Corrective Action Plans

Allowable Costs The District understands the need to properly document internal control procedures for allowable costs in accordance with Uniform Guidance and State Single Audit Guidelines. In the future, the District will retain their documentation to support their allowable cost approval for federal and state grants.

Segregation of Duties ? State Grant Reporting Recommendation: We recommend that the County review its internal controls and designate an individual other than the preparer to review and approve any grant claims. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Department head will review all staff prepared grant payment requests for accuracy prior to submission. If the grant payment request is prepared by the department head, the Finance Director will review prior to submission. Name of the contact person responsible for corrective action: Darcy Smith, Finance Director. Planned completion date for corrective action plan: The secondary review of grant payment requests will be completed by December 31, 2022.

Preparation of Annual Financial Report Recommendation: We recommend the County continue reviewing the annual financial report. Such review procedures should be performed by an individual possessing a thorough understanding of accounting principles generally accepted in the United States of America and knowledge of the County?s activities and operations. While it may not be cost beneficial to train additional staff to completely prepare the report, a thorough review of this information by the finance director is necessary to ensure the basic financial statements and all accompanying information is accurate and complete. Action planned/taken in response to finding: The County?s finance director will assist the County?s auditors in their preparation of the annual finance report and required disclosures. The finance director will thoroughly review this report and disclosures when issued. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Name of the contact person responsible for corrective action: Darcy Smith, Finance Director. Planned completion date for corrective action plan: The assistance with the preparation and review of the financial statements will be completed by December 31, 2021.

Finding Number: 2022-004 Condition: Participant files selected for testing did not include complete information to support participant eligibility Planned Corrective Action: While the Detroit Housing Commission works towards implementing Rent Cafe, an electronic platform to allow applicants, residents, and Management the ability to streamline the continued occupancy and eligibility process, DHC will continue to utilize the manual application process with the following controls in place: 1. There will be ongoing training to support staff in Public Housing Rent Calculation. Within the designated training, Housing Specialists, Property Managers, Assistant Property Managers and Compliance Specialists will focus on correctly calculating subsidy for applicants and residents. Trainings will include but are not limited to properly identifying and verifying income, expenses, allowances, adjusted income, total tenant payment (TTP), utility standards, PHA payment and subsidy standards. 2. Regional Managers will conduct the first line of quality control file reviews. Upon Housing Specialist, Property Manager and Assistant Property Manager's completing Initial Eligibility, Annual and Interim recertifications, Regional Managers will review the proposed certification against the certification's checklist for approval. 3. The Compliance Department will conduct ongoing Quality Control File Reviews on a 10% sample selection of households to ensure timely completion and accuracy of ongoing participant rent determination. a. When deficiencies are identified during a Quality Control review, site staff will have 7 days to cure and upload the corrective file to SharePoint. b. The final quality control review will also include reconciliation for acceptance of the electronic file to PIC. 4 . To address the incorrect utility allowance amounts being utilized to calculate tenant rent, the following will occur: a. DHC's REM Department will work with DHC's IT Department of update the Utility Allowance tables in the housing's Yardi Software. Current utility allowances will be entered in the software's utility allowance table and will prepopulate based on the action type and effective date of the recertification. b. Site staff will include the printed utility allowance chart within the certification with the allowance amount provided clearly identified for review by the Regional Manager when conducting the first line of quality control file review. Contact person responsible for corrective action: Scharre Leslie, Operations Analyst & Compliance Manager Anticipated Completion Date: 6/30/2023

RE: Lutheran Social Services of Central Ohio Hamilton Housing, Inc. Corrective Action Plan Fiscal Year Ended June 30, 2022 Finding Number: 2022-001 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management deposited the surplus cash amount of $478 into residual receipts on September 23, 2022.

RE: Lutheran Social Services of Central Ohio Groveport Housing, Inc. Corrective Action Plan Fiscal Year Ended June 30, 2022 Finding Number: 2022-001 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management deposited the surplus cash amount of $10,953 into residual receipts on September 23, 2022.

Finding Number: 2022-002 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management deposited the surplus cash amount of $28,666 into residual receipts on September 23, 2022.

Finding 2022-002: Loan Continuing Compliance Requirements Noncompliance/Significant Deficiency Responsible: Jessica Flores, Economic Development and Housing Manager Management Response and Corrective Action The City began a implementation of a monitoring process for existing first-time homebuyer outstanding loans, and is continues working on a process to review all loans. The City will complete implementation of a monitoring process in the following fiscal year. Proposed Completion Date: June 30, 2023

2022-003 Higher Education Emergency Relief Funds -Assistance Listing No. 84.425 Recommendation: We recommend the College review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: Union College will ensure that all HEERF reports are reviewed by the VP for Financial Administration prior to submission. We will also ensure proper supporting documentation is retained and the necessary steps are followed as required. Name(s) of the contact person(s) responsible for corrective action: Brandie Kolff van Oosterwyk, Controller. Planned completion date for corrective action plan: The goal date for this project to be completed is prior to the FY23 audit.

