Corrective Action Plans

Corrective Action Plan 2025-003: Student Financial Aid and Accounts Receivable will work in coordination to sync the process of importing files and posting to accounts on the same day. Our new ERP has streamlined reporting to COD and catches and corrects any date discrepancies between the two systems. This finding was directly related to the migration from our old system and the disruption of data flow. Additionally, a review for matching COD disbursement dates will now be included during the monthly reconciliation process moving forward as a second layer of quality control. Anticipated Completion Date: June 30, 2026 Contact Person: Mary Reed, Director of Financial Aid & Advising

Corrective Action Plan 2025-002: This finding is related to the transition to a new Jenzabar One (J1) ERP system. The Jenzabar Financial Aid (JFA) module, while now integrated into the broader J1 suite, remains a stand-alone solution rather than a fully native component. As a result, Ottawa University needed to modify its financial aid refund disbursement processes to ensure accurate and efficient data flow between systems. These adjustments created challenges in achieving the timely distribution of student refunds. The primary issue involved the timely processing of PLUS Loan refunds. Parent IDs for these refunds were extracted from financial aid data in JFA and established as individual vendors in J1. These IDs then needed to be properly linked to the corresponding student before any parent refunds could be issued. To address this, Financial Aid has designated staff to oversee the creation and linking of parent IDs in J1 to ensure timely processing. Additionally, reports have been developed to identify accounts eligible for refunds, helping to ensure compliance with the 14-day requirement. The Accounting Department also encountered challenges related to vendor setup and the ability to process student refunds in batches. To address these issues, we collaborated with the J1 support team and IT to customize the system, ensuring that student refund checks could be processed and formatted in accordance with bank specifications. While we were not initially prepared for these challenges and had to adapt throughout the process, a solution has since been implemented. As a result, check printing has become an efficient and streamlined operation. The Student Accounts Receivable Office, Controller’s Office, Financial Aid, and IT departments are actively collaborating to establish a more structured and efficient process for managing Federal Student Aid. The first step has been to implement a weekly workflow with clearly defined responsibilities and completion timelines as follows: Financial Aid posts all activity at the beginning of the week, followed by Student Accounts generating credit balance refund reports and initiating student refunds. Accounting then completes the process by issuing refunds to students via check or direct deposit. In addition, Student Accounts and IT are working to develop a datespecific report to identify students with current financial aid disbursements who have outstanding credit balances. This detective control report will be reviewed weekly, and refunds will be processed in accordance with the established workflow. The departments are also developing a detailed Accounts Receivable Aging Report to help the Receivables team more effectively identify any students who have a credit balance. This effort is intended to ensure full compliance with the 14-day requirement outlined in the Federal Student Aid Handbook. Anticipated Completion Date: June 30, 2026 Contact Person: Heather Long, Director of Student Accounts

Corrective Action Plan 2025‐001: The Registrar and the IT department are working together to ensure timely and accurate data is being transmitted on a regular schedule to the Clearinghouse as needed. When date determination exceptions occur (e.g., degrees being conferred after initial reporting or withdrawal dates being retroactively determined for administrative purposes), the Registrar’s Office, IT, and Financial Aid will work together to determine the appropriate date adjustments needed to manually update the Clearinghouse with the correct information if needed as quickly as possible. Anticipated Completion Date: June 30, 2026 Contact Person: Julie McAdoo, University Registrar

