Corrective Action Plans

Finding 2023-007 Special Tests and Provisions – Perkins Loan Recordkeeping and Record Retention Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: We did not maintain all records as required under the program and as a result, subsequent to yearend, were required to buy back specific Perkins Loans that did not have proper documentation maintained. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: All loan documentation was provided to Department of Education as part of the liquidation process and any loans that did not have proper documentation were purchased back by the College in September 2023 and the Perkins Liquidation was complete with final reporting requirements completed. Anticipated Completion Date: September 30, 2023

Finding 2023-005 Special Tests and Provisions – Enrollment Reporting Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.063 – Federal Pell Grant Program Finding Summary: During testing of enrollment reporting, it was noted that 7 of 19 students tested were not reported to NSDLS with changes in effective dates and enrollment statuses; and the certification dates were not within 60 days of the changes and 8 of 19 students tested were reported to NSLDS with incorrect program begin dates. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The errors noted in tested were corrected when we were notified of the errors and additional review was taken to ensure that a final enrollment roster was submitted as required as part of the close audit process. Anticipated Completion Date: September 30, 2023

Finding 2023-004 Cash Management –Reconciliations (Direct Loan) Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.268 – Federal Direct Student Loans Finding Summary: When testing cash management related to reconciliations, the auditors noted 2 of the 12 monthly SAS reconciliations were not completed. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: The Student Financial Aid Director completed a final reconciliation after final disbursements were made to students to ensure all aid awards was correctly reflected. Anticipated Completion Date: September 30, 2023

Finding 2023-006 Reporting – Special Reporting – Fiscal Operations Report and Application to Participate (FISAP). Federal Agency Name: Department of Education Program Name: Student Financial Aid Cluster CFDA # 84.033 – Federal Work Study Program CFDA # 84.007 – Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA # 84.063 – Federal Pell Grant Program CFDA # 84.268 – Federal Direct Student Loans CFDA # 84.038 – Federal Perkins Loan Program Finding Summary: In testing key line items as indicated in the compliance supplement, the auditors noted 2 line items for which amounts reported in the FISAP did not agree to supporting records and documentation that were provided during testing. Lines that were not reported correctly were Part II, Section E Line 22 and Part II, Section D Line 7. Responsible Individuals: Jillaine Smith, Chief Operating Officer, Erin Drew, Facilitator of Advancement Services and Patty Pietz, Presentation Sisters Accountant. Corrective Action Plan: Any errors that were required to be corrected were made for 2022 and resubmitted to the Department of Education prior to the 2023 report being completed. Anticipated Completion Date: September 30, 2023

Department of Education Macalester College respectfully submits the following corrective action plan for the year ended May 31, 2023. Audit period: June 01, 2022 – May 31, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no findings in the current year that require corrective action plan. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.038, 84.268, 84.007, 84.063 Recommendation: We recommend the College evaluate the circumstances that delayed reporting disbursements to COD to ensure that it will not happen again. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We experienced a malfunction in our reporting software and were not aware of the issue until after the reporting deadline. We now have procedures in place whereby we confirm that COD has received the file once we have submitted it. Name(s) of the contact person(s) responsible for corrective action: Jenae Schmidt Planned completion date for corrective action plan: Implemented in November 2022. If the Department of Education has questions regarding this plan, please call Jenae Schmidt at 651-696-6214.

Contact person responsible for corrective action: Cynthia Duncanson, CFO. All findings related to the sliding fee application and calculations are results of occurrences at the front desk. In order to gain a better management of training and monitoring of this process, we have formed a team through the revenue cycle with oversite of front desk staff training, performance tracking and reporting and competency testing. This team consists of 2 revenue cycle supervisors, and 4 superusers. Performance outcomes, including sliding fee application calculation efficiency and application completion, will be reported to the site supervisors monthly, carrying a significant weight on overall performance measures Implementation/ Completion: Team development, immediate. Performance outcome reporting, January, 2024.

1780 Sloan Avenue Indianapolis, IN 46203 (317) 351-1534 To Whom It May Concern, This letter is in response to our Single Audit/Uniform Guidance Finding. We understand that we are to verify two items when ESSER funds are used for construction contracts over $2,000: 1. Verify that the required prevailing wage rate clauses are included in the contract—also known as Davis-Bacon Act compliance. 2. For each week in which work was performed under the contract, verify that the contractor submitted the required certified payrolls. Although we did state the contractor was to be compliant with all applicable laws and regulations, the contractor did not provide this information in a timely manner and we were subsequently unable to provide these requirements during the audit. Regarding Finding 2023-001, please know that our organization understands this requirement and will adhere to it moving forward. Our plan of action includes incorporating strict language of the requirement in both contract and bid documents, correspondence submitted weekly, and explicit penalties for a contractor if they are unable to comply, which could include withholding of payment or stopped work. In addition to the measures above, I will be responsible to ensure all contractors are following these requirements. If you have any questions, please do not hesitate to contact me. Best Regards, Luke Kahren Chief Operating Officer luke.kahren@vcpindy.org (317) 351-1534

The Board of Directors is and will remain involved in the financial affairs of the Cooperative.