2022-004 Perkins Promissory Notes - Assistance Listing No. 84.038 Recommendation: We recommend that the College put a procedure in place to ensure that all students have a promissory note prior to disbursing of funds. Also recommend a procedure be put in place to ensure proper record retention documenting the completion of promissory note. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: The process Union College follows to ensure promissory notes are signed is coordinated through Student Financial Services (SFS). SFS determines eligibility of awards and adds them to the student financial package. Once a loan has been accepted SFS has the student sign the promissory note. The loan is disbursed once the paperwork has been completed and reviewed. Perkins loans followed this procedure in the time they were available. The Perkins program is no longer active so there are no new promissory notes going forward. Student accounts is currently reviewing student files to ensure promissory notes or documentation deemed appropriate by the Department of Education is available for the Perkins loans that will be assigned to the Department of Education. The assignment process will be completed by June 30, 2023. The remaining loan files will then be reviewed. Promissory notes or documentation will be retained until the loans are either assigned or liquidated. This review will be completed in FY24. Name(s) of the contact person(s) responsible for corrective action: Brandie Kolff van Oosterwyk, Controller Planned completion date for corrective action plan: FY24.

2022-002 Gramm-Leach-Bliley Act - CFDA No. Various Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: Union College is developing a strategy to comply with the requirements of the Gramm-Leach-Bliley Act. Part of this process involves the consideration of contracting with a consultant to assist with the various aspects of implementing the policies and procedures necessitated by the legislation. We are actively in conversations with CLA regarding this project and are working towards having a substantive plan in place and operational for FY24. Name(s) of the contact person(s) responsible for corrective action: Brandie Kolff van Oosterwyk, Controller Planned completion date for corrective action plan: The goal date for this project to be completed is prior to the FY24 audit.

Management agrees with the recommendation that drawdown requests be reconciled to the general ledger and will implement this in the current fiscal year.

2022-003 Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, & 10.559 Recommendation: We recommend the District update policies related to school nutrition reporting to ensure they have appropriate reviews that would prevent or detect errors or fraud. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The School Nutrition Supervisor and Supervisor of Finance approve all expense transactions on an ongoing basis. By the third week of each month, a designated Accounting Assistant runs financial reports used to prepare the monthly school nutrition program claims. The Budget Manager has not approved the claims prior to submission, which has been the practice for all other District programs. Effective July 1, 2022, the accounting assistant schedules a meeting with the School Nutrition Supervisor to review each monthly claim, clarify questions and adjust if needed, prior to submitting a claim to DPI. Name(s) of the contact person(s) responsible for corrective action: Davita Jo Molling, Supervisor of Finance Planned completion date for corrective action plan: July 1, 2022

Finding Number: 2022-005 Condition: The University did not make available timely student HEERF quarterly reporting for the quarter ended September 30, 2021. Planned Corrective Action: Create a review process to ensure correct and timely reporting documents are posted in accordance with federal regulations. Contact person responsible for corrective action: Mark Schroeder, Holly Oswalt Anticipated Completion Date: December 20th, 2022

Finding Number: 2022-004 Condition: Certain credit balances were not refunded to students within 14 days. Planned Corrective Action: Identify one or more additional staff members who can perform this function in the event of illness or absence, cross-train these individuals, and ensure permissions are granted, ensuring appropriate segregation of duties. Contact person responsible for corrective action: Matt Beattie, Mark Schroeder Anticipated Completion Date: February 28, 2023

Finding Number: 2022-003 Condition: The University could not provide records to substantiate that the relevant criteria was complied with by the University in all cases. Planned Corrective Action: Train faculty to preserve and provide documentation related to reported last dates of attendance. This will be stored in the university?s enterprise document management system. Contact person responsible for corrective action: Dina DuBuis, Ann Elinski Anticipated Completion Date: February 15, 2023

Finding Number: 2022-004 Condition: Of the 40 students tested for NSLDS Enrollment Reporting, the University: -For 3 students, reported the status change with incorrect effective dates -For 2 students, reported the status change to NSLDS in an untimely manner Planned corrective Action: The new person hired as the Assistant Registrar for Special Programs and Compliance was officially hired on January 11, 2022. She has gone through training for both NSC and NSLDS. She is and will continue to work closely with Financial Aid related to status change dates and reporting data to the NSLDS. She is responsible for dealing with NSLDS error reports. Contact person responsible for corrective action: Noreen Ferguson, University Registrar Anticipated Completion Date: June 30, 2022. The responsibilities of this position are completed. There will be ongoing training as training sessions become available either through NSC or NSLDS.

2022-002 Significant Deficiency in Internal Controls over Compliance and Compliance - Reporting Agency: U.S. Department of Education Program(s) and Federal Award Identification Number(s): Impact Aid ALN 84.041 FAIN: S041B220137 Contact Person: Ralph Watkins, Superintendent Corrective Action Plan: Documentation issues for Impact Aid application will be resolved in a timely manner. The FY 22 issues have been addressed Completion Date: June 30, 2023

Management?s response: Management agrees with the finding. In January of each year the Fiscal Director, Jerod Nunn, will meet with the grant manager and review the Office of Management and Budget?s compliance supplement. Any changes and/or updates will be noted in the Federal grant files and will be properly followed so the district is in compliance with the Davis-Bacon and Related Acts and Reorganization Plan Regulations.