Finding Numbers: 2025-001 and 2025-002 Program: USDA Rural Rental Housing Loans – ALN 10.415 Title: Noncompliance with Loan Agreement Corrective Action Plan: The Jackson County Development Corporation (JCDC) defaulted on the USDA Rural Development loan in 2017 due to insufficient operating cash flow generated by the Walker Hill Apartments. Since that time, the Housing Authority of Jackson County (JCHA) and JCDC have actively engaged in ongoing communication with USDA Rural Development to resolve the matter. During fiscal year 2025 and continuing into 2026, JCHA has taken the following actions to resolve the default: • In January 2025, JCHA requested an appraisal from USDA Rural Development; however, Rural Development indicated that an appraisal would not be conducted until an offer was received on the property. • JCHA coordinated with a licensed broker and posted the Walker Hill development for sale on April 15, 2025, for the balance owed on the USDA note. • Due to lack of offers, the listing price was reduced to $355,000. • Two residents relocated to public housing units, and the property currently has one remaining resident. • USDA Rural Development also indicated that they would post an additional listing on their portal to assist with marketing the property. • On August 8, 2025, JCHA received a cash offer for the property and forwarded the information to USDA Rural Development for review. • USDA Rural Development ordered an appraisal on August 11, 2025; the appraisal inspection was completed October 3, 2025. • The appraisal resulted in a value of approximately $250,000. USDA Rural Development indicated that a $75,000 offer could not be accepted based on the appraised value. • The property was subsequently listed at $285,000 to solicit additional interest. • As of March 25, 2026, a potential buyer has provided proof of funds and is pursuing financing. Upon receipt of a pre-approval letter, the offer will be formally submitted to USDA Rural Development for approval. It remains the intent of JCHA and JCDC to fully resolve this matter through completion of the USDA foreclosure and disposition process. JCHA will continue to cooperate with USDA Rural Development and provide documentation, property access, and administrative support necessary to facilitate resolution. Upon final disposition of the property, JCHA anticipates dissolving the JCDC entity, thereby eliminating any remaining obligations associated with the loan. Anticipated Completion Date: Resolution is dependent upon USDA Rural Development approval of a sale or completion of foreclosure proceedings. Management anticipates resolution during fiscal year ending June 30, 2026, subject to USDA Rural Development timelines. Responsible Party: Executive Director, Housing Authority of Jackson County JCDC Board of Commissioners Respectfully Submitted,

Planned Corrective Action: The City acknowledges the finding. Based on the recommendation, the City plans to do the following: • Establish separate program/project accounts within the financial system for each WIC grant award to ensure expenditures are recorded and tracked individually by grant period. • Develop and implement written procedures requiring that all expenditures be reviewed and recorded based on the date incurred relative to the grant’s period of performance. • Perform monthly reconciliations of WIC expenditures by grant to verify that costs are accurately recorded and aligned with the appropriate funding period. • Implement period-end cutoff procedures to ensure expenditures near grant end dates are reviewed and properly assigned to the correct grant period. CHD Fiscal will begin implementing the plan by creating the program codes and will meet with WIC to establish roles for the written procedures. Anticipated Completion Date: 06/30/2026 Responsible Contact Person: Mark Menkhaus, Division Manager

Finding 2025-002 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Work-Study Community Service Requirement Not Met and Failure to Report FWS Earnings (significant deficiency): Criteria – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities unless the institution has received an approved waiver from the Department of Education. Per 34 CFR § 675.19(b), institution must maintain fiscal control and accountability over FWS funds and comply with all reporting requirements established by the Secretary. This includes accurately reporting FWS student earnings through required federal systems and maintaining documentation to support reported activity. Condition - Based on documentation provided for the 2024–2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, only $1,057 was identified as wages paid to students employed in community service activities. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from the U.S. Department of Education of not meeting the required 7 percent community service expenditure threshold. Additionally, during review of the institution’s 2024–2025 Federal Work-Study (FWS) activity, it was noted that FWS student earnings were not reported to the Common Origination and Disbursement (COD) System. The institution’s financial aid records and payroll registers indicate that students earned a total of $23,131 in FWS wages during the award year; however, no corresponding COD submissions or COD acknowledgment files were provided for review to demonstrate that these earnings were reported as required. Cause – The infraction appears to have resulted from failure to monitor compliance with the 7 percent FWS community service requirement and inadequate internal controls to ensure timely and accurate reporting of FWS earnings. Effect – The institution did not comply with the statutory community service spending requirement and FWS earnings were not reported through required federal reporting channels, limiting transparency and federal oversight. Questioned Costs - $0 Perspective – The Federal Work-Study Program includes explicit statutory spending and reporting requirements that are considered key compliance controls. In this instance, the institution expended approximately 4 percent of its authorized FWS allocation ($1,057 of $26,649) on community service wages, compared to the required 7 percent, resulting in a 43 percent shortfall from the required threshold. In addition, 100 percent of FWS earnings identified during testing ($23,131) were not reported to the COD System, as no submission or acknowledgment records were available. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen monitoring of community service requirements and establish formal FWS reporting controls and perform periodic internal audits of FWS expenditures and reporting to identify and correct issues prior to year-end and federal reporting deadlines. Management’s Response – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities. Based on documentation provided for the 2024-2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, $1,057 was identified as community service wages. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from ED was requested or approved

Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Finding 2025-001 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs- Pell Grant Disbursement Reported in Incorrect Award Year (significant deficiency): Criteria – Per 34 CFR § 690.61, institutions must ensure that Pell Grant disbursements are made and reported for the correct award year and in accordance with program requirements. Institutions are required to report Pell Grant disbursements in the correct award year and submit all disbursement records by the published COD closeout deadline for the applicable award year Disbursements not reported by the closeout deadline may not be shifted to a subsequent award year to compensate for missed reporting. Condition - For the 2024–2025 award year, testing revealed that one (1) out of ten (10) students selected for testing became eligible for a Federal Pell Grant disbursement of $204 during the 2023–2024 award year. The institution failed to process and report the disbursement in COD prior to the 2023–2024 COD closeout deadline. To compensate, the institution incorrectly posted the $204 disbursement to the student’s account and reported the payment to COD under the subsequent 2024–2025 award year. Cause – The infraction appears to have resulted from failure to monitor and comply with COD Pell Grant closeout deadlines and inadequate controls to ensure disbursements are reported in the correct award year. Effect – Pell Grant disbursement activity was reported inaccurately to the Department of Education. Reporting the disbursement in the incorrect award year compromises the accuracy and integrity of federal Pell reporting. Misreported Pell activity increases the risk of required data corrections and program review findings. Questioned Costs - $204 Perspective – Accurate and timely reporting of Pell Grant disbursements by award year is a key Title IV compliance control, as Pell Grant funding is awarded, monitored, and closed out on an annual basis. In this instance, one (1) out of ten (10) students tested (10%) had a Pell Grant disbursement that was reported in an incorrect award year due to failure to meet the applicable COD closeout deadline. Although the dollar amount involved was limited, the error demonstrates that controls designed to ensure award-year accuracy and timely COD reporting did not operate effectively. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen closeout monitoring procedures, ensure award-year accuracy, and perform periodic internal reviews. Management’s Response – For the 2024–2025 award year, one (1) out of ten (10) students selected for testing became eligible for a Federal Pell Grant disbursement of $204 in the 2023-2024 award year. The institution failed to process the disbursement in COD prior to the 2023-2024 closeout deadline. To compensate, the institution incorrectly posted the $204 disbursement to the student’s account and reported the payment to COD under the subsequent 2024-2025 award year. Per 34 C.F.R. § 690.61 and the U.S. Department of Education’s Common Origination and Disbursement (COD) system requirements, institutions must report Pell Grant disbursements in the correct award year and by the published COD closeout deadline. A. Agree B. Conditions That Caused the Infraction a. Upon further review of the student’s account ledger, the institution identified that a $204 Pell Grant disbursement was incorrectly reflected for the Fall 2024 term. The student did not attend or enroll in Fall 2024; therefore, no Title IV funds should have been associated with that payment period. b. The Pell award was disbursed but was not properly aligned with the student’s actual enrollment timeline. Although the student attended Summer 2024 and Spring 2025, the institution did not submit a Student Bill Letter (SBL) for Spring 2025 because the student was enrolled in only one course. At the time, institutional practice did not require SBL submission for students enrolled less than half time or in a single course. As a result:  The Pell disbursement was not aligned with the correct payment period.  The $204 Pell award was incorrectly reflected as a Fall 2024 disbursement instead of being applied to the appropriate term.  This created a compliance issue related to Title IV disbursement timing and documentation.  Subsequent guidance from FA Solutions clarified that SBLs must be submitted for all enrolled students, regardless of enrollment intensity, to ensure proper alignment of Title IV funds with the correct payment period. C. The School’s Planned Corrective Action Plan (CAP)- The institution will implement the following corrective actions to address and prevent recurrence of this finding: a. Ledger Correction  The Student Accounts Office will revise the student’s ledger to accurately reflect the $204 Pell Grant disbursement as a Summer 2024 credit/refund, the term in which the student had eligible enrollment.  Any misapplied term references will be removed to ensure alignment with Title IV regulations. b. Policy and Procedure Update  Institutional procedures will be updated to require submission of Student Bill Letters (SBLs) for all enrolled students, including those enrolled in a single course or less than half time, when Title IV funds are involved.  This requirement will be documented in both Financial Aid and Student Accounts procedural manuals. c. Staff Training  Financial Aid and Student Accounts staff will receive training on updated SBL submission requirements and Title IV disbursement alignment.  Training will include review of payment period eligibility, enrollment intensity, and documentation standards. d. Cross Departmental Review Process  Financial Aid and Student Accounts will implement a secondary review process prior to Pell disbursement to confirm:  Enrollment for the applicable term  Presence of a submitted SBL  Correct payment period assignment D. Responsible Officials a. Dr. Gina Garlington, Financial Aid Administrator Responsible for Title IV compliance, staff training, SBL submission, and oversight of Pell disbursement procedures. b. CLA, Third Party Servicer and School’s Student Accounts Office Responsible for ledger corrections, and reconciliation of student accounts. E. Expected Timeline for Implementation a. All timelines have been complete F. Monitoring of Corrective Action Plan a. The CAP will be monitored through the following mechanisms:  Monthly reconciliation reviews between Financial Aid and Student Accounts  Random sampling of Pell disbursements to confirm correct payment period alignment.  Annual internal compliance review of SBL submissions and Title IV disbursements.  Documentation of corrective actions retained for audit and program review purposes.  Any discrepancies identified during monitoring will be addressed immediately and documented. G. Status of CAP Prior to This Finding a. This is the first occurrence of this finding for the institution. b. No prior corrective action plan existed addressing this specific issue. View of Responsible Officials- Officials agree with findings