The Board of Directors is and will remain involved in the financial affairs of the Cooperative.

The Cooperative will make required deposits to the General Operating Reserve.

The Board of Directors is and will remain involved in the financial affairs of the Cooperative.

The Board of Directors is and will remain involved in the financial affairs of the Cooperative.

Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: In order to remediate cited deficiencies and to bring Southern Wesleyan University into compliance with updated regulation changes to the Gramm-Leach-Bliley Act, the Department of Information Technology will update its written information security program. In addition, the department will also sufficiently document its security risk assessment and safeguards. This documentation will include sufficient information on general threats, the implementation of vendor management policies and reviews, and the implementation of an incident response plan. After all the aforementioned documentation has been compiled, the department will provide a report to the Board at the university's fall 2024 Board of Trustee’s meeting, detailing the measures enacted. Person Responsible for Corrective Action Plan: Warren Dennis, Assistant Director of Information Technology Anticipated Date of Completion: 06/01/2024

November XX, 2023 Office of the Secretary of State Audits Division 255 Capitol St. NE, Suite #500 Salem, OR 97310 Plan of Action for Wheeler County, Oregon Wheeler County, Oregon respectfully submits the following corrective action plan in response to deficiencies reported in our audit of fiscal year ended June 30, 2023. The audit was completed by the independent auditing firm Solutions, CPAs PC, John Day, Oregon. The deficiencies are discussed below with the Action Plan listed for each. 1. Material Weakness – Financial Statement Preparation Criteria: The financial statements are the responsibility of the county’s management, including the prevention or detection of material misstatements in the presentation and disclosure of the financial statements. Non-attest services performed by the auditor in the preparation of the financial statements cannot be considered compensating controls. Condition: The county engages their auditors to provide non-attest services for the preparation of its financial statements. Although common for municipalities the size of the county, this condition represents a control deficiency over the financial reporting process that is required to be reported under professional standards as long as management makes all financial reporting decisions and accepts responsibility for the content of the financial statements. However, those activities performed by the auditor are not a substitute for, or extension of, internal controls over the preparation of the financial statements in accordance with generally accepted accounting principles (GAAP). Cause: The county’s accounting personnel do not possess the advanced training that would provide the expertise necessary to prepare the financial statements and related notes in accordance with GAAP, and therefore may not be able to prevent or detect a material misstatement in the preparation and disclosure of the financial statements. Misstatements in financial statements may include not only misstated financial amounts, but also the omission of disclosures required by GAAP. Effect: Material misstatement in the preparation and disclosure of the financial statements in accordance with GAAP may not be prevented or detected. Misstatements in financial statements include not only misstated dollar amounts, but also the omission of disclosures required under GAAP. Recommendations: We understand that it may not be practical to acquire or allocate the internal resources to perform all the controls necessary over financial reporting. However, management (including the County Court) should mitigate this deficiency by keeping informed about the county’s internal controls, performing supervisory reviews, studying the financial statements and related footnote disclosures, and understanding its responsibility for the financial statements as a whole. Action Plan: We understand the importance of risk management and the need to address risks in an informed, cost-beneficial way. As a result of our cost-benefit analysis we have determined the value of incurring the additional expense of hiring a staff person or another firm to prepare our financial statements does not justify the cost. We accept the auditor’s recommendations and will attempt to implement in a timely manner. 2. Material Weakness – Preparation of the Schedule of Expenditures of Federal Awards Criteria: The schedule of expenditures of federal awards (SEFA) is the responsibility of the county’s management, including the prevention or detection of material misstatements in the presentation and disclosures of SEFA. Services performed in reconciling the SEFA to the trial balance during the annual compliance audit cannot be considered compensating controls of the county. Condition: During our reconciliation of the SEFA to the financial statements, and testing of controls, we noted material omissions from program expenditures reported. Additionally, identification of funds passed-thru to subrecipients were omitted from the county drafted SEFA. Cause: The county’s system of controls over the SEFA is lacking effective controls over completeness. Effect: Material misstatement in the preparation and disclosure of the financial statements in accordance with GAAP may not be prevented or detected. Misstatements in financial statements include not only misstated dollar amounts, but also the omission of required disclosures. Recommendations: We recommend the county develop further control procedures over drafting the SEFA to address completeness. We recommend the county develop a system of tracking federal awards and related compliance requirements to assist in accumulating information to prepare the SEFA. This deficiency is related specifically to the preparation of the SEFA and does not reflect on controls over compliance or transactional controls. Action Plan: We understand the importance of risk management and the need to address risks in an informed, cost-beneficial way. We have addressed this finding with plans to develop controls over preparing the SEFA. Specifically, we intend to track compliance requirements for all grants in a database to address internal control issues over completeness. We also intend to implement review and approval controls over the county drafted SEFA. 3. Significant Deficiency – Internal Control over Compliance with Federal Program Requirements Criteria or specific requirement (including statutory, regulatory, or other citation): The Secure Rural Schools and Community Self-Determination Act of 2000 requires a county receiving funds under the Forest Service Schools and Roads Cluster to perform an allocation of funds between Title I, II, and II under based on county court certified allocations. In the current year, that allocation included a federal sequestration of funds that was also required to be allocated to Title I and Title III, which resulted in noncompliance with the requirements related to earmarking and with special tests and provisions. Annual certification of funds spent under Title III is also required. In the current year, that certification included funds that were included in previous certifications, which resulted in noncompliance with the requirements related to reporting. Condition and context: During our review of the allocation of 2023 funds received, we noted an error in the allocation performed by the county. Title I had an overallocation of funds by $2,203, and Title III was under allocated by the same $2,203. The reconciliation of the amounts included in the 2022 annual certification for Title III funding identified an over certification of $11,303 that had already been included in the 2021 annual certification. Questioned Costs: Actual questioned costs totaled $2,203 and consisted of amounts passed through to local schools and expended in the road department on otherwise compliant uses. Cause: There is a lack of internal control over earmarking, reporting, and special tests and provisions over allocation of Forest Service Schools and Roads funding and the annual certification. The county lacks review and approval controls over the allocation of funds and the annual certification. Effect: The effect is noncompliance with earmarking, reporting, and special tests and provisions requirements. Recommendations: It is recommended that the county implement review procedures over the annual receipt to verify amounts allocated are complete and accurate prior to posting to the general ledger. A recalculation of both the certification and a detailed review of amounts used in the annual reporting is recommended. Action Plan: The county understands and concurs with this finding. It is the intention of the county to implement a review process to be completed prior to making formal allocation and reporting of Forest Service Schools and Roads Cluster.