Finding Number: 2022-001 Condition: Controls in place did not identify an inaccurate calculation of assistance. Planned Corrective Action: The corrective action plan in response to Finding 2021-001 was implemented on September 22, 2022; and therefore the fiscal year ended June 30, 2022 was complete before implementation of the corrective action plan, which is as follows: Case Managers, Quality Review and Agency Managers can see supporting documentation and review cases in real time. All cases are processed by Case Managers, who consult with Agency Managers on questions, and 100 percent of cases are quality reviewed by a team from CLA (an outsourced professional services firm specializing in grants management) prior to processing payment. As Heart of West Michigan United Way receives MSHDA written guidance updates, we continue to hold twice-weekly meetings with CERA Agency Managers to discuss the frequent changes to the MSHDA guidance in order to gain a full understanding of the program requirements and regulations. Information is then disseminated to Case Managers. We will continue to hold regular trainings for CERA Case Managers to ensure consistency in approach and understanding of required documentation and proper assistance calculation. CLA continues to conduct a quality review check of 100 percent of applications to enhance internal controls and oversight. Additionally, the CERA Program Manager completes random checks of assistance calculations and payments. Contact person responsible for corrective action: Gail Montgomery, Vice President of Finance Anticipated Completion Date: September 23, 2022

2022-007 Special Education Cluster (IDEA) and COVID-19 Education Stabilization Fund Recommendation: The School Corporation should implement procedures and controls to ensure all disbursements have proper support and proper approval documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The school corporation will strengthen controls to ensure all federal grant expenditures have documentation of review and approval by a person knowledgeable of the grant requirements. Name of the contact person responsible for corrective action: Cheryl Harvey, Business Manager Planned completion date for corrective action plan: Begin immediately

2022-003 Child Nutrition Cluster Recommendation: School Corporation management should establish a system of internal controls to ensure compliance with the grant agreement and program income requirements. Documentation should be retained to support the existence and accuracy of all program income earned. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The school corporation with review existing control processes surrounding program income and strengthen procedures to ensure documentation to support program income is adequate and reviewed. Name of the contact person responsible for corrective action: Cheryl Harvey, Business Manager Planned completion date for corrective action plan: Begin immediately

Need Analysis Planned Corrective Action: PowerFAIDS utilizes the ?Year in School? reported by the student on the ISIR to calculate Federal Direct Loan eligibility during packaging. If misreported by the student, advisors did not always catch these errors in their review. Executive Director of Financial Aid will provide in-house training to all advising staff to ensure proper understanding of awarding and implication of not appropriately updating fields used to calculate aid eligibility. WBU has funded a Financial Aid Compliance Specialist position in the Office of Financial Aid. Once filled, this position with be devoted to internal audit and federal/state regulation compliance. Person Responsible for Corrective Action Plan: Christy Miller, Executive Director of Financial Aid Anticipated Date of Completion: November 2022

The University of New Hampshire respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University of New Hampshire (UNH) will work to resolve the reporting finding for fiscal year 2022 reporting. UNH will develop a process to ensure that the information reported is accurate and supporting documentation used to prepare the reports and review and approval of the reports is retained. Name(s) of the contact person(s) responsible for corrective action: Liz Stevens, Director of Student Financial Services (Student Reporting) Susan Zipkin, Director Accounting and Financial Compliance (Institutional Reporting) Planned completion date for corrective action plan: March 31, 2023 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Plymouth State University respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Plymouth State University (PSU) will work to resolve the reporting finding for fiscal year 2022 reporting. PSU will develop a process to ensure that future information is reported timely, and the review and approval of the reports is documented and retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Mary Batch, Director of Finance (Institutional Reporting) Mac Broderick, Director of Student Financial Services (Student Reporting) Planned completion date for corrective action plan: July 31, 2022 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Keene State College respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Keene State College (KSC) will work to resolve the reporting finding for fiscal year 2022 reporting. KSC developed a process to ensure that the information is reporting timely, accurately, and supporting documentation used to prepare the reports and review and approval of the reports is retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Catherine Mullins Planned completion date for corrective action plan: July 1, 2022 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Granite State College respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Granite State College (GSC) will work to resolve the reporting finding for fiscal year 2022 reporting. GSC and the University of New Hampshire (UNH) are in the process of merging as part of a new college within UNH, which resulted in a transition of reporting responsibilities and processes. GSC and UNH will develop a process to ensure that the information reported is accurate and supporting documentation for the review and approval of reports is retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Andrea Nepveu, Acting Director of Financial Aid (Student Reporting) Susan Zipkin, Director, Accounting and Financial Compliance (Institutional Reporting) Planned completion date for corrective action plan: March 31, 2023 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above.

TOFMHS will implement a Preparer of the SF 425 wherein the reports will be ?Prepared? by the Fiscal Officer, and ?Certified? by the Program Director, who will have that role in PMS (Payment Management System).