Establish a formal reconciliation process between the general ledger and amounts reported in the FISAP; require documented review and approval of all FISAP data by the Controller or CFO prior to submission; Enhance the year-end closing timeline to ensure all relevant financial data is finalized before FISAP preparation; Develop and maintain written procedures for FISAP prepartion and review to ensure continuity during staffing transitions; Provide cross-training for key personnel involved in federal reporting to mitigate risks associated with turnover

2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 out of 21 contractor and subcontractor certified payrolls tested were not submitted timely. VOAWW recognizes that timely receipt and review of certified payrolls is essential to ensuring compliance with federal wage requirements. To strengthen internal controls and ensure certified payrolls are consistently obtained, reviewed, and retained, VOAWW will implement the following corrective actions: Implementation of Certified Payroll Submission Controls Before the end of FY26, VOAWW will implement internal controls requiring contractors and subcontractors to submit certified payrolls with each pay application. These controls will include: • A requirement that certified payrolls be submitted prior to payment • A standardized checklist for verifying receipt of certified payrolls • Documentation of the review and approval process • Follow up procedures for missing or incomplete payrolls These steps will ensure certified payrolls are consistently obtained and reviewed before payment is released. Training for Staff on Wage Rate Requirements Beginning in FY26, staff responsible for managing HUD funded construction projects will receive training on: • Davis-Bacon and related wage requirements • Certified payroll documentation standards • Review procedures and red flags • Requirements under 29 CFR Part 5 Contractor Communication and Expectations Before the end of FY26, VOAWW will update contractor communication materials to clearly outline certified payroll requirements, including: • Submission timelines • Required documentation • Consequences for noncompliance • Points of contact for questions or clarifications These expectations will be reinforced during project kick off meetings and throughout the contract period. Centralized Tracking of Certified Payrolls By the end of FY26, VOAWW will implement a centralized tracking log for all certified payroll submissions. This log will document: • Receipt dates • Review dates • Reviewer initials • Any follow up actions taken This will ensure a complete audit trail and consistent monitoring of compliance. These corrective actions will strengthen VOAWW’s internal controls over Wage Rate Requirements, ensure timely receipt and review of certified payrolls, and reduce the risk of noncompliance with federal labor standards. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