2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their documentation and ensure that there are documented safeguards for identified risks. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The IT Executive Director will review the completed risk assessment to identify specific shortcomings, so that safeguards can be documented in relation to those specific risks. Additionally, he will review the updated GBLA regulations and ensure the University is in compliance. Name of the contact person responsible for corrective action: Brandon Ray, Executive Director, Information Technology Planned completion date for corrective action plan: January 31, 2023.

Department of Education 2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review their internal control procedures over awarding, return of title IV calculations, and professional judgment and implement a formally documented review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will make the following changes: Awarding: The following are internal controls that the University already has in place to review awards for accuracy. • Financial aid worksheet: As part of the awarding process every award year, a financial aid worksheet is created to verify that the awards input in Colleague are accurate. The worksheet is updated each time there is a change to a student’s financial aid eligibility or status. • COD report monitoring: On a weekly basis, reports are processed to determine if there are any discrepancies between what has been awarded in Colleague and what is being reported/accepted in COD. Any discrepancies found are reviewed and corrected. • Monthly loan/grant reconciliation: The monthly loan/grant reconciliation monitors for any discrepancies between what is shown as disbursed in Colleague and the disbursements that have been accepted by COD. Any discrepancies found are reviewed and corrected. • Over award report: Processed at the beginning of each term, this report details if any students are awarded beyond unmet need and/or cost of attendance. Any discrepancies found are reviewed and corrected. • Enrollment level report: Processed before the start of each term and at the end of the add/drop period, this report evaluates awarded enrollment level against actual enrolled credits. Any discrepancies found are reviewed and corrected. • Disbursement processing rules: There are rules built into the Colleague system to limit disbursement of awards when actual enrollment status does not match awarded status. Any discrepancies found are reviewed and corrected. Beyond the internal controls already in place, the University will implement the following: • Secondary review of awards: For new Financial Aid Counselors, all awards will be reviewed for the first two months to ensure accuracy and commitment to proper training. Additionally, based on current staffing levels, a random selection of 10% of all awarded students will be reviewed to evaluate for awarding accuracy. • Grade level review: After the 10th day of each term, a review will be performed to compare the current class standing of each student to the grade level that was used for awarding. Any discrepancies found will be reviewed and corrected. Return to Title IV (R2T4) Calculations: The Colleague system is used to process R2T4 calculations. This system has been developed to correctly calculate the return formula based on limited information entered by the R2T4 processor. To ensure the correct information is entered, the University will implement a secondary review of all R2T4 calculations. The primary R2T4 processor will enter all required information in the R2T4 calculation screen within Colleague, and then print the screen for review by a secondary member before the return is referred for processing. The primary processor and secondary reviewer will be required to sign off on the printed calculation sheet, verifying the accuracy of the information. The items that will be included as part of the secondary review will be the date of determination, enrollment status, last date of attendance, and institutional charges. Professional Judgment: The University will implement a Professional Judgment Committee. The committee will consist of at least one Financial Aid Counselor and the Director of Financial Aid. The committee will collectively review all the documentation for each case to make a final determination. Name of the contact person responsible for corrective action: Dustin Kummrow, Director of Financial Aid Planned completion date for corrective action plan: November 1, 2023

