Corrective Action Plans

FINDING # 2022-003 (REPEAT FINDING OF 2021-003) U.S. Department of Education ? Passed-through the NYS Education Department Special Education Grants to States (IDEA, Part B); CFDA No. 84.027; Project #0032-22-0778; Grant Period ? Fiscal Year Ended June 30, 2022 Special Education Preschool Grants (IDEA Preschool); CFDA No. 84.173; Project #0033-22-0778; Grant Period ? Fiscal Year Ended June 30, 2022 Significant Deficiency Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: According to Uniform Guidance Section 200.430 Compensation - Personal Services, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must comply with the established written accounting policies and practices of the District, and support the distribution of salaries and wages among specific activities or cost objectives while reasonably reflecting the total activity for which the employee is compensated. Condition: Although the District ultimately obtained Payroll Certification Forms from the employees funded through these federal funds, they did not comply with their written procedures regarding the timeliness of obtaining signed Payroll Certification Forms from employees whose salaries were funded through federal funds. Cause: The District did not take timely action to obtain Payroll Certification Forms from employees whose salaries were funded through federal funds. Effect: The salaries for employees who worked on the grant were not properly supported to be in compliance with the District?s written procedures and the Uniform Guidance. Questioned Costs: None. Recommendation: We recommend the District comply with their written policies and procedures to be in compliance with the Uniform Guidance. District?s Response: The District?s response is included in their corrective plan. FINDING #2021-003 According to Uniform Guidance Section 200.430 Compensation ? Personal Services, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must comply with the established written accounting policies and practices of the District, and support the distribution of salaries and wages among specific activities or cost objectives while reasonably reflecting the total activity for which the employee is compensated. The District did not obtain Payroll Certification Forms from the employees funded through these federal funds and thus, they did not comply with their written procedures regarding obtaining signed Payroll Certification Forms from employees whose salaries were funded through federal funds. We recommended the District comply with their written policies and procedures to be in compliance with the Uniform Guidance. STATUS: Not Implemented DISTRICT?S RESPONSE East Ramapo Central School District Office of Funded Programs (OFP) has reviewed and revised their standards for the documentation of Personnel Expenses to ensure payroll certification forms are prepared in a timely and accurate manner. These procedures adhere to the Uniform Guidance Section 200.430. The OFP Accountant, Renee Vaughan, will establish an internal database to record all employees whose salaries are fully or partially supported with Federal funds. Initial records will be based on Budget estimates derived during the FS-10 process. Upon Approval of a Federal Grant, the OFP Accountant will generate from the internal database, (1) a report with a list of employees whose salaries are fully or partially supported with Federal funds and (2) Personnel Activity Report (PAR) forms for each employee. The OFP Accountant will also produce an informational sheet to accompany the PAR forms. This informational sheet will include a statement about the purpose of the PAR, monthly return-by dates, procedures for changes, etc. The same action will be taken when an employee starts or changes position within the Grant period. The OFP Assistant, Donna Tanner, will distribute these materials to the appropriate employees at the beginning of the grant year. When responses are received, the OFP Assistant will review the form for completion. Completed forms will be marked as such on the report list and returned to the OFP Accountant. Incomplete forms will be returned to the employee for completion. The OFP Assistant will continually follow-up with employees regarding forms not returned by the return-by dates established in the information sheet. Non-responsive PAR requests will be brought to the attention of the Superintendent and the Office of Personnel. The OFP will keep physical and or digital record of each signed PAR. The OFP Accountant will track the completion of forms in the internal database, as well as record any changes in the internal database. Any changes to allocations will prompt the creation and distribution of a new PAR form. At the end of each quarter, OFP Accountant will provide a detailed PAR report to the OFP Executive Director, Dr. Daniel Shanahan. This procedure was initiated in November 2022 and continues to be in effect presently.

