recipients; however, all unclaimed funds will be returned to the appropriate aid program no later than 240 days after the initial disbursement. The Accounting Office will maintain an “Outstanding Title IV Refund Checks/EFT Returns” list that will be provided to the Bursar’s Office every month. The Bursar’s Office will review the “Outstanding Title IV Refund Checks/EFT Returns” list every month and follow the procedures below regarding the outstanding checks/EFT returns.  The Bursar’s Office will use all reasonable means to locate the student or parent whose Title IV refund checks or returns have become 120 days old.  If all attempts are not successful, any outstanding Title IV refunds checks that have become stale dated (over 180 days) will be voided. The Bursar’s Office will make an entry, after a check has been voided, debiting the student account, and crediting a designated account that the Accounting’s Office will specify. This entry will then be interfaced to the Finance General Ledger debiting Student AR and crediting “Unclaimed Title IV Account”.  The Bursar’s Office will then send an e-mail notice to the Financial Aid Office containing the student’s name, student ID number, Title IV program(s), aid year and dollar amount that has been credited to the “Unclaimed Title IV Account”.  Based on the information provided, funds will be returned to the appropriate aid program within 210 – 240 days.  The Financial Aid Office will make the appropriate change(s) to the Fiscal Operations Report and Application to Participate (FISAP).  The Accounting’s Office will reconcile the “Unclaimed Title IV Account” every month. Name(s) of the contact person(s) responsible for corrective action: Charlette Mock, Director of Accounting and Lucreta Tribune, Associate Vice President for Finance Planned completion date for corrective action plan: This plan will be implemented no later than April 2024, with ongoing review of the process. This process should be completely in effect by the end of the current fiscal year, June 30, 2024. If the U.S. Department of Education has questions regarding these plans, please call Juanita Edwards at 601-877-6672.

Department of Education 2023-010 NSLDS Enrollment Reporting (ASU) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have made significant changes during fiscal year 2024 in the Office of Student Records to address controlled and non-compliance Title IV regulations. While significant changes were made, we recognize that additional improvements are needed. The Registrar will implement internal controls to ensure all Title IV requirements are met regarding enrollment reporting. In addition, the Registrar will create a student enrollment procedures manual and implement a monitoring process to ensure that enrollment statuses are reported accurately and timely to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Kisha Bond Planned completion date for corrective action plan: The planned completion date for this corrective action will be August 2024. If the U.S. Department of Education has questions regarding these plans, please call Juanita Edwards at 601-877-6672. 2023-010 NSLDS Enrollment Reporting (JSU) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations the school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Jackson State University has an established and published academic calendar which guides the day-to-day academic operations and functions of the University. In some instances, the census and financial purge deadlines are extended to ensure students complete their registration requirements. When extensions are provided, the enrollment file is unable to be submitted timely and also causes delays in processing the Enrollment Error report. To alleviate the untimely submission of the Enrollment Report, different practices have been established to aid students in completing their registration before the published deadline and subsequently ensuring the Enrollment file is submitted by the deadline. The University will adhere to published deadlines to prevent delays in reporting and error resolution. The University will enhance semester onboarding by: • Begin purge process earlier in the semester to ensure timely enrollment verification for each semester. • Increase communications between Office of the Registrar and Office of Financial Aid to weekly checks to discover and resolve resolutions within a 5-day window. This ensures we will meet the 10-day resolution deadline. Name(s) of the contact person(s) responsible for corrective action: Ozie Ratcliff, Director of Financial Aid and Lekesha Tubbs, University Registrar. Planned completion date for corrective action plan: Updated process will begin 3/25/2024. If the U.S. Department of Education has questions regarding these plans, please call Ozie Ratcliff at 601-979-3347. 2023-010 NSLDS Enrollment Reporting (UMMC) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations the school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Enrollment Management worked with DIS to create a supplement report (UMC RPT ST Student Academic Program Status Withdrawn, Dismissed or LOA-V2) to capture students whose enrollment status changes but is not picked up through monthly clearinghouse submissions. This report will run in tandem with our monthly clearinghouse report and any student with a status change not pulled on the clearinghouse report will be manually updated within the National Student Clearinghouse database by our Associate Director of Enrollment Services. These updates will then be reported to NSLDS, along with our monthly enrollment report. Name of the contact person responsible for corrective action: Dr. Emily Cole, Executive Director of Enrollment Management Planned completion date for corrective action plan: Effective immediately. The Office of Enrollment Management will begin utilizing the new report with the March enrollment file submitted to clearinghouse. If the U.S. Department of Education has questions regarding these plans, please call Julie Schwindt at 601-984-1058.