2025-004 Indirect Cost Rate Application on Federal Invoices We acknowledge BDO’s observation regarding the indirect cost rate applied to federal invoices during the period in which VOAWW transitioned from its approved NICRA rate to the de minimis rate. During this transition, VOAWW applied the NICRA rate of 17.2% while moving to the de minimis rate but did not complete the required true-up to 10% for a three-month period prior to the de minimis rate being increased to 15%. VOAWW has reviewed the circumstances that led to this error and determined that it occurred during an unusual and infrequent set of conditions. Transitions between indirect cost methodologies are rare and increases to the federal de minimis rate are also uncommon. As a result, this specific scenario is unlikely to recur. Nonetheless, VOAWW recognizes the importance of strengthening controls around indirect rate changes to ensure accurate application during any future transitions. To address this finding and strengthen controls over indirect cost rate application, VOAWW will implement the following corrective actions: • Formal Rate Transition Procedures – Before the end of FY26, the Finance Department will develop and document a standardized procedure for transitioning between indirect cost rates, including effective dates, interim rate requirements, required true-ups, and approval checkpoints to ensure accurate application during any future rate changes. • Centralized Indirect Rate Tracking – Before the end of FY26, the Finance Department will maintain a centralized indirect rate schedule that includes approval documentation, effective dates, and any required adjustments. This schedule will be referenced during invoice preparation and review to ensure consistent and accurate rate application across all federal awards. • Contract Kick-Off Meetings and Cross-Department Alignment – Before the end of FY26, Finance, Grants, and Contract Compliance will implement contract kick-off meetings for new awards and significant contract amendments to align on billing requirements, approved indirect cost rates, effective dates, and other critical compliance information and ensure consistent communication across departments. • Documentation of Important Communications – Before the end of FY26, VOAWW will implement guidance for documentation of important communications with funders that have a single audit impact. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

Child Nutrition Cluster, ALN’s 10.553 & 10.555 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Explanation of disagreement with audit finding: Management agrees with the finding. Action taken in response to finding: Newton operated the National School Lunch Program (NSLP) during the Extended School Year (ESY) for the first time during the summer 2024, which created a reporting challenge. Students from across the district's 23 schools attended ESY in seven (7) schools/sites, but their school-year home schools could not be changed in the Student Information System (Aspen). Therefore, student meal counts reported to their home school on the FP9 but had to be reported on the DESE School Report for the ESY school/site they attended. Given the system interface complexities, some counts had to be manually entered, for which two (2) meal counts were incorrectly entered for breakfast versus lunch. Given that the district did not operate the School Breakfast Program (SBP) and did not serve breakfast, these two (2) manual errors were counted as lunch counts when entered for the School Report. The total meal count did match on the FP9 and School Report. For this inconsistency, the correct action should have been to manually update these two counts in the Point of Sale system (Mosaic) so that the two breakfast counts reflected correctly as lunch counts. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: Newton was able to set conditional parameters in Aspen for ESY 2025 so that the student meal counts reported to their ESY school/site versus their home school, so this reporting issue was corrected the following summer.