U.S. Department of Education 2022-003: Student Financial Aid Cluster ? Student Eligibility and Awarding ? Assistance Listing Number: Various Recommendation: We recommend that the College implements a process that will ensure all Title IV funds are awarded at proper amounts. Action taken in response to finding: This student was awarded an incorrect amount because a subsequent ISIR transaction was received but the Pell was not recalculated on the basis of the new information. After this discovery, we have taken the following actions in response: ? We examined our ISIR import process to make sure that our means of communicating locked transactions was functioning correctly. We found that our system for monitoring new transactions was deficient; if a set of conditions were aligned, a new transaction could slip by our notice. Implemented by August 2022. ? We added another layer of review wherein the output of both the messages we receive from our third-party verification partner and our internal reports associated with importing ISIRS are examined on a regular basis. New transactions on students with a current locked transaction are reported to staff members for further review. Implemented by August 2022. ? We wrote an ad hoc report that allows us to identify subsequent ISIR transactions and will run it regularly to reduce the likelihood of this issue occurring again. Implemented by August 2022. Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: The corrective action plan was implemented by August of 2022.

U.S. Department of Education 2022-004: Student Financial Assistance Cluster ? 240 Days Outstanding Check ? Assistance Listing Number: Various Recommendation: We recommend the College to update its procedures and procedures for processing and monitoring refund checks to ensure compliance with the Title IV requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the 2021-22 aid year, the financial aid and fiscal services departments have been working hard together to clean up and streamline the process by which we handle stale-dated ?financial aid checks? (Title-IV funds processed through BankMobile) as well as ?student refund checks? (non-Title IV funds processed through our district office). In our review, we found that three students had Title IV aid incorrectly processed as ?student refund checks? whose initial disbursement date was more than 240 days before the date of discovery. As a result, we reported those checks to the auditors when asked for outstanding Title IV checks. We have taken the following actions in response to this item: ? We have developed a ?Time Out / Reversal? workgroup that includes members of both the financial aid and fiscal services department to ensure that reissuance of checks does not occur automatically (pre-existing, but this workgroup allows us to address this issue). ? We have trained the workgroup members specifically on the importance of the 240 day limit. Implemented by September 2022. ? We continue to improve the communication between the financial aid and fiscal services. department. We currently hold meetings every two weeks to bring up any common issues and solve problems related to the administration. Implemented by September 2022. Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: The corrective action plan was implemented by August of 2022.

U.S. Department of Education 2022-001: Student Financial Assistance Cluster ? NSLDS Enrollment Reporting ? Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the District review its report procedures to ensure that the enrollment and program information is 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: Repeat finding was unavoidable as we were unaware we were out of compliance until we were over half-way through the current year (21-22). Alysa Borelli, Dean of Enrollment Services contacted the National Student Clearinghouse (NSC) for guidance on what was causing our NSDLS errors and since has restructured when Solano is supposed to report to NSC. Solano has not been reporting in the correct part of the month for the NSDLS roster to pick up an accurate enrollment snapshot, which is the root cause of all of the findings under this header. Solano has received updated training for all staff who are responsible for submitting to NSC. Additionally, the staff member that used to submit who was not submitting at the correct time as removed from this task and replaced. Solano will be following the new protocols starting with Spring 2023 semester and does not expect this to be a repeat finding. It was known that 2nd year findings were unavoidable. Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: All training and adjustments to our processes was completed in December 2022.

2022-002 COVID-19 American Rescue Plan Act Local Fiscal Recovery ? Assistance Listing No. 21.027 Recommendation: We recommend that the Town implement a control to ensure an independent review of the financial reports is performed by an individual other than the preparer to verify accuracy and completeness prior to submission to the State of Connecticut Office of Policy and Management. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The audit discovered that inaccurate reporting to the U.S. Department of the Treasury occurred in the financial report for the period September 30, 2021, December 30, 2021 and the reporting periods thereafter. The Grants Manager has been notified of this breakdown in internal control and the inaccuracy of the reports to the U.S. Department of the Treasury due to the timing of running the Munis report of expenditures. Going forward, the Grants Manager will ensure the Munis actuals reflect all transactions for the period and will ensure that all payrolls, fringe benefits and account payable runs have occurred prior to drafting the financial report for review and signature by Finance. Finance will independently run the Munis report of actual expenditures to confirm and validate the draft report to the U.S. Department of the Treasury and will serve as the final approver and signatory prior to submission. Name of the contact persons responsible for corrective action: Melissa McCaw, Director of Finance, and Kim Cummings, Assistant Director of Finance. Planned completion date for corrective action plan: February 1, 2023

Trinity Manor Senior Non-Profit Corporation respectfully submits the following corrective action plan for the year ended December 31, 2022. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: Year ended December 31, 2022 Corporation Contact Person: Shannon Hilbrecht, Accounting Manager at the Management Agent The findings from the December 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding ? Federal Award Findings and Questioned Costs Finding 2022-001: Considered a significant deficiency in internal control over compliance. Recommendation: The Corporation should pay back the $18,000 with a deposit to the replacement reserve account. Action to be Taken: The Corporation concurs with the facts of this finding, has already paid back the $18,000 to the replacement reserve account during 2023, and is implementing procedures to prevent this in the future.