Department of Education 2023–009 Common Origination and Disbursement (COD) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The Fall 2022 and Spring 2023 disbursement dates in COD for Parent Plus Direct Loans did not match the disbursement date on the student ledgers. Auditors’ Recommendation: During CLA testing of Eligibility. CLA noted that the University was not in compliance with the federal financial aid regulations COD reporting requirements, including reporting disbursements, adjustments, and cancellations in a timely and accurate manner. CLA recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office will conduct bi-weekly reviews of enrollment changes, including university withdrawals. In addition, bi- weekly reviews of adjustment completion will be done to ensure banner adjustments are sent to COD within 10-14 business days. Name of the contact person responsible for corrective action: Ozie Ratcliff – Director of Financial Aid Planned completion date for corrective action plan: Updated process will begin 3/25/2024. If the Department of Education has questions regarding this plan, please call Ozie Ratcliff at 601-979-3347.

Department of Health and Human Services 2023-008 Head Start Program – Assistance Listing No. 93.600 Condition: The University filed the Real Property Status Report SF-429 after the deadline. Recommendation: We recommend the institutions review and revise its current reporting procedures and review requirements to ensure that the reports are submitted accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Mississippi State University will review and revise the current reporting procedures for the SF 429: Real Property Status Report to ensure reports are submitted in accordance with established deadlines. Name(s) of the contact person(s) responsible for corrective action: Tucker, Director Sponsored Programs Planned completion date for corrective action plan: June 30, 2024 If the Department of Health and Human Services has questions regarding this plan, please call Jonathan Tucker at 662-325-1930.

Department of Health and Human Services 2023-007 FFATA Reporting – Reports filed past the deadline – Assistance Listing No. 93.211 Condition: FFATA reporting was not submitted timely Auditors’ Recommendation: We recommend the institution strengthens their understanding of the reporting requirements established by the grant and ensure reports are filed timely Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The respective Supervisor of Post-Award Accounting or the Accounting Specialist position which handles this responsibility reviews a fully executed sub-agreement and they identify or determine if the applicable award, whether new or an amendment, meets the FFATA threshold. If the award meets the prescribed threshold, essential data are compiled from each applicable sub-agreement(s) via an internal Post-Award sub-award tracking spreadsheet for entry into the FSRS.gov. Effective September 2023, the above stated process is being completed no more frequently than weekly, and no less frequently than monthly. Once all data has been successfully entered and uploaded, the Supervisor, Accounting Specialist, or designee will confirm that the report has been successfully submitted via an email. Beginning March 2024, submitted reports are saved on the shared drive in a FFATA folder organized by fiscal year and month. The submission date will be incorporated into the name of the file to specifically identify the date the report was successfully submitted. Effective March 2024, once the FFATA reporting process is complete, notification is also made via email to the appropriate management personnel regarding the completion of this entire process as an additional internal control and to ensure compliance of this reporting requirement as identified in 2 CFR Part 170. Name(s) of the contact person(s) responsible for corrective action: Julie Schwindt, Director, Post-Award Accounting Planned completion date for corrective action plan: March 31, 2024 If the Department of Health and Human Services has questions regarding this plan, please call Julie Schwindt at 601-984-1058.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Numbers: 84.425U Contact Person: Aracely Soto, Director of Finance Anticipated Completion Date: July 1, 2024 Planned Corrective Action: All bids that include laborers and mechanics employed by contractors or subcontractors to work on construction contracts must include language requiring prevailing wage rates, and the vendor must agree to provide copies of certified payrolls for all funded construction projects upon request. The District is not planning to use the Education Stabilization Fund for any future construction.

Finding 2023-006 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren will submit a revised ESSER data report to DOE. Anticipated Completion Date: Completed as of the date of this report.