Credit Balance Recommendation: We recommend the University evaluate its procedures and policies around credit balances to ensure that students are refunded within the fourteen day requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management understands this federal requirement and will ensure that it is met. Name(s) of the contact person(s) responsible for corrective action: Controller Will Gibbons Planned completion date for corrective action plan: June 30, 2026

Direct Loan Reconciliations Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support of performance monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will take action to ensure compliance with this recommendation.. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Deniesha Newby Planned completion date for corrective action plan: June 30, 2026

Common Origination and Disbursement (COD) Reporting Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will ensure that its policies and procedures are reviewed and updated to ensure compliance with this recommendation. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Deniesha Newby Planned completion date for corrective action plan: June 30, 2026

Direct Loan Overaward Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review existing procedures and modify as needed to ensure compliance with this recommendation.. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Deniesha Newby Planned completion date for corrective action plan: June 30, 2026

National Student Loan Database System (NSLDS) Reporting Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review regulations to ensure that staff understands reporting requirements of the NSLDS. Name(s) of the contact person(s) responsible for corrective action: Financial Aid Director Deniesha Newby Planned completion date for corrective action plan: June 30, 2026

Return of Title IV (R2T4) Funds Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will take action to comply with this recommendation. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Deniesha Newby

U.S. Department of Education Maranatha Baptist University (the University) respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 01, 2024 to June 30, 2025 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 Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2025-001 Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063 & 84.268 Recommendation: We recommend that the University maintain documentation of both formal and informal award notifications in their financial aid software to ensure all necessary communications are made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University Financial Aid Office will add a step in the awarding process to verify that award emails are sent and are documented in the system. Name of the contact person responsible for corrective action: Donald Donovan, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2026 *** If the U.S Department of Education has questions regarding this plan, please call Donald Donovan, Chief Financial Officer, at 920-206-2314.

Finding: The change in student status for 2 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) timely when the student withdrew or changed status during the fiscal year. The change in student status for an additional 2 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) accurately when the student graduated during the fiscal year. Explanation for Finding: The Registrar's data collection was not reviewed after submission to National Student Clearinghouse (NSC) by another responsible individual to ascertain the accuracy of graduate, withdrawal and status change dates of students being reported. The College received a response from NSC of no errors, therefore the withdrawn student in question was not reported in a timely manner. Corrective Actions Taken or Planned: The Registrar will run a report on the 15th of the month to verify any students that have exited the institution from the prior two submission periods (last two months) have valid exit dates in the National Student Loan Clearinghouse. The Assistant Registrar will review the work of the Registrar and verify any discrepancies between Coe’s records and those stored in the National Student Clearinghouse for correction. The Registrar will then ensure timely and accurate submission of student records from the Clearinghouse to NSLDS after all the data has been reviewed. When there are staffing changes in the future that impact a person on the staff in the Office of the Registrar who has been responsible for the verification and reporting of valid exit dates in the National Student Loan Clearinghouse, it is the responsibility of the Registrar, unless the Registrar has left, in which case it shall be the responsibility of the Assistant Registrar, to appoint another specific staff member in the Office of the Registrar to take the actions required by the written policy for the verification and reporting of this data. Persons Responsible and Completion Date: Registrar, Assistant Registrar. The actions outlined above has been added to the Withdrawal & Exit Procedure (NSC-NSLDS) as of 10/28/2025

Condition: The subsidiary ledger for loans funded by the Federal award programs maintained by the Department did not agree to the City’s general ledger. Corrective Action Planned: The City is actively evaluating a Loan Servicing software package to replace the current offline subledger and anticipate on implementing it in fiscal year 2027. Going forward, Office of Strategic Planning and Community Development (OSPCD) Finance in conjunction with the Auditing Department will train the OSPCD program director and staff on the agreed standard methodology and criteria for recording and reporting new loans and payments in both the subledger and MUNIS. Loan activity will be reconciled to the general ledger to ensure compliance each fiscal year. The City will continue to research discrepancies for CDBG and HOME, make necessary adjustments and plans on resolving the remaining variances in these two program accounts. Anticipated Completion Date: September of 2026 Contact: Alan Inacio, OSPCD Director of Finance and Administration

Name of Contact Person: Amanda John, Executive Director. Corrective Action: We will implement proper internal control procedures for the Housing Choice Voucher program eligibility requirements. Proposed Completion Date: Immediately.