Finding 2022-005 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The Information Technology Department will schedule a call with the ECF consultant, the Financial Management Office, and the Fiscal Control Office by July 15, 2023 to discuss all necessary paperwork that will be submitted to the Financial Management and Fiscal Control Offices 30 days prior to the final submission deadline to ensure that all payment requests can be submitted in the allotted time period, and give the Finance Offices understanding of what the reimbursement amount will be. The ECF consultant will copy the Chief Financial Officer, Finance Director, Grants Manager, and Fiscal Control Director on his/her submission.

Finding 2022-004 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: During the revise Information Technology reclamation process, students with ECF devices that do not return the device will be noted in SIS to not have returned an ECF device. The device will be locked through the Moysle system and can be traceable, and the student?s profile in SIS will indicate that they are eligible to receive a District only device that is retained at each school site if the student/family doesn?t start a payment plan to pay for the device that was not returned.

Finding 2022-003 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The Information Technology Department will revise the Technology Issue and Reclamation Plan to include two reconciliation periods, one after technology issuance in the summer/fall, and the other after technology reclamation in the spring/summer, to ensure that all contracts and documentation accounted for have the correct corresponding contract in the devices profile in the database where the documents are kept.

Corrective Action Plan For the year ended March 31, 2022 U.S. Department of Housing and Urban Development: The Housing Authority of the City of Paterson respectfully submits the following corrective action plan for the year ended March 31, 2022. Auditor: Novogradac and Company, LLP Certified Public Accountants 1144 Hooper Avenue Suite 203 Toms River, New Jersey 08753 The findings from the March 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Financial Statement Findings Reference 2022-001: Criteria: In accordance with N.J.S.A. 46:30B and the Uniform Unclaimed Property Act of the State of New Jersey, all property, including any income or increment derived there from, less any lawful charges, whether located in this state or another state, that is held, issued, owing in the ordinary course of a holder's business and has remained unclaimed by the owner for more than three years after it became payable or distributable is presumed abandoned, and is subject to custody of the state as unclaimed property. Additionally, HUD requires PHA?s to conform to state escheatment laws related to unclaimed tenant utility reimbursements. Condition: The Authority has unclaimed property in stale dated checks that meet that State?s definition. Reference 2022-001 (continued) Context: During our audit, we noted several checks that were either outstanding for greater than a three-year period or determined to be stale dated by management. These checks were made up of housing assistance payments and utility reimbursements, and were recorded as a liability in the Section 8 Housing Choice Vouchers Program. HUD?s regulations require the Authority to follow the State?s escheat laws, which would require the Authority to ultimately consider these checks as unclaimed property, and turn them over to the State Treasurer. Known Questioned Costs: N/A Cause: The Authority did not properly consider state and federal regulations related to unclaimed property. Effect: Due to the stale dated checks being outstanding for greater than a three-year period, they are to be considered unclaimed property in the State of New Jersey. The Authority did not properly identify these outstanding checks as unclaimed property, or follow the proper reporting requirements of the State of New Jersey. Additionally, no stale dated checks were escheated to the State. Recommendation: The Authority should draft and adopt a method of complying with reporting requirements related to unclaimed property in accordance with the State of New Jersey Statutes. Authority Response: The Authority accepts the recommendation of the auditor and has made arrangements to comply with the State of New Jersey Statutes. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor and has made arrangements to comply with the State of New Jersey Statutes. Irma Gorham is responsible to remedy the deficiency by March 31, 2023. Federal Award Findings and Questioned Costs Finding 2022-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: No Significant deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). Finding 2022-002 (continued): Condition: Based upon inspection of the Authority?s files and on discussions with management there were documents that were unavailable for examination at the time of audit. Context: Of a sample size of thirty-six (36) tenant files, the following information was unavailable for examination at the time of audit: ? Verification of income and assets was missing in one (1) file Our sample size is statistically valid. Known Questioned Costs: $11,054 Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered and designed a system of internal controls that reasonably assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: We agree with the Auditor?s observations on the inspection of the tenant files and will implement internal control procedures that will assure tenant file compliance. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor on the inspection of tenant files and has made arrangements to comply with the Section 8 Housing Choice Vouchers Program. Irma Gorham is responsible to remedy the deficiency by March 31, 2023. Schedule of Prior Year Audit Findings Reference 2021-001: Observation: During our audit, we noted several checks that were either outstanding for greater than a three-year period or determined to be stale dated by management. These checks were made up of housing assistance payments and utility reimbursements, and were recorded as a liability in the Section 8 Housing Choice Vouchers Program. HUD?s regulations require the Authority to follow the State?s escheat laws, which would require the Authority to ultimately consider these checks as unclaimed property and turn them over to the State Treasurer. Reference 2021-001 (continued): Status: The finding remains open. See Finding 2022-001 above. Sincerely yours, Irma Gorham Executive Director