Corrective Action Plan (Prepared by the Charter Holder) Finding 2023 – 001 Management has recognized the need for additional personnel to assist in ensuring compliance and accuracy with various reporting and compliance requirements. In September 2023, the Charter Holder posted a grant manager position to support the Chief Financial Officer with state and federal reporting, budgeting, and grant compliance. While the position is vacant, the Charter Holder’s business manager is reviewing financial and compliance reports for accuracy. Management has reached out to Texas Education Agency about the reporting error and is waiting for further instructions on how to correct the reporting error. Responsible Party: Marian Hamlett, CFO Implementation Date: Immediately

U.S. Department of Education 2023-001 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the University consider any modifications to the GLBA policy and procedures manual and related supporting documentation to ensure compliance with the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of the University winding down operations, and no longer providing educational services, University management will consider any modifications to the GLBA policy and procedures manual and related supporting documentation to ensure compliance with the state criteria. Name(s) of the contact person(s) responsible for corrective action: Rachel Nielsen, Vice President of Finance and Administration Planned completion date for corrective action plan: July 31, 2024

School’s Response – The School concurs with this finding and will include Davis Bacon prevailing wage requirements in all future construction contracts that are being paid by federal funds.

The District will implement controls in its meal claim process to ensure that student meals claimed for reimbursement equal student meals served. The Food Service Supervisor and/or Food Service Administrative Assistant will create a summary meal count sheet each month totaling the number of student meals seved based on the electronic and manual meal count sheets prior to submitting the meal claim in the Michigan Nutrition Data System (MiND). The monthly meal claim submitted will be filed with the supporting documentation an dsigned by the individual submitting the claim attesting that the meals claimed match the meals counted.

#2023-003 Significant Deficiency in internal controls and noncompliance related to reporting: The District did not have adequate internal controls over meal claiming process and as a result, errors were made and not detected. Recommendation: Personnel need to be assigned to provide a second review of the meal counts. Ideally, software would be used to avoid human error in tallying. Action Taken: Since May of 2023, the Bandon School District has used Mealtime to avoid human error in tallying. The Food Services Director reviews these numbers monthly to ensure accuracy.

The Board of Directors is and will remain involved in the financial affairs of the Cooperative.

Name of Contact Person: Terry Alston, Chief Finance Officer Corrective Action Plan: Management will monitor Program Report Code expenditures on a monthly basis for compliance with the 10% federal requirement. Amendments will be submitted through the BUD system, as necessary, to ensure compliance with the 10% requirement. Proposed Completion Date: Immediately

Department of Education Bucknell University respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review procedures around sending correct information to the NSLDS. In addition, we recommend the University develop a process to help better oversee the submissions completed by the third-party servicer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Bucknell is currently reviewing its existing process of reporting student enrollment data to the NSLDS. The University through its Registrar and Financial Aid Office will update current procedures to include a more thorough verification of third-party servicer submissions to the NSLDS. Name(s) of the contact person(s) responsible for corrective action: Tim Kracker, University Registrar and Erin Wolfe, Director, Financial Aid Planned completion date for corrective action plan: December 2023 If the Department of Education has questions regarding this plan, please call Elizabeth D. Stewart, Associate Vice President, Treasurer & Controller at 570-577-3108.

We concur with the auditor’s finding. We will be completing a full audit of remaining Perkins files to ensure that all necessary documentation is accounted for and properly filed. Contact Person Responsible for Corrective Action: Carol Summervill, VP for Finance Anticipated Completion Date: Corrective action was started in October and will be completed by December.