Finding 2023-004 – Title I Grants to Local Educational Agencies - Special Test and Provisions – Annual Report Card, High School Graduation Rate Audit Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The CFO and Associate Superintendent will send a memo to principals and registrars defining documentation that must be maintained for mobility purposes. Anticipated Completion Date: 6/30/24

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Business Office and Payroll staff will review a Labor Distribution Report to verify that the staff is only paying appropriate personnel from the Food Service Fund. Anticipated Completion Date: 6/30/24

Views of Responsible Officials and Planned Corrective Action: The County agrees with the finding and recommendation. The County was awarded $32M in new funding to address the housing needs of low- and moderate-income residents facing eviction and/or homelessness during the COVID pandemic. Staff was focused on effectively managing the COVID funding during that time to help keep residents safely housed; therefore, the monitoring tasks for HOME-assisted TBRA were not completed as required. The Department is creating additional Standard Operating Procedures (SOPs) to ensure all steps are being taken to meet monitoring requirements, even if current personnel changes so the process can continue effectively and on time. Action taken in response to finding: The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). 1. Completion of a HOME/HOME-ARP Training Plan 2. Completion of a HOME/HOME-ARP Monitoring Completion Plan 3. Ongoing prioritizing of progress as part of the regular agenda in twice monthly Finance & Grants meetings 4. Completion of an SOP for current and future continuity of function Regarding HOME-ARP funds: the rental units must comply with the same requirements as HOME per 24 CFR 92.251 for (a) new construction, (b)rehabilitation projects, (c)(1) and (2) acquisition of standard housing, (e) manufactured housing, and (f) on-going property condition standards. 1. These requirements are being added to the HOME/HOME-ARP Reports, as part of the Monitoring Completion Plan 2. Ongoing prioritizing of progress as part of the regular agenda in twice monthly Finance & Grants meetings 3. Completion of an SOP for current and future continuity of function Name of contact person (s) responsible for the corrective action plan: Kim Zanti, Division Chief, Community Planning and Grants

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work search were adjusted in order to protect employees and claimants. Before the pandemic, all claimants were required to come to the local office to verify their identity. Removing these process controls resulted in several consequences as itemized below: • By waiving the waiting week, the claimant was able to receive payment the following week. For example, a fraudster could file a claim on Friday, then receive payment on Sunday, removing the typical week that an employer would respond to validate the separation from employment. • The information mailed to the employer and claimant were not received before payments were made due to the lack of waiting week. • Businesses were closed at that time and did not respond to the unemployment paperwork timely to report fraudulent claims. • Identity theft fraudsters often changed the address of the individuals for which they had filed claims in order to prevent the victims from being notified and reporting the fraud. In 2020, the work search requirement was reinstated. In 2021, all claimants had to verify their identity in-person at the local office before the claim was opened for a regular unemployment claim. The UIdentify program was utilized for identity verification for the PUA claims filed after January 1, 2021. The waiting week was reinstated in January 2021, which lengthened the time period for employers to respond before payment was issued. In addition, Internal Audit created the Fraud Investigation Unit and hired additional staff to focus on investigating the identity theft fraud claims. When the perpetrator is identified, a determination is issued and an overpayment is established in the perpetrator’s name/SSN for collection. The NASWA Integrity Data Hub (IDH) crossmatch was implemented in July 2020 as well in an effort to identify additional fraudulent claims for investigation. ADWS was the first UI program to implement 2 projects with the Department of Labor for identity verification. One is using Login.gov and the other involves the United States Postal Service where they verify the identity of claimants for using multifactor authentication and in person presentation of ID. The Login.gov pilot started in 2022 and the USPS pilot project started in 2023. 1. The Login.gov project uses the current system that Federal agencies use to verify identity and went into service in Arkansas as of March 2022. A link is given to the claimant, when they select verify ID through login.gov and go through the steps to verify their identity through the federal government system. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. 2. The United States Postal Service project, implements in Arkansas March 2023, offers the claimant the same link as Login.gov, but grants the additional option to verify their identity at any US Post Office in the country. A barcode is created and must be taken with a valid government-issued ID (they are given examples) along with proof of current address to the post office in person. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. Anticipated Completion Date: Corrective action was taken for the ALA staff recommendations. Contact Person: Name: Sheri Rooney Title: Program Administrator Agency: Division of Workforce Services Address: 2 Capitol Mall City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-3382 Email Address: Sheri.Rooney@arkansas.gov