Program: Housing Voucher Cluster Federal Financial Assistance Listing Number: 14.871 / 14.879 Federal Grantor: U.S. Department of Housing and Urban Development Award No. and Year: Multiple Compliance Requirements: Special Tests and Provisions – HQS Enforcement Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: The 2025 OMB Compliance Supplement requires that for dwellings under Housing Assistance Payment (HAP) contracts that fail a Housing Quality Standards (HQS) inspection, the County must enforce HQS requirements. Specifically, upon notification that a unit has failed HQS, the County must inspect the unit within 15 days to confirm the deficiency and notify the owner if the deficiency is confirmed. Once notified, the owner is required to make the necessary repairs within the prescribed time frame. If the owner does not correct the cited HQS deficiencies within the specified correction period, the County must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. Condition: For one sample selected for testing, the County did not timely enforce HQS requirements. Cause: The cause of the finding was an administrative oversight that resulted in delays in issuing the final inspection notice following a missed inspection appointment. The County’s existing procedures did not adequately ensure timely follow-up and escalation when an inspection resulted in a noshow. Effect: Because the required inspection and notification were not completed timely, the County did not fully comply with the HQS enforcement requirements. This delay increased the risk that housing assistance payments could continue for a unit that did not meet HUD’s minimum housing quality standards, potentially affecting program compliance and participant health and safety. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of sixty (60) out of a total population of 1,029 instances of failed HQS were selected. The condition noted above was identified during our procedures related to special tests and provisions – HQS enforcement. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its HQS enforcement procedures by implementing controls to ensure timely follow-up on failed inspections, including missed appointments. Such controls may include automated tracking of inspection deadlines, supervisory review of no-show appointments, and escalation procedures to ensure owners are notified within required time frames. Management Response and Corrective Action Plan: 1. Person Responsible: Linda Tarzjani, Leasing Manager 2. Corrective action plan: Concur. We will strengthen our HQS enforcement procedures by implementing controls to ensure timely follow-up on failed inspections, including missed appointments. In doing so we will consider automated tracking of inspection deadlines, supervisory review of noshow appointments, and escalation procedures to ensure owners are notified within required time frames. 3. Anticipated Implementation date: February 1, 2026

Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Financial Assistance Listing Number: 93.566 Federal Grantor: U.S. Department of Health and Human Services Pass Through: California Department of Social Services Award No. and Year: Various Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 45 CFR Part 400, prescribes the eligibility conditions refugees must meet to receive RCA including the following: • RCA recipients must meet the general eligibility requirements for immigration status and refugee identification in accordance with 45 CFR §400.40 - §400.44. • RCA is limited to refugees who are ineligible for TANF, SSI, OAA, AB, APTD, and AABD in accordance with 45 CFR §400.53. • Mandatory work registrants must comply with work requirements and may not voluntarily quit or refuse suitable employment within 30 days prior to application; benefits must be terminated when requirements are not met (45 CFR §§400.75(a), 400.77, and 400.82(a)). • RCA payments may not exceed ORR-authorized rates and may not be less than the State TANF payment rate (45 CFR §§400.60(b) and 400.60(d); ORR PL 22-01). Condition: During our testing of the Social Services Agency’s (SSA) compliance with eligibility and allowable cost/cost principles, we noted the following: • One (1) instance of payment issued to a participant who did not meet eligible immigration status requirements. • One (1) instance of payment issued to a participant who was eligible for another federally funded cash assistance program. • One (1) instance of payment issued to a participant who failed to meet the mandatory work registrant requirements within the required time frame. • One (1) instance of payment issued to a participant using an incorrect benefit rate. Cause: Controls over eligibility determination and benefit rate calculation were not consistently applied, including insufficient verification and supervisory review of eligibility criteria and payment amounts. Effect: Program funds were expended for ineligible participants and an incorrect benefit rate was used, increasing the risk of noncompliance with federal requirements. Questioned Costs: Questioned costs for cases tested in which we determined to be ineligible to receive cash assistance was $1,814. Context/Sampling: A nonstatistical sample of sixty (60) out of all active program participants were sampled. For ineligible cases, we have projected questioned costs against the remaining population for a total of $24,276. The underpayment related to an incorrect benefit rate used was not projected as questioned costs as this did not result in an over-expenditure of federal funds The condition above was identified during our procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles testing. Repeat Finding from Prior Years: Yes. Recommendation: We recommend that the SSA department strengthen its internal controls to ensure that program eligibility criteria and benefit determinations are properly supported. Management Response and Corrective Action Plan: 1. Person Responsible: Rosa Palacios, Human Services Manager 2. Corrective action plan: Staff Guidance and Eligibility Reminder: Program will issue a reminder to all eligibility staff reinforcing program eligibility requirements and the importance of thoroughly reviewing documentation when making eligibility determinations. The reminder will highlight key areas identified in the audit findings, including verification of immigration eligibility, identifying applicants who may qualify for other federally funded cash assistance programs, and ensuring accurate benefit determinations. Work Requirement Reporting Coordination: Program will also communicate with the contracted provider responsible for monitoring work participation requirements to reinforce expectations regarding timely reporting of participant non-compliance. Internal staff will be reminded to take timely action once non-compliance is reported to ensure benefits are discontinued in accordance with program requirements. System Correction: The incorrect benefit rate identified during the audit was related to a prior system configuration issue that required manual processing. The system has since been updated. Program staff will continue to monitor system updates and verify benefit calculations as needed. 3. Anticipated Implementation date: June 30, 2026

