Corrective Action Plans

SIGNIFICANT DEFICIENCY 2024-002 Crime Victim Assistance -Assistance Listing No. 16.575 Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2025

Finding 2024-002 Significant Deficiency and Noncompliance - Lack of Required Uniform Guidance Policies and Procedures Condition: The City did not update their federal policies and procedures to be in full compliance with Uniform Guidance. Anticipated Completion Date: September 30, 2025 Corrective Action: The City will implement a new policy document specifically for Uniform Grant Compliance to have one document to ensure compliance.

"Finding 2024-003 – U. S. Department of Education (USDE), TRIO Programs (significant deficiency): Information on the federal programs – Upward Bound, FAL No. 84.047A, June 30, 2024; Student Support Services, FAL No. 84.042A, June 30, 2024 Criteria – Federal regulations regarding program requirements. 34-CFR 645.21 Condition – Non-compliances were noted as more fully described in the context below. Context – The College did not meet the two-thirds requirement for the Upward Bound Program. Per federal regulations, not less than two-thirds of the College's program participants will be lowincome individuals who are potential first-generation college students. Cause – Administrative oversight. Effect – The College’s participation in the Title III and TRIO Programs could be subject to USDE sanctions as applicable. Repeat Finding – Yes. Auditor’s Recommendation – We recommend the College monitor participation for the program to assure all requirements are met. View of Responsible Officials – Prior to the start of the Upward Bound FY2024 (September 1, 2024 - August 31, 2025), there was communication between the Program Director and her USDOE Program Officer regarding the current number of participants being served and the number of low-income & first-generation participants (2/3 requirement) as of August 2024. The Program Director explained that recruitment continues to be a challenge stemming from the Covid-19 pandemic, constant changes/turnover in target school personnel, and low student engagement. The monthly plan to increase participant numbers was shared with and approved by the Program Officer. With this, a Continuation Award was granted on September 5, 2024, without any reduction in funds or stipulations to allow the Program to continue to operate and serve students. Program Staff continue to work hard to increase the number of participants, which directly impacts the 2/3 requirement. Please note that decreased student engagement is a nationwide issue in TRIO.

"Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs Planning (significant deficiency) Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grants Program, FAL No. 84.063, June 30, 2024; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024 Criteria – Federal regulations governing Title IV programs. Condition – Non-compliances were noted, as more fully described in the context below. Questioned Costs – N/A Context – We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs 1) Three (3) out of 25 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). Cause – Oversight by responsible employees. Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions as applicable. Repeat Finding – No Auditor’s Recommendation – We strongly recommend the College refine the processes and procedures for the timely recording of disbursements in the general ledger allowing for more accuracy in financial reporting. View of Responsible Officials – The College has refined processes and procedures to ensure student refunds are processed within 14 days after the credit appears on the student account.

The audit was filed late in 2023 due to an extended vacancy of a key finance position combined with the selection of a new audit firm, which resulted in additional time to prepare for and complete the audit. It is expected that this should not be an issue going forward.

Finding No. 2024-001 Housing Choice Voucher: Tenant Eligibility – Significant Deficiency Contact Person: Patricia Tyus Executive Director/CEO The Authority's Housing Choice Voucher program was not pulling Earned Income Verifications (EIVs) within 90 days of move-in, as required by HUD regulations. Additionally, the Authority was missing one recertification for a tenant during the audit period and was missing criminal background checks for tenants. These issues were all for tenants at Whitemarsh Point Eagle Landing. CORRECTIVE ACTION: EIV compliance The Nelrod Company was solicited to provide a Compliance Monitor Plan for SRHA. They did not completely prepare what was required for; but focused on SEMAP, and they were delayed with the deliveries in the contract. We discontinue the contractual relationship and implemented the following items in 2024. We have completed the following items: 1. SRHA placed a priority on getting the staff EIV access so that all the staff can pull and print the EIVs 2. HCV added additional EIV procedures to the HCV SOPs 3. Worked with Vista Management (PBV) to ensure the EIV are printed and in the files 4. Management staff completed training for the staff on the following dates: Quality Control file training—02/08/2024; Compliance Training on all processes--09/06/2024; Adjustment Payment Training--10/4/2024; File Compliance Procedures—1/17/2025. TARGET DATE: On-going

