Corrective Action Plans

Recommendation: Implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024

Recommendation: Implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024

Procurement Federal agency: U.S. Department of Agriculture Federal program title: Child Nutrition Cluster CFDA Number: 10.553, 10.555, and 10.559 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): 1-0882-000 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance and Other Matters CORRECTIVE ACTION PLAN (CAP): Recommendation: It is recommended that the District implement procedures and controls to ensure proper procurement procedures are being followed. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will continue to work on establishing procedures and controls to ensure proper procurement procedures are being followed. Official Responsible for Ensuring CAP: Tina Burkholder, Director of Business Services. Planned Completion Date for CAP: June 30, 2024.

Finding Number 2023-005 — Significant Deficiency in Internal Control/Non-Compliance — Appropriate Expense Period of Covid 19-ESSER II 23b — Credit Recovery Condition: During expense testing of ESSER funds, a journal entry that reclassed the cost of Edmentum, program licenses for Plato courses, had expensed the entire annual license fee. The period for eligible expenditures did not begin until October 1, 2022. This journal entry expensed the full cost of the invoice, $11,914.50, and the district did not prorate the costs to include only those expenses from October 1, 2022 through June 30, 2023. The District did not adhere to the proper period for expenditures. Responsible Person: Carl Seiter, Director of Business Services Implementation Date: December 31, 2023 Corrective Action: Develop a summary of all federal grants. This summary will detail the fiscal year it is associated with but more importantly, it will provide the proper period of eligible expenditures for each federal funding source. This summary may be used and readily available at the time approvals are granted for expenditures. If an expense does not fall within the eligible time period, the expense can be rejected by the approver. This summary will be shared with all administrators and staff. In addition, the process for reclass journal entries will also include a pause to check that each invoice associated with a federal grant, is falling within the proper period of expenditures. Sincerely, Carl Seiter Director of Business Services Shepherd Public Schools

Finding Number 2023-006 — Significant Deficiency in Internal Control — Covid 19-ESSER II 23b-Summer School and ESSER II-98C - Approval Process Condition: During expense testing of ESSER funds, a July 2022 expenditure for $24.95, payable to BMO, and an August 2022 invoice for $10,167, payable to IXL for math software licenses, were not approved by the Director of Business Services. During this time, the Director of Business Services position was vacant. Proper internal control procedures would ensure a proper approval process, for any position that is temporarily vacant. Responsible Person: Carl Seiter, Director of Business Services Implementation Date: December 31, 2023 Corrective Action: Develop an approval process workflow that would temporarily utilize another administrator for approvals in Munis if any key position is vacant. The district has two administrators per building. The administrators will have the other building administrator act as approver for that building in the event an administrative position is vacant. If both principal positions are vacant, an administrator in another building will be integrated into the approval process for the building with no administrator. At Central Office, the next key position for approvals would be Trina Smith, the Accounts Payable/Accounts Receivable Accountant. If this position is vacant, the llRlPayroll Accountant will assume those approval duties. The final step of approval is the Director of Business Services to approve items before the AP/AR position can process any items. These items include invoices, requisitions, purchase orders, payroll related items and journal entries. In the event the Director of Business Services position is vacant, the District Superintendent of Schools will be the final approver. Sincerely, Carl Seiter Director of Business Services Shepherd Public Schools

Department of Education Augustana University respectfully submits the following corrective action plan for the year ended July 31, 2023. Audit period: August 01, 2022 – July 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. 84.007, 84.0033, 84.063, 84.268, 84.379 Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented a secondary compliance check of student withdrawal dates. As the Registrar Assistant is notified of student withdrawals, the ‘Leave Date’ is entered into the Jenzabar/CX system. On a weekly basis, the Assistant Registrar will double check the withdrawal notice with the date in Jenzabar/CX. Performing this double check on a weekly basis should catch any incorrectly entered dates before they are transmitted to NSLDS. If an incorrectly entered date is found, the Assistant Registrar will notify the Director of Financial Aid, who will check NSLDS to further ensure the date has not been incorrectly included in enrollment reporting. Name(s) of the contact person(s) responsible for corrective action: Joni Krueger Planned completion date for corrective action plan: immediately / already implemented If the Department of Education has questions regarding this plan, please call Joni Krueger at 605.274.4121.

Federal Agency Name: U.S. Department of Treasury Program Name and FALN #: FALN # 21.023 COVID-19 Emergency Rental Assistance Program (ERA) Finding Summary: One homebuyer payment was allocated to ERA instead of the Homeownership Assistance Fund (HAF). Homebuyers are not eligible for assistance under ERA. Responsible Individuals: Chas Olson - Executive Director and Bridgette Loesch, SD Cares Housing Assistance Program Manager Corrective Action Plan: We have made the adjustment to the correct program once we were made aware of the issue by the auditors. We will carefully review the program sheets prior to submitting to accounting to ensure they are allocated to the correct program. Anticipated Completion Date: September 30, 2023

Department of Education Carleton College 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—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. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have developed additional validation steps to confirm that the status of every student who has completed their program and graduated is accurately reflected at both the National Student Clearinghouse and at NSLDS. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: 9/30/2023 If the Department of Education has questions regarding this plan, please call Theresa Rodriguez, Registar at 507-222-4290.

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Macomb Community College Single Audit Act Compliance report for the year ended June 30, 2023, and corrective actions to be completed. 2023-001 Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. We noted that one out student of a testing population of two was not reported timely to NSLDS and did not have the correct status change reported. As a result of this condition, the College was exposed to an increased risk that incorrect and untimely information would be reported to NSLDS. Auditor Recommendation. We recommend that the College consistently apply their enrollment reporting procedures to prevent untimely status change reporting in the future. Corrective Action. This situation occurred because the student graduated during a term in which they were not enrolled. This is connected to our upload to the National Student Clearinghouse which did not mark the student as graduated (G Not Applied) in our degree verify file. There is a known defect in our student information system that causes this issue. We are currently working collaboratively with our information technology department to resolve this defect which will ensure that we capture students in this situation in the future. Responsible Person. Registrar/Director of Enrollment Services Anticipated Completion Date. June 30, 2024

United States Department of Education Summit Academy OIC respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 to 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—FINANCIAL STATEMENT AUDIT No findings to report. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2023-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the Organization review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Summit Academy does acknowledge this finding and we have updated our WISP as recommended. Additionally, we have instituted a semiannual, pre-scheduled meeting of the responsible officials to review the most current requirements of the GLBA to assure that the organization WISP is always up to date. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO. Planned completion date for corrective action plan: Fall 2023 If the Department of Education has questions regarding this plan, please call Marc Carrier at 612-278-5282.

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.