Views of Responsible Officials and Planned Corrective Action: We agree with the auditor’s finding and recommendations, and the following corrective action will be taken to improve the situation: • The Director of Computing Services will oversee the review subsections of 16 CFR 314 to ensure compliance with requirements. o Perform a more thorough GLBA Risk Assessment, which will be used to improve the institution’s security policy and posture. This is outlined in 16 CFR 314(b). o Improve safeguards and more frequent testing to improve system security and threat transparency will be added, including email security and log file monitoring, in addition to other controls as outlined in 16 CFR 314(c) and (d). Several quotes have been acquired and are in the process of being reviewed. o Conduct a review of policies and training, as outlined in 16 CFR 314(e), and mitigate deficiencies in awareness training and policies. o Improve documentation around third-party service providers to ensure compliance with 16 CFR 314(f). o All response plans are to be reviewed and improved as needed because of the Risk Assessment and other monitoring activities to ensure appropriate activities are included and tested at regular intervals. o The institution will develop a compliance document to record efforts according to each section of 16 CFR 314, including those areas that are already compliant. It is the goal of SEARK College to remain in a state of continuous improvement and in compliance with required regulations. The Director of Computing Services will work with the Senior Leadership Team to ensure that appropriate resources are made available, and that activities occur in a timely manner. Anticipated Completion Date: The indicated reviews and assessments are already in progress, with a goal of June 30, 2024, to have fully integrated the stated improvements into our systems and procedures. Contact Person: Name: JoAnn Dupra Title: Director of Computing Services Agency: Southeast Arkansas College Address: 1900 Hazel St City, State, Zip: Pine Bluff, AR 71603 Phone Number: (870) 543-5993 Email Address: jdupra@seark.edu

Views of Responsible Officials and Planned Corrective Action: Management understands the recommendations provided in the finding. We are planning on updating our 2021 Risk Assessment with our campus community in the near future. In accordance with ALA's recommendation, we will focus on GLBA 16 CFR 314 elements and financial aid data. As with our 2021 Risk Assessment, our plan will be reviewed and accepted by our Chancellor. We intend to have the Risk Assessment updated and reviewed by June 30, 2024. We will also coordinate the risks identified with the extensive list of controls and policies that currently protect student’s financial aid information. These include: Acceptable Use Policy_V7_3.pdf Antivirus and Malware Policy_V2_1.pdf Cloud Services Policy_V1_2.pdf Confluence Screenshots Of Contact Information For Critical Systems (1).pdf Data Classification Policy_V1_2.pdf Data Encryption Policy_V7_1.pdf Data Management Use Protection Policy_V7_2.pdf Data Protection Policy_V7_2 Data Protection Policy_V7_2.pdf Disaster Recovery Business Continuity System Recovery Prioritization List_V1_2.pdf Disaster Recovery Procedure_V1_5.pdf Drive Data Deletion Policy_V7_2.pdf E-Learning Policies_V7_1.pdf Email and Digital Communication Policy_V8_2.pdf Email and Digital Communication Policy_V8_2.pdf Employee Data Deletion Policy_V7_2.pdf Encryption of Sensitive Data on Transmission Policy_V7_2.pdf Faculty Senate Legislation Reference_V6.1.pdf Firewall Blacklist and Whitelist Policy_V7_2.pdf Firewall Management Procedure_V7_2.pdf GLBA Risk assessment.docx Incident Response and Forensic Analysis Procedures_V7_5.pdf IT Employee Departure Procedures_V7_2.pdf IT Security Awareness and Competencies Policy_V1_5.pdf IT Services System Administration Privileged Access Management Policy_V7_2.pdf IT System Backup Procedures_V7_2.pdf IT System Patching Process_V7_3.pdf Lab / Classroom Administrative Rights Exception Request_V6_1.pdf Local Firewall Procedures for Workstations and Mobile Devices_V7_2.pdf Log Review Policy_V2_1.pdf Mobile Device Security - Remote Email Destruction Process_V1_1.pdf Mobile Device Security Policy_V2_1.pdf Multi-factor Authentication - Information Technology Services - UA Little Rock.pdf Network Patching Process_V1_1.pdf PCI Compliance _ Training Policy_V7_2.pdf Physical Security Policy_V1_3.pdf Retention of Records Policies_V7_2.pdf Security and Incident Response Team Policy_V1_3.pdf Security and IT System Access Policy_V1_2.pdf Student Account Deletion Policy_V7_2.pdf System Log Requirements_V8_2.pdf UALR Change Management Policy 2.2.pdf Vendor Remote Access Policy_V1_1.pdf Vulnerability Scan Policy_V7_2.pdf Wireless Network Guest Security Policy_V1_1.pdf Wireless Security Policy_V1_2.pdf Workstation Administrative Rights Exception Request_V6_1.pdf Anticipated Completion Date: June 30, 2024 Contact Person: Name: Gerald J. Ganz, Jr. Title: Vice Chancellor for Finance & Administration Agency: University of Arkansas at Little Rock Address: 2801 S. University Avenue City, State, Zip: Little Rock, AR, 72204 Phone Number: 501-916-5622 Email Address: GJGanz@ualr.edu

