Corrective Action Plans

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: We are actively addressing this issue while highlighting the Division of Vocational Rehabilitation’s (“DVR’s”) high compliance rate of 98.3 percent. The Vocational Rehabilitation Specialist (“VRS”) and the Vocational Rehabilitation Manager have been thoroughly informed about the correct data entries required for Service E (work experiences while in Service status). It’s essential to note that “competitive integrated employment” must not be selected for Service E status. Instead, staff should choose alternatives such as “internships, whether paid or unpaid,” or “transitional employment” to ensure accurate data recording and prevent the inclusion of data element 350. Additionally, “competitive integrated employment” requires the client to be actively employed in alignment with their employment goal outlined in their Individualized Plan for Employment with a stable employment value date entered in the employment record. To assist our staff in this process, the Aware-System Bulletin will include a clear reminder to verify both the employment status and the stable employment value date for each case. Instructions for using the managed layout edit checker will also be provided, equipping staff with the necessary tools to identify errors and make corrections independently. The VRS will ensure that the Service E or Employed status aligns appropriately with the appropriate employment categories. This corrective action reinforces best practices and significantly improves staff compliance with the accuracy of our data from DVR’s case management system. Completion Date: On going monitoring and training as needed. Responding Official(s): Lea Dias, Vocational Rehabilitation Administrator and R. Pascual-Kestner, Vocational Rehabilitation Assistant Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: In addition to our Electronic Benefit Transfer (“EBT”) Management Evaluations of the Processing Centers, which occur on a rotational basis of once every three years, the EBT Office will go out and visit in-person each Processing Center on Oahu, to do a spot check to ensure the Processing Centers are following the EBT Card Security Procedures on an annual basis. Also, for the Neighbor Island Processing Centers, the EBT Office will do a desk review of the DHS 1494, DHS 1495, and DHS 1050 forms and conduct a Teams Virtual Meeting with the Processing Center’s Supervisor(s) to ensure the EBT Card Security Procedures are being followed. In addition to EBT Management Evaluations, in person spot checks, and desk review with Virtual Team Meetings for Neighbor Island, the EBT Project Manager will make periodic reminder announcements for Processing Centers to adhere to the EBT Card Security Procedures at the monthly Joint Section Meetings to account for changes in staff that maybe new and not familiar with the EBT Card Security Procedures. Completion Date: June 2026 Responding Official(s): Sabrina Young, Benefit, Employment, and Support Services Division Electronic Benefit Transfer Project Manager

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Upon further review of the case, it was determined that the caseworker processed the case in “Manual Eligibility” mode which prevented the Kauhale On Line Eligibility Assistance System (“KOLEA”) from terminating benefits. Another worker removed “Manual Eligibility” mode in January enabling KOLEA to process the case and send a termination notice. The worker should have processed the case and taken the case out of “Manual Eligibility” mode when case processing was complete. Corrective Action Taken or Planned: The “Eligibility Determination” training module will be updated to include additional instructions for Manual Actions in the Kauhale On Line Eligibility Assistance System (“KOLEA”). Workers will be instructed to seek guidance from a supervisor for next steps, before running a case manually. This training will be provided on April 30, 2025, to all supervisors and caseworkers and will include a Participant Guide and a summary of the change. To ensure that the training was effective, a query will be run of all cases that are set to “manual,” including the date in which the case was placed in manual. Med-QUEST Division (“MQD”) will review all identified cases to determine if the case should remain in manual for any legitimate eligibility reason. Completion Date: April 30, 2025 Responding Official(s): Lori Lei Aponte, Med-QUEST Division, Eligibility Branch Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Department has engaged with a vendor to implement our new online provider enrollment system HOKU on August 3, 2020 and started the process to have all providers re register their information in the new online system. Most providers were given a deadline to do this by December 31, 2023 and if missed they would be terminated in 2024. There are a few providers who did not re register by December 31, 2023, and these were primarily providers of exclusive or specific services who refused to enroll into HOKU. Not enrolling these providers will have a disruptive impact to the service delivery experience and greatly increase the costs to the program, by risking the Department having to send additional patients to the mainland to get the specialized medical care needed. The Department will be terminating these remaining providers by December 31, 2025. Additionally, the Department is planning to apply for an 1115 demonstration waiver amendment in 2025, to waive the 42 CFR 455.414 provider enrollment requirements for these few providers with exclusive services. Completion Date: December 31, 2025 Responding Official(s): Marvin Malohi, Med-QUEST Division, Supervising Contracts Specialist