U.S Department of Housing and Urban Development 2022-003 Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their process for maintaining 3rd party verification of income, for uploading data to PIC, and for generating HAP amendment letters. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Create a third party verification policy and procedure SOP. Name(s) of the contact person(s) responsible for corrective action: Doryan Campo Planned completion date for corrective action plan: April 2023

U.S Department of Housing and Urban Development 2022-002 Housing Choice Voucher Program ? Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their processes for maintaining documentation for tenant selection from the waiting list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Create a waiting list management SOP. Name(s) of the contact person(s) responsible for corrective action: Aida Nu?ez Planned completion date for corrective action plan: April 2023

COVID-19 Provider Relief Funding Recommendation: We recommend the Hospital design controls to ensure that reporting is completing in accordance with latest HHS guidelines.. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Hospital will ensure that controls are put into place to present lost revenues in accordance with HHS guidelines. Name of the contact person responsible for corrective action: Al White, CFO. Planned completion date for corrective action plan: February 1, 2023

Corrective Action: We will be creating universal tick sheets for the elementary and secondary schools. The internal control will be more manageable when we make this change. The tick sheets will be on separate sheets for breakfast and lunch and there will be a signature line on each sheet in order to identify the employee that ticked during the meal. All Student Nutrition employees will be instructed to use the standardized tick sheet and will be advised not to make any change to the form. Due Date of Completion: December 31, 2022 Responsible Party: Director of Student Nutrition

U.S. Department of Housing and Urban Development 2022-001: Section 8 Housing Assistance Payments Program ? Assistance Listing No. 14.195 Recommendation: Management should review its internal control procedures to ensure proper oversight over the payroll disbursement process surrounding earned time payouts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon realization of the overpayment, Human Resource (HR) and Payroll have developed a new process where the hourly rates are to be verified and validated prior to the processing of an earned time payout. This process is for all employees that remain employed but are no longer eligible to accrue earned time, thus requiring their earned time to be paid out. On the bi-weekly HR changes worksheet, HR will denote what the hourly rate should be upon pay out of the earned time. Payroll will then cross-check the hourly rate and the earned time hours prior to processing payroll. Name(s) of the contact person(s) responsible for corrective action: Jonathan Allia, Vice President of Finance Planned completion date for corrective action plan: August 1, 2022 If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Jonathan Allia, Vice President of Finance at 617-971-5762.

SIGNIFICANT DEFICIENCY ? INTERNAL CONTROL OVER COMPLIANCE U.S. Department of Labor 2022-003 Reporting Recommendation: We recommend that Argentum update its policies and procedures to ensure adequate review and approval over quarterly financial reports. Procedures must also be implemented to maintain documentation supporting such procedures and submit the required report in timely manner. Explanation of disagreement with audit finding: There is no disagreement with audit finding. Action taken in response to finding: Argentum experienced high staff turnover in 2021 through midyear 2022 which impacted the implementation of corrective actions for this finding during the first half of 2022. Argentum established a documented review process for financial reports for the last two quarters in 2022 prepared by the Grants Manager and approved by Staff Accountant. Argentum will develop an internal documented process for review and approval of performance reports separately from ETA WIPS review and approval process. Performance reports will be prepared by the Program Director and approved by VP of Workforce Development. Name of the contact person responsible for corrective action: Janet Andrews Program Director and Ashante Abubakar Vice President Workforce Development Planned completion date for corrective action plan: September 30, 2023