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work search were adjusted in order to protect employees and claimants. Before the pandemic, all claimants were required to come to the local office to verify their identity. Removing these process controls resulted in several consequences as itemized below: • By waiving the waiting week, the claimant was able to receive payment the following week. For example, a fraudster could file a claim on Friday, then receive payment on Sunday, removing the typical week that an employer would respond to validate the separation from employment. • The information mailed to the employer and claimant were not received before payments were made due to the lack of waiting week. • Businesses were closed at that time and did not respond to the unemployment paperwork timely to report fraudulent claims. • Identity theft fraudsters often changed the address of the individuals for which they had filed claims in order to prevent the victims from being notified and reporting the fraud. In 2020, the work search requirement was reinstated. In 2021, all claimants had to verify their identity in-person at the local office before the claim was opened for a regular unemployment claim. The UIdentify program was utilized for identity verification for the PUA claims filed after January 1, 2021. The waiting week was reinstated in January 2021, which lengthened the time period for employers to respond before payment was issued. In addition, Internal Audit created the Fraud Investigation Unit and hired additional staff to focus on investigating the identity theft fraud claims. When the perpetrator is identified, a determination is issued and an overpayment is established in the perpetrator’s name/SSN for collection. The NASWA Integrity Data Hub (IDH) crossmatch was implemented in July 2020 as well in an effort to identify additional fraudulent claims for investigation. ADWS was the first UI program to implement 2 projects with the Department of Labor for identity verification. One is using Login.gov and the other involves the United States Postal Service where they verify the identity of claimants for using multifactor authentication and in person presentation of ID. The Login.gov pilot started in 2022 and the USPS pilot project started in 2023. 1. The Login.gov project uses the current system that Federal agencies use to verify identity and went into service in Arkansas as of March 2022. A link is given to the claimant, when they select verify ID through login.gov and go through the steps to verify their identity through the federal government system. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. 2. The United States Postal Service project, implements in Arkansas March 2023, offers the claimant the same link as Login.gov, but grants the additional option to verify their identity at any US Post Office in the country. A barcode is created and must be taken with a valid government-issued ID (they are given examples) along with proof of current address to the post office in person. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. Anticipated Completion Date: Corrective action was taken for the controls the ALA staff recommended. Contact Person: Name: Sheri Rooney Title: Program Administrator Agency: Division of Workforce Services Address: 2 Capitol Mall City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-3382 Email Address: Sheri.Rooney@arkansas.gov

Corrective action planned: Utilize a CPA experienced with federal award to review and ensure compliance with grant proposals and activities. Anticipated completion date: April 30, 2024 Contact person responsible for corrective action: Jalen Tollefson, Grant Director

Management’s Response: The College will strengthen its policies and procedures to ensure documentation of review and approvals for reporting to ensure reporting compliance. Anticipated Completion Date: February 28, 2024