Views of Responding Officials: The Department does not agree with this finding. According to 45 CFR section 205.55, it states, “…the State agency will request through the Income Eligibility and Verification System (“IEVS”)…”. However, the policy does not specify the State agency must “properly use IEVS information to evaluate benefit amounts…” as notated in this finding under “Effect.” Unless IEVS provides the necessary information for the applicable benefit month(s) used to determine a TANF applicant’s or recipient’s (“client”) eligibility, information obtained through IEVS will only validate whether a household received an income source, after the fact, but will not verify the dollar amount. Hard-copy verification is obtained from the client to verify income source and dollar amount, for the applicable benefit months, to determine eligibility in accordance with §17 676-51, Hawaii Administrative Rules. For example, if a client applied for TANF on February 28, 2025, and the department processes the application on March 20, 2025 (current month), verification of the household’s income received in February 2025 and received thus far in March 2025, must be obtained to determine eligibility for the month of application (February 2025) and subsequent months (based on projected income). Data obtained from IEVS are not current; therefore, if the information obtained from IEVS is used to determine eligibility, then we would violate our own administrative policy (i.e., §17 676-51, Hawaii Administrative Rules). For example, wage information through SWICA becomes available on a quarterly basis. The most current SWICA information available would have been for quarter ending December 31, 2024, for an application received on February 28, 2025, that was processed on March 20, 2025. Eligibility determination would have been improperly made if SWICA information from IEVS was applied. Corrective Action Taken or Planned: The department will continue to conduct IEVS check. The information obtained will only be used to validate a source of income reported by the applicant/client IF the information is applicable. Completion Date: On going Responding Official(s): Catherine Scardino, Benefit, Employment, and Support Services Division Temporary Assistance for Needy Families Program Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Temporary Assistance for Needy Families (“TANF”) Program Office will collaborate with the division’s Staff Development Office to develop “refresher” training modules on the Benefit, Employment, and Support Services Division (“BESSD”) Learning Academy. Each training module will focus on a specific topic of concern. To monitor staff’s completion of the training modules and their progress, each module will include a quiz or test at the end that staff will be required to complete and pass (e.g., pass equates to a score of 80% and higher). The TANF Program Office and the Staff Development Office began discussions on February 26, 2025. Completion Date: December 31, 2025 Responding Official(s): Catherine Scardino, Benefit, Employment, and Support Services Division Temporary Assistance for Needy Families Program Administrator

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact that the FSRS.gov system has since been retired and integrated into the SAM.gov system acknowledges the need for reducing duplicate recording in favor of an integrated system. Staff’s understanding of the process was in line with available guidance currently still posted on HUD’s website (https://www.hud.gov/sites/dfiles/CPD/documents/CPD_FSRS_Learning_Session_Final_8.26.21.pdf). The City of San Diego did not receive notification of the FSRS deadline from HUD for Fiscal Year (FY) 2024. With regard to the dates entered in the FSRS.gov system, the agreements’ effective dates cover the entire fiscal year, and the awards were approved by our City Council to be in effect for the full fiscal year. Hence, staff entered the date July 1, 2023. Management accepts that going forward, dates should be entered based on the date the agreements are fully executed. Management agrees to include specific FFATA training and procedures in all CDBG manuals and checklists including procedures for compliance, if and when federal agency communication is late or lacking. Implementation Date: The conditions described above have already been corrected. FFATA training and procedures will be implemented within 30 days. Contact: Michele Marano Assistant Deputy Director, Community Development Economic Development Department City of San Diego Email: mmarano@sandiego.gov Phone: 619.236.6381

Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards Condition: During the audit, Wipfli LLP noted there were certain federal grants received from pass-through entities that were inadvertently excluded from the Schedule of Expenditures of Federal Awards. Management’s Response PINC management acknowledges that some funds were inadvertently excluded from the Schedule of Expenditures of Federal Awards due to a combination of a recent CFO leadership transition and an outdated accounting system. However, these issues were not a result of fraud or misuse of funds, and the discrepancies were quickly addressed without any negative impact on the financial statements or audit timeline. The company is actively working to implement a new accounting system with an improved grants module to prevent similar issues in the future. These proactive steps reflect our commitment to compliance, financial accuracy, and continuous improvement in reporting processes. Contact Person Responsible for Corrective Action: Joshua Pevarnik, VP & CFO Anticipated Completion Date: Ongoing and by 6/30/2025

Finding Reference: 2024-012 - SFA Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has established a formalized procedure, effective immediately, to ensure the accuracy and compliance of the annual Fiscal Operations Report and Application to Participate (FISAP). As part of this process, a FISAP Review Committee will be created to oversee the review of the FISAP and all supporting documentation at least three weeks before the official submission deadline. The FISAP will be prepared by the Executive Director of Student Financial Aid Services and Scholarships, who will also gather and compile all necessary supporting documentation. This completed report, along with all relevant data, will then be submitted to the FISAP Review Committee for thorough examination. The committee will verify the accuracy of all figures and ensure that the supporting documents meet FISAP compliance requirements. Submission of the FISAP will only proceed once the FISAP Review Committee has reached a consensus confirming the accuracy and completeness of the report. This structured review process will help safeguard against errors, enhance compliance, and ensure that JSU meets all federal reporting standards. Estimated Completion Date: September 1, 2025

Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of the program. UMMC will make efforts to ensure that all practices and policies are clearly documented and evaluated periodically. Estimated Completion Date: June 30, 2025

Finding Reference: 2024-003 - SFA COD Reporting (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU reconciles Pell and federal direct student loans to COD monthly. The reconciliation is done timely, and ASU will continue to reconcile and provide evidence of review. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships; Ms. Lakesha Tubbs, Registrar; Adrienne Walls, Bursar Corrective Action Planned: In previous years, Jackson State University has extended the purge and registration dates to better serve a high number of students from underrepresented communities and low-income backgrounds, ensuring that they have the opportunity to complete the enrollment process. However, this practice has led to inaccurate reporting of enrollment dates. Moving forward, Jackson State University will work with new, continuing, and readmit students beginning in April 2025 through the start of the Fall 2025 semester on August 18, 2025, to ensure all enrollment materials are completed before the beginning of each term. As part of this effort, Jackson State University has redesigned its new student orientation process with the goal of ensuring students are completely registered before arriving on campus for the fall semester. Within this new model, a dedicated position has been created for First-Time Freshmen to establish proactive outreach and education regarding costs to students and families. The redesigned orientation process places a strong emphasis on First-Time Freshmen, guaranteeing they receive the necessary guidance and support to successfully transition into college life. Additionally, the university will enforce enrollment deadline dates to prevent inaccurate enrollment data and eliminate errors in disbursement records. In addition to enhancing the student enrollment process, JSU is also taking steps to strengthen financial accountability. Furthermore, Jackson State University’s Financial Aid Office, in coordination with its Business Office, will begin holding regularly scheduled reconciliation meetings at the end of each month. These meetings will ensure that the amounts disbursed on both sides align and that figures from both departments match what has been drawn down and either paid out or returned to the U.S. Department of Education Common Origination and Disbursement (COD). Both departments will also utilize an institutional reconciliation document to add another layer of control and prevent errors. These strategic improvements reflect Jackson State University’s ongoing commitment to compliance, operational efficiency, and student success. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The internal control procedures will initiate a reconciliation of disbursement dates against COD data. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (UMMC) Responsible Official: Davita Weary, Director of Student Financial Aid Corrective Action Planned: Reconciliations will be reviewed with Kelly Dismuke, Director of Finance Operations, on a monthly basis. Estimated Completion Date: March 26, 2025 Finding Reference: 2024-003 - SFA COD Reporting (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: USM reconciles Pell and DL monthly. Copies of reconciliations are saved in a shared drive and can be made available upon request. The reconciliations will be reviewed on a monthly basis by the Financial Aid Assistant Director (Alanna McDonald) and Director (David Williamson), and the Bursar (Barbara Madison) when necessary. Estimated Completion Date: March 17, 2025

Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: The Jackson State University Division of Financial Aid has implemented a comprehensive training initiative to strengthen compliance, improve accuracy, and enhance staff proficiency in federal student aid verification. As of May 7, 2024, ongoing training has commenced for all financial aid staff on the 2024-2025 verification process and required documentation. Additionally, beginning April 4, 2025, the department will launch continuous training on verification procedures and Federal Student Aid compliance to ensure staff remains informed of regulatory updates and best practices. To further enhance accuracy and accountability, the department will collaborate with the Department of Information Technology (IT) to develop internal error reports that proactively identify discrepancies in student records. An internal checklist will also be implemented to ensure that each student selected for verification by the U.S. Department of Education has submitted all required documentation. This checklist must be reviewed and signed off by the Executive Director of Student Financial Aid Services and Scholarships before final processing. As part of the department’s transition to a more automated verification process, JSU will integrate Campus-Logic, powered by Ellucian, to streamline operations and reduce manual errors. Comprehensive training sessions will be conducted to ensure financial aid staff are proficient in using the platform. Additionally, an internal checklist within Campus-Logic will be established to facilitate structured review and compliance tracking. A final verification review will be conducted by the Executive Director of Student Financial Aid Services and Scholarships to uphold accuracy and federal compliance, ultimately mitigating errors and improving audit outcomes. Estimated Completion Date: December 19, 2025 Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The verification process will ensure all student data is accurate and corrected by staff. Estimated Completion Date: September 30, 2025

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver credit balance to students. The contract with the servicer should have been uploaded to the Dept of Ed database. Since the audit finding, the contract has been uploaded. ASU will upload the contract timely going forward. Estimated Completion Date: Effective Immediately Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (MVSU) Responsible Official: Mrs. Brittney Manuel-Carpenter, Account Receivable Supervisor Corrective Action Planned: MVSU acknowledged the findings of reference 2024-06 SFA-Special Test- Using a Servicer to Deliver Title IV Credit Balances. MVSU acknowledges that the servicer contract is uploaded to the Department of Education database and is available for viewing. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: University will contact the Department of Education Cash Management to correct the URL link. While the link was broken on the Cash Management site it was active on the USM Business Services website: https://www.usm.edu/business-services/refunds.php and is continually maintained on their site. Estimated Completion Date: April 1, 2025