Finding 2024-002 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Per 34 CFR 685.300(b)(5), the College provided reconciliations for the following programs, however the reconciliations were not correct and therefore the programs were not properly reconciled, monthly or annually. a. Federal Pell Grant Program b. Federal Direct Loan Program c. Federal FSEOG Program d. Federal Work Study Program 2. The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the Federal Pell Grant Program. 3. The College distributed the Annual Security and Fire Report (ASR) on October 10th, 2024. PER 34 CFR 668.41, By October 1 of each year, an institution must distribute the ASR to all enrolled students and current employees as described in § 668.46(b). 4. Per HEA, Section 484B and 34 CFR 668.22, one (1) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement that the college determined the student withdrew. 5. Per HEA, Section 484B & 34 CFR 668.22, three (3) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program post-withdrawal disbursement funds disbursed within the 45-day requirement that the college determined the student withdrew. 6. Per HEA, Section 484B & 34 CFR 668.22, five (5) out of 6 students tested for withdrawals and the return of Title IV funds (R2T4) and the school did not complete the R2T4 calculations correctly. As a result of these inaccuracies, two (2) students were overpaid Pell and Direct Loan (DL) funds in the amount of $612 and one (1) student was underpaid $866 in Pell funds. The following errors occurred: a. Incorrect withdrawal dates were used b. Incorrect dates of determination were used c. Funds that could have been disbursed were incorrectly recorded as funds disbursed The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – Title IV reconciliations were prepared. They have been provided to WPG. The College hired an experienced Director of Financial Aid on February 18, 2025. She will ensure the proper reconciliation and management of all financial aid programs and the accurate and timely submission of program reports. The Director of Campus Security has been advised of the deadline for distribution of the Annual Security and Fire Report (ASR).

Finding No. 2024-002 Department(s): New York City Department of Health and Mental Hygiene Program(s): Assistance Listing Number 93.323, Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Corrective Action(s): DOHMH agrees with the recommendation that “DOHMH enhance their internal controls over the reporting process by ensuring that all financial and special performance reports undergo documented review and approval before submission within the required timeframe.” Anticipated Completion Date: Effective Immediately; 3/25/2025 Person(s) Responsible for Implementation: Yuming Li - Director, yli@health.nyc.gov Anthony Faciane - Assistant Commissioner, afaciane@health.nyc.gov Wai Ting Yu - Assistant Commissioner, wyu4@health.nyc.gov Jennifer Carmona - Senior Director, jcarmona@health.nyc.gov Xiu Mei Mai - Director, xmai@health.nyc.gov James Chan - Director, jchan6@health.nyc.gov Yulia Gudzinskiy - Grants Manager, ygudzinskiy@health.nyc.gov Jenny Tejada - Director, jtejada@health.nyc.gov Inna Dubrovenska - Assistant Director, idubrovenska@health.nyc.gov

Finding No. 2024-007 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): HRA implemented the corrective actions noted in our response to the Fiscal 2023 Single Audit findings. In November of 2023, HRA hired an Executive Director for the Home TBRA program, updated the quality assurance evaluation tool and trained staff on the differences of budgeting the “gross” and “net” income. Note that HRA began closing out the TBRA tenants with renewal lease dates starting on 8/1/2023, as the program fully closed and transitioned to the City Fighting Homelessness and Eviction Prevention Supplement (“CityFHEPS”) by the 6/30/24 HRA- Housing Preservation and Development Memorandum of Understanding expiration date. Although the rental assistance portion of the HOME TBRA program began phasing out, the following corrective actions were implemented as part of the Fiscal 2023 Single Audit recommendation: • Supervisory staff were retrained on case review and instructed to do a thorough and comprehensive review of the budget and documentation received to inform case decisions. There have been on-going team and individual meetings, informational sessions and trainings with staff involved with TBRA to improve performance and outcome. Anticipated Completion Date: Not Applicable. As noted above, the Rental Assistance portion of the program has been taken over by CityFHEPS. Person(s) Responsible for Implementation: Jordan Worrell, HTBRA Executive Director worrellj@hra.nyc.gov (929)-252- 5403

Views of Responsible Officials: The College agrees that it did not submit the data correction nor recalculated awards for one out of the forty of the students sampled. While the College does not believe that this failure rate represents a significant deficiency, we acknowledge the importance of the finding and will take mitigation steps moving forward. The Financial Aid Office brought verifications back in-house for the 23-24 award year after a five-year contract was ended with a third-party agency. To strengthen compliance efforts, our financial aid staff underwent verification training from NASFAA as well as internal training over the past two years. The Financial Aid Office will review existing procedures to identify areas of improvement, specifically, verification corrections within our SIS Colleague system and the FAFSA Partner Portals for the 24-25 and 25-26 award years. Furthermore, efforts are under way to hire additional staff to strengthen the breadth of available resources to meet compliance requirements.