SIGNIFICANT DEFICIENCY ? INTERNAL CONTROL OVER COMPLIANCE U.S. Department of Labor 2022-001 Allowable Costs Recommendation: We recommend that Argentum establish policies and procedures to support a system of internal control that requires the review and approval of employee time spent on a timely basis to ensure charges made to Federal awards for salaries and benefits are accurate, allowable, and properly allocated. Explanation of disagreement with audit finding: There is no disagreement with audit finding. Action taken in response to finding: Argentum experienced high staff turnover in 2021 through midyear 2022 which created challenges in ensuring consistent application of internal controls for employee time review and approvals. Since April 2022, Argentum has implemented corrective actions and a dedicated staff has been ensuring procedures for review and approval of employee time spend on the federal award are followed. Name of the contact person responsible for corrective action: Saara Dillard Grants Manager and Ashante Abubakar Vice President of Workforce Development Planned completion date for corrective action plan: September 30, 2023

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Significant Deficiency - Eligibility Finding 2022-003 Corrective Action Plan: I. Quality Sampling and Accountability a. In December 2022 Sr. Quality & Training Specialists were realigned to provide direct policy support to assigned teams. The assignment of specific Sr. Quality and Training Specialists to work directly with certain teams will enhance the relationship between Q&T, Eligibility staff and their Supervisors, with the goal of improving quality and timeliness of work. This realignment will more easily enable Sr. Quality & Training staff to correct errors identified through the second party review process and share those findings with the worker and their Supervisor for learning and accountability purposes. b. The Quality and Training Unit will complete monthly quality sampling for TANF. Error trends will be shared with the managers and their supervisors, who will work collaboratively with Quality & Training staff to coordinate appropriate strategies to train and coach staff to mitigate errors moving forward. c. Supervisors will review specific quality sampling results with their staff. The supervisor will, when necessary and appropriate, address continued errors using an individual Corrective Action Plan with the worker to include refresher training, additional second party review and/or initiating the formal documentation process. d. Managers will review quality sampling results with supervisors quarterly to follow up on errors addressed, trainings completed and progress with individual Corrective Action Plans II. Process Improvement - A new Quality Assurance team will be created to validate the second party review process across all DSS divisions. This process will involve sampling records that have gone through the second party review process at the divisional level to ensure the review was accurate and that any errors were corrected. This team will also align second party review findings to audit findings to determine if training or process improvement strategies may improve quality. The team should be hired and standard operating procedures drafted by 4th quarter of FY23. Person responsible: Jim Wright, Sr. Social Services Manager Ellese Massey, Social Services Manager Estimated date of completion: June 30, 2023

The Housing Authority's Executive Director will start randomly pulling files to double check the calculations and make sure EIV reports/Income match.

Finding 2022-001- Housing Choice Voucher Tenant Files - Eligibility- Internal Control over Tenant Files - Noncompliance and Significant Deficiency Housing Choice Voucher Program CFDA #14.871 Corrective Action Plan: 1) SCCHA will arrange for a thorough tenant file audit of existing HCVP files to determine whether there is a significant Incident of incorrect income projections and/or tenant rent calculations. The Initial audit will entail 230 HCVP files randomly sampled (approximately 10% of the program.) The file audit process will continue to include more randomly selected files as Indicated by the results of the initial audit. 2) SCCHA will Increase monitoring and review of HCVP files to increase accuracy and ensure compliance with regulatory and statutory requirements related to income projection and rent determinations. 3) Any staff members with rent calculation certifications older than ten years will be required to attend HCVP rent calculation training and pass the corresponding certification exam. Anticipated Completion Date: 1) Within six months; 2) Initiated within 60 days and on-going thereafter; 3) Within twelve months depending on third-party trainer availability Persons Responsible: Larry McLean, Executive Director; Pam Jackson, HCV Program Director; and Shanae Golliday, Program Integrity & Compliance Coordinator