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that addresses all 7 required elements of the GLBA regulations: • Review GLBA Requirements: Conduct a thorough review of the Gramm-Leach-Bliley Act (GLBA) regulations to understand the 7 required elements. - Completed • Gap Analysis: A gap analysis has been performed to identify missing elements in the current information security program. - Completed • Program Development: Develop and implement policies and procedures to address the identified gaps. This includes administrative, technical, and physical safeguards. - In Progress • Training: Provide training to staff on the new policies and procedures to ensure compliance and proper implementation. - Planning • vCISO Support: Leverage the expertise of the newly hired virtual Chief Information Security Officer (vCISO) to guide the development and implementation of the information security program. - In Progress 2. Conduct a Comprehensive Risk Assessment to identify and address significant gaps in the risk assessment process: • Risk Assessment Framework: Establish a risk assessment framework that aligns with GLBA requirements. - In Progress • Identify Risks: Identify potential risks to the confidentiality, integrity, and availability of customer information. – In Progress • Evaluate Controls: Assess the effectiveness of existing controls and identify areas for improvement. – In Progress • Mitigation Plan: Develop a risk mitigation plan to address identified vulnerabilities and implement appropriate controls. - Planning • vCISO Support: Utilize the vCISO's expertise to ensure a thorough and effective risk assessment process. – In Progress 3. Monitoring and Continuous Improvement to ensure ongoing compliance and continuous improvement of the information security program: • Regular Audits: Conduct regular audits to ensure compliance with GLBA regulations and the effectiveness of the information security program. – Planning • Feedback Mechanism: Establish a feedback mechanism to gather input from staff and stakeholders on the effectiveness of the program. - Planning • Update Policies: Periodically review and update policies and procedures to address emerging threats and changes in regulations. – In Progress • vCISO Support: Engage the vCISO in monitoring and continuous improvement efforts to maintain high standards of information security. – In Progress 4. Reporting and Accountability to ensure accountability and transparency in the implementation of the corrective action plan: • Assign Responsibility: Assign responsibility for the implementation of the corrective action plan to a dedicated team or individual. - Planning • Progress Reports: Provide regular progress reports to senior management and stakeholders on the implementation of the corrective action plan. - Planning • Documentation: Maintain thorough documentation of all actions taken to address the identified issues. - Planning • vCISO Support: Include the vCISO in reporting and accountability processes to ensure expert oversight and guidance. – In Progress By following this corrective action plan and leveraging the expertise of the vCISO, MVSU can address the deficiencies in its information security program and risk assessment process, ensuring compliance with GLBA regulations and protecting customer information effectively. Estimated Completion Date: November 30, 2025

Finding Reference: 2024-010 - Eligibility (Board Office) Responsible Official: Dr. Casey Prestwood, Associate Commissioner for Academic and Student Affairs Corrective Action Planned: An evaluation form was developed and implemented to be used with each applicant review as a checklist of requirements. In addition, there is a second layer of review of all approved applicants’ eligibility prior to requesting disbursement of funds. An outside CPA firm was contracted in May 2024 to perform the second layer of review of each approved applicant before disbursement, to review all disbursement prior to that date in the current grant cycle, and to provide guidance on internal controls. An additional staff person to assist with grant awarding and programmatic operations was hired in August 2024. Estimated Completion Date: August 2024