CORRECTIVE ACTION PLAN U.S. Department of Education | Arizona Department of Education Tuba City Unified School District No. 15 respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024 – June 30, 2025 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. FINANCIAL STATEMENT FINDINGS 2025-001 INFORMATION TECHNOLOGY Type of Finding: Material Weakness in Internal Control Over Financial Reporting Condition/Context: The District did not establish internal control procedures over information technology systems to ensure proper protection of District and student data. The following control deficiencies were noted regarding the District’s information technology policies and procedures: • The District did not limit access within the District’s accounting software to only those areas in each employee’s job function. Several employees had full administrative access to the accounting software, including third-party consultants, without compensating manual controls. • The District did not have a formal written policy regarding system or software changes. • Data-sharing agreements with third party provides that had access to the District’s data were not provided. • Documentation was not provided to support that the IT systems generated electronic audit trail reports or change logs were being reviewed or analyzed. This would include systemgenerated incident or error reports. • Disaster recovery and contingency plans were not provided. Recommendation: To strengthen internal controls, the District should evaluate its procedures regarding information technology security. The District should review and establish IT policies and procedures to protect the District’s data, train employees, establish backup plans, disaster recover or contingency plans, and 3rd party security and data confidentiality agreements. System general irregularity reports, including incident or error reports should be reviewed on an ongoing basis. Corrective Action: The District will evaluate its procedures regarding information technology security. The District will review and establish IT policies and procedures to protect the District’s data, disaster recovery or contingency plans, and 3rd party security and data confidentiality agreements. Additionally, the District will review system generated irregularity reports, including incident or error reports on an ongoing basis. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Leah Begay, Business Manager

Eligibility - Direct Loan Awarding Federal Direct Student Loans (84.268) Recommendation: We recommend that the University enhance its policies and procedures related to the packaging and awarding of financial aid, particularly in situations requiring manual calculations or professional judgment, to ensure student eligibility is accurately determined and awards are properly calculated. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, we've added a required review step for any aid package that is adjusted using professional judgment. This review focuses specifically on confirming that annual loan limits and subsidized eligibility are recalculated correctly after any change. Staff has also received refresher training on subsidized loan eligibility and amounts, and how to verify that the correct amount is awarded when appropriate. In addition, we will incorporate periodic spot checks of files involving manual adjustments to ensure calculations are accurate and consistent. Name(s) of the contact person(s) responsible for corrective action: Erica Riggs Planned completion date for corrective action plan: Spring 2026, ongoing.