Views of Responsible Officials: The college agrees with this finding with explanation. These occurrences were anomalies related to a rare misalignment of the academic calendar for summer session for the 2023/2024 academic year. The calculation findings for five of the seven students were related to a schedule misalignment for the summer semester. The academic calendar for the 2023/2024 award year had 106 days of enrollment during the summer semester. There was a gap of six days between the Summer 2 and Summer 3 terms skewed the calculations. The College has not identified a similar alignment gap for any previous award year. The Financial Aid Office will actively monitor the development of the academic calendar. Additionally, the Financial Office will review and revise existing procedures to identify areas for improvement to ensure that all withdrawn students who began attendance will have their Return to Title IV calculations accurately completed. The Financial Aid Office has taken steps to retrain relevant financial aid personnel and developed internal checks for accuracy in the calculation process.

Views of Responsible Officials: The College has noted that this finding may not align with the unique nature of our summer session, which has three terms included. There are four non-standard summer terms that do not follow the same reporting structure as the Fall and Spring Terms. The College interprets the 60-day reporting requirement to apply to the standard terms for Fall and Spring only. Historically, the college has reported summer enrollments in August, which has been treated as compliant by the Clearinghouse. However, after further review, the College will adjust its reporting schedule to align with recommendations from this finding. This adjustment will ensure that summer reporting aligns with the 60-day timeframe that is consistent with the Fall and Spring terms.

Name of contact person responsible for corrective action: Marguerite Lane, Associate Vice President Enrollment Management Mlane@molloy.edu 516-323-4014 Corrective action: Molloy University understands the finding and has devised a process to ensure that the correct withdrawal date is recorded National Student Loan Data System (NSLDS) with the 60-day window from the date of determination. In the finding, the withdrawals were reported within the window, but the effective dates reported were incorrect. We identified the issue and made the corrections, but the corrections were made outside the 60-day window. To address this, we will utilize our current practice of relying on error reports to address such errors, but we will run these reports at an increased frequency (bi-weekly) and have an additional staff member review the information. We will keep a file for each student withdrawal to show that our dates align in our system, the National Student Clearinghouse, and NSLDS within the required timeframe. Proposed Completion Date: March 31, 2025

Finding 2024-002 – Significant Deficiency Award No.: 97.036, Disaster Grants-Public Assistance (Presidentially Declared Disasters) Federal Grantor: U.S. Department of Homeland Security, Federal Emergency Management Agency, Passed-through California Governor’s Office of Emergency Services, FEMA-4683-DR-CA Compliance Requirement: Other compliance requirements. Condition: The schedule of Expenditures of Federal Awards (SEFA) was not complete, and expenditures reported on the SEFA were revised during the single audit. Criteria: 2 CFR Part 200, Subpart F (Uniform Guidance) Section 200.502 states, “The auditee should prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee’s financial statements.” Internal controls over the SEFA should be in place ensure accrual basis expenses incurred under the federal program are properly reported as expenses on the SEFA and are properly reported as revenue in the financial statements prior to the start of the single audit. Cause: SEFA was not fully reconciled and finalized until after the single audit began. Effect: The expenses included on the SEFA for program 97.036, Disaster Grants-Public Assistance (Presidentially Declared Disasters), program FEMA-4683-DR-CA, were revised during the single audit and questioned costs in the amount of $131,195 were identified, which could have resulted in the auditor not selecting the correct major program or expenses for testing and could have resulted in the single audit not satisfying the requirements of the Uniform Guidance. Context: The District provided cost estimates to the California Governor’s Office of Emergency Services (CalOES) for the amount of flood damage expenses incurred for FEMA Project 725590 and 710830 that were used by CalOES to reimburse the District. The District did not adequately reconcile the expenses incurred at year-end to expense reports available in the accounting system and did not revise the expense estimates provided to CalOES to the actual amounts incurred during the year, resulting in CalOES overpaying the District and the District using the estimated costs on the SEFA for the single audit. Recommendation: We recommend additional review procedures be implemented to ensure the SEFA is complete and accurate when the single audit begins, which includes reconciling all expenses incurred under each federal award down to the invoice, payroll check and lowest level of other costs claimed, cutting-off each expense at year-end and claiming the reconciled qualifying expenses within 45 days after each quarter end. At year-end, programs should be reviewed for cost adjustments, extensions, and other changes that should be reflected on the SEFA when reconciling expenses for the SEFA. Separate program codes should be used for each grant on the SEFA that summarizes expenses down to the individual invoice level that should be provided to the auditor for the single audit. If overclaimed amounts are identified, the grantor and/or pass-though agency should be contacted to determine whether to return the funds or apply the overclaimed amounts to future claims. Views of Responsible Officials and Planned Corrective Actions: The District will implement a formal reconciliation process to ensure all expenditures incurred under each federal award are accurately recorded before the start of the single audit. A quarterly reconciliation process will be conducted after each quarter-end to review and adjust expenses as necessary. The District will contact FEMA to determine whether the questioned costs may be applied to a future claim or whether the amount needs to be returned to FEMA. Estimated Completion Date of Corrective Action: October 1, 2025