Finding Number: 2022-001 Condition: Payroll was paid to a contractor under prevailing wage provisions, but the required certified payrolls were not received from the contractor. Planned Corrective Action: The Academy will require certified payrolls to be provided for any future payroll paid under construction contracts where federal funds are used to finance the expenditure. Contact person responsible for corrective action: Cynthia Schwark Anticipated Completion Date: 11/15/2022

2022-001 Higher Education Emergency Relief Fund ? CFDA No. 84.425E; 84.425F Recommendation: We recommend that the College implement controls related to cash management that designates a different reviewer and signer of drawdowns that occur within a given year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As a result of audit finding and 2022-001, the College implemented a process that includes formalized review and approval of drawdowns of federal awards. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler Planned completion date for corrective action plan: 6/30/23

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? FEDERAL COMMUNICATIONS COMMISSION ? COVID-19 ? EMERGENCY CONNECTIVITY FUND PROGRAM ? FEDERAL ALN 32.009 2022-001 Internal Control Over Compliance With Special Tests and Provisions Requirements Finding Summary 47 CFR ? 54.1711 requires that Independent School District No. 831 (the District) only seek support for eligible equipment provided to students and school staff who would otherwise lack connected devices sufficient to engage in remote learning. The District did not have sufficient controls in place within its Emergency Connectivity Fund Program to assure compliance with federal special tests and provisions requirements. Corrective Action Plan Actions Planned ? The District will review its procedures relating to special tests and provisions requirements specifically relating to eligible equipment for which the District could seek reimbursement to ensure compliance in the future with any additional federal awards. Official Responsible ? Chrissy Rehnberg-Eide, Director of Business Services. Planned Completion Date ? April 30, 2023. Disagreement With or Explanation of Finding ? The District is in agreement with this finding. Plan to Monitor ? The District?s Director of Business Services will ensure appropriate controls are in place to verify the District?s compliance with federal special tests and provisions requirements.

2022-002 Federal Agency: Department of Education Federal Program: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425F Condition The Purdue Fort Wayne campus did not have adequate controls in place to ensure invoices related to technology services were properly recorded in accordance with GAAP. Views of Responsible Officials and Planned Corrective Actions Contact Person Responsible for Corrective Action: Glen Nakata, Vice Chancellor for Financial and Administrative Affairs Contact Phone Number: 260-481-4199 The University system, including the Purdue Fort Wayne (PFW) Campus, has internal controls and training in place related to non-catalog purchases and the review of Goods Receipt/Invoice Receipt (GRIR) discrepancies. In the case of these two purchase orders, it appears these were isolated instances where established controls were not fully implemented as designed. These processes will be covered in staff meetings on all campuses and Procurement Services will review and update non-catalog order instructions and GRIR report documentation to ensure clear guidance is given. Anticipated Completion: March 2023 Once the Corrective Action Plan is completed, Purdue Internal Audit will conduct a follow-up review to ensure the corrective action plan is fully implemented and being followed consistently.

2022-001 Federal Agency: Department of Education Federal Programs: Federal Supplemental Educational Opportunity Grants (FSEOG), Federal Pell Grant Program, Federal Direct Student Loans Assistance Listing Numbers: 84.007, 84.063, 84.268 Condition Special Tests and Provisions - Return of Title IV Funds The Purdue Fort Wayne campus did not properly design or implement an effective internal control system to ensure compliance with the requirement for timely return of funds related to the Special Tests and Provisions - Return of Title IV Funds. Specifically, there was a lack of timeliness in initiating a return of Title IV funds, causing a return to be issued more than 45 days after the date the University became aware of student's withdrawal date. Views of Responsible Officials and Corrective Action Plan Contact Person Responsible for Corrective Action: Ron Herrell, Director of Financial Aid Contact Phone Number: 260-481-6242 The PFW Office of Financial Aid has an established Return of Title Four Aid (R2T4) policy and underlying control structure in place to ensure compliance with the R2T4 requirements. The PFW Office of Financial Aid will enhance its current R2T4 policy and procedure to include a step-by-step process to completing an R2T4. This will ensure that in the absence of the Assistant Director of Loans (who is currently responsible for R2T4 calculation completion) a succession list determining who is next in line to complete R2T4 calculations will be established to ensure these are completed in the 45-day window. Anticipated Completion Date: December 2022 Once the Corrective Action Plan is completed, Purdue Internal Audit will conduct a follow-up review to ensure the corrective action plan is fully implemented and being followed consistently.