Finding: SECTION III – Federal Awards Findings: 2024-001 Expense Approval Documentation – Significant Deficiency During the audit performed by Carver, Florek and James, CPA’s, there was a finding related to expense approval documentation. A total of 20 transactions related to SAFE’s building construction project were tested and 16 did not contain certain documentation of approval. Cause: During the pre-construction phase, SAFE’s Board of Directors accepted a construction bid from Quality Construction for the purposes of expanding SAFE’s emergency shelter facility. The Board of Directors authorized the total amount of the contract for construction and for architectural services, to include project management. Architectural services and project management were provided by MMW Architects. The Board further authorized Stacey Umhey and Heidi Pederson to approve all invoices related to the project. In their role as project managers, Architects from MMW Architects approved all construction invoices for costs incurred prior to forwarding those invoices to SAFE. Ms. Umhey and Ms. Pederson relied on this approval for costs of the project and considered this approval by the architects to be in compliance with SAFE’s policy. Corrective Action: All future invoices will be approved by the authorized SAFE staff person, even in instances where there is project manager approval. This corrective action will be put in place immediately and will continue into the future.

Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support of performance monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office will complete monthly reconciliations in addition to the reconciliation at the time of draw of federal funds to comply with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Belinda Burke, VP for Finance and Administration, CFO Planned completion date for corrective action plan: April 2025

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Department will evaluate its policies and procedures around reporting to the COD to ensure that student information is reported timely. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: April 2025

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007,84.033 Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained as well as maintained in student files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has added personnel and implemented an electronic document management system. All verification documentation is now scanned and maintained within each student’s electronic file to ensure accuracy, completeness, and audit readiness. Staff continue to receive regular training on verification protocols. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: April 2025

Student Financial Assistance Cluster - Assistance Listing No. No. 84.063 Recommendation: We recommend the University implement a review process to ensure calculations of Pell awards are using the correct information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To reduce calculation errors in Pell Grant awards, the Financial Aid Office has hired additional staff, increased training, and implemented an automated packaging system. This system ensures Pell award amounts are calculated using accurate and verified student information. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: August 2025

Student Financial Assistance Cluster - Assistance Listing No. No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Information Technology Department will ensure its written information security program addresses the required minimum elements outlined in 16 CFR 314.4. Name(s) of the contact person(s) responsible for corrective action: Belinda Burke, VP for Finance and Administration, CFO Planned completion date for corrective action plan: April 2025

Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has hired additional personnel to enhance oversight and processing capacity. Staff will continue to receive training and will review all late and supplemental awards to verify that students meet financial need criteria before Title IV funds are disbursed. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Given the findings related to enrollment reporting, the University will review policies and procedures to ensure information is reported in a timely and accurate manner. The University will review the NSLDS regulations and ensure understanding and compliance of the NSLDS definitions related to required reporting of enrollment changes. The University will verify program lengths for all active programs reported to NSLDS. The Registrar is the responsible party for enrollment reporting via NSC to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Lynda Szymanski, VP for Academic Affairs Planned completion date for corrective action plan: April 2025

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the conclusion of each academic term, the Director of Financial Aid will review enrollment data with the Registrar’s Office to identify students who may require Return of Title IV (R2T4) calculations. Completion of all required R2T4 calculations will be documented and verified by the Director to ensure full compliance with federal guidelines. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: May 2025

2024-018. USU Extension Extra Services Compensation Program Non-Compliance with Uniform Guidance State Agency: Utah State University Research & Development Federal Agency: Various 1) Potential Financial Impact USU retained Huron Higher Education Consulting to conduct a Uniform Guidance compliance review of compensation costs charged to federal sponsors. Huron Consulting routinely works with Carnegie R1 institutions to review research compliance issues. Huron conducted a detailed review of an extensive data set for ESC payments made to USU employees, focusing on employees who had salary charged to federal grants or designated as a grant cost share. This review identified limited instances (1) when salaries directly charged to sponsored projects included extra service compensation in the institutional base salary and (2) when extra service compensation was charged to federal sponsors. Overall, the review found that the vast majority of USU ESC payments (referred to as secondary payments in the internal audit) were not charged to federal sponsored awards. Out of a total population of $5.8 million ESC payments reviewed, the unallowed compensation costs related to ESC is approximately $140,000. USU is in the process of addressing the unallowable compensation costs by removing unallowable charges on open awards and refunding unallowable charges on closed awards. 2) Policies and required documentation for ESC. ESC Policies: USU is reviewing its policies associated with ESC and institutional base salary (IBS) (both currently defined in USU Policy 376: Extra Service Compensation). A working group has been established that includes the Provost’s Office, the President’s Office, the Office of Research and Human Resources to develop updated procedures for requesting ESC. Once in place, a new Extra Service Compensation website will be rolled out that will provide guidance on the policy, acceptable uses of extra-service Compensation, and training materials. In conjunction with the website development, a communication plan to inform stakeholders, especially approving department heads and administrators, will be developed. Institutional Base Salary Policy and Procedures: USU will create and implement an Institutional Base Salary policy that aligns with federal requirements and industry best practices and specifically defines salary components and the associated pay codes that are included and excluded from an employee’s institutional base salary. USU will also update its time and effort certification system with correct institutional base salary mapping. 3) Internal controls for sponsored program compensation USU will implement the following improvements in its internal controls: Revised ESC Form. USU has revised its ESC Form to include documentation / calculation demonstrating payment is commensurate with institutional base salary. Revised ESC Application and Approval Process: USU has already updated the internal ESC review process to include appropriate controls to ensure that all ESC requests are reviewed for Uniform Guidance and USU policy requirements. In this regard, all ESC requests at USU are now reviewed by the Office of Sponsored Programs in the context of all funding sources associated with the applicant (including cost share indexes). This change directly addresses prior routing based on the source of funding which resulted in the Office of Research/Sponsored Programs being bypassed for state-funded ESC requests. Certification language has been inserted at appropriate approval levels to ensure that employees are not receiving ESC related to their primary position/workload. Improved Definitions of Primary Work Statement: USU has initiated a collaborative effort between Human Resources, the Provost’s Office, and the Office of Research to clearly define the primary work assignment for faculty via the role statement or annual work plans to clarify the full workload associated with the IBS. Increased Compliance Monitoring: After-the-fact monthly review of ESC payments is being collaboratively performed between the Office of Research and Provost’s Office. Additionally, USU has reorganized its operations to house post-award research administrators within the Office of Research and added an additional supervisory position to manage post award compliance and management. USU will charge central-post award research administrators with monitoring salary charges to sponsored awards and cost share accounts as a secondary internal control. Research Incentive Programs: The Office of Research will establish permissible conditions and components for research incentive programs and any and all proposed programs will be reviewed and approved by the Office of Research before implementation. 4) Adequate training to university personnel regarding sponsored programs compensation compliance. Uniform Guidance training for faculty and staff: USU is building and incorporating new training modules for those managing federal awards which will include guidance on allowable compensation costs and determining institutional base salary. ESC Training: USU has developed a new required annual training for anyone requesting or approving ESC from all types of funding sources at USU (delivered via USU’s Learn Blue system). This training addresses requirements for ESC and employees’ role and responsibilities for compliance requirements. Additional training regarding time and effort certification will be developed. Pay Code Training: USU will provide additional training and education for departmental and payroll staff responsible for coding and processing salary across the institution. Responsible Person: Lisa M. Berreau Vice President for Research Utah State University 435-797-3509 Anticipated completion date of corrective action plan: Actively in progress and full completion by Jan. 1, 2026.

2024-008. Non-Payroll Expenditures Did Not Receive Adequate Reviews State Agency: University of Utah Research & Development Federal Agency: Department of Health and Human Services The Controller’s Office will work directly with the identified PI’s to provide additional training and understanding of the importance of appropriate and timely approvals. In addition, the Controller will work with the Office of Sponsored Projects and the Financial Reporting & Accounting office to review current training processes, as well as the process for notification and follow up with those AE’s/PI’s who do not meet the standard set forth in policy. Contact Person: Steven Phillips Anticipated Correction Date: 6/30/2025