Finding Reference: 2024-001 - SEFA Reporting (ASU) Responsible Official: Sabrena Johnson, Director of Grants and Contracts Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $298,151 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, Alcorn State University has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: May 31, 2025 Finding Reference: 2024-001 - SEFA Reporting (DSU) Responsible Official: Jacnita Robinson, Grant Accountant Corrective Action Planned: Delta State University acknowledges the audit finding related to errors in the Schedule of Expenditures of Federal Awards (SEFA) reporting. The federal award in question was not intentionally omitted from the SEFA. At the time of SEFA preparation, Delta State University believed the award would be reported on the Mississippi Department of Finance and Administration’s SEFA, as they were identified as the recipient of the award. The University’s intention was to prevent the duplication of expenditures and avoid double-booking the same federal funds on both SEFAs. To prevent this type of error in the future, Delta State University will review and revise its internal controls and procedures for identifying and classifying federal awards. Additional training will be provided to the staff responsible for award set-up and SEFA reporting to ensure proper classification and communication with state agencies regarding the reporting responsibilities for pass-through and beneficiary awards. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (JSU) Responsible Official: Dr. Almesha Campbell, Vice President for Research and Economic Development Corrective Action Planned: Jackson State University will follow the procedures outlined for preparing the Schedule of Expenditures of Federal Awards. Such procedures include, but are not limited to the following: • Verify the ALN provided on the award documents and cover page and then enter it in Banner during the award set-up process. In addition, review the ALNs for continuation awards. If errors are identified during this process, they will be corrected. • Review previous year’s SEFA report and data support to ensure the report is in the format requested by IHL • Correspond with the Division of Business and Finance to include additional expenditures. Currently, the expenditures to include are 1) Direct Loans, 2) Expenditures with ALN 21.027, and 3) Perkins Loans Expenditures • The Director for Fiscal Reporting and Compliance will complete a subsequent review after the Director for Grants and Contracts prepares the report for submission. Furthermore, the newly created Oversight Committee will review the SEFA before submission to ensure that the Federal Perkins Loan program expenditures are included on the SEFA. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (MUW) Responsible Official: Rachel Sudduth, Assistant Director of University Accounting Corrective Action Planned: University Accounting will review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified, this would also include federal expenditures made through Mississippi Bureau of Buildings. Estimated Completion Date: March 21, 2025 Finding Reference: 2024-001 - SEFA Reporting (MVSU) Responsible Official: Mr. Samuel Melton, Director of Sponsored Programs/Title III Corrective Action Planned: Mississippi Valley State University will ensure that federal awards are correctly coded when preparing the Schedule of Expenditures of Federal Awards using the following procedures: • The Office of Business and Finance and Office of Sponsored Programs will verify the ALN provided on the award documents provided by the sponsor (i.e., federal agency and/or pass-through entity). If errors are identified during this process, they will be corrected. • The Director of Accounting will complete a subsequent review after the designated Staff Accountant prepares the report for submission. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (UM) Responsible Official: Dr. Steven G. Holley, Vice Chancellor for Administration and Finance Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024, was revised to include $131,454 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN 21.027. Additionally, the University of Mississippi has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 30, 2024 Finding Reference: 2024-001 - SEFA Reporting (USM) Responsible Official: Andrea Phillips, Controller Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $597,135 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, USM has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 23, 2024 Finding Reference: 2024-001 - SEFA Reporting (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: UMMC engaged with a Workday certified consulting firm to review the operational effectiveness of the configuration of Workday, review reports available, and assess processes and procedures. As part of the engagement, this firm also evaluated various operational processes within the contract and grants office. The engagement began in June of 2024 and has made significant changes to Workday to bring operational efficiency into our processes and configurations; as well as, developed reports that identify variances and differences that need to be researched and corrected. The team also corrected reports that were pulling data inaccurately and trained internal UMMC IT staff on how to address system corrections going forward and the methodology to develop/modify IT reports. The firm also revamped our award setup process in Workday and built checklists along with Standard Operating Procedures that bring efficiencies and accuracy into our Award setup process. We also built in roles for review of an award at the time of setup to ensure that errors are quickly identified and corrected in the system. Estimated Completion Date: June 30, 2025

The Registrar’s Office will incorporate the recommendations to fix the deficiency to create and deploy a more timely report to identify students who re-enroll at the College. It should be noted that since the College is implementing this change as early as March 2025, there may be a continuation of the deficiency from July 1, 2024 through March 31, 2025.

Occidental College Corrective Action Plan Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Explanation of Deficiency: Occidental sent a degree file to the National Student Clearinghouse (NSC) on June 12, 2024. It was a sent a week after an enrollment file. The enrollment file had errors which required resolution before the NSC could process the degree file. The enrollment file errors were remedied on June 25, 2024. The degree file also had errors posted on June 26, 2024, and corrected by Occidental on July 29, 2024. Correction Action Plan: The staff member currently responsible for resolving National Student Clearinghouse (NSC) file errors has now been trained in the institutional responsibility to send NSC files on time and to resolve any resulting errors immediately. In additional, the College will soon be hiring an administrative position (currently open) in the Registrar’s Office who will act as Occidental’s main liaison with the NSC. Plans for the new liaison training include both NSC processing as well as the relationship between NSC submissions and the institutional responsibility to report accurate enrollment to the National Student Loan Data System (NSLDS) as required. Training will be conducted by the Registrar with the assistance of the Director of Financial Aid for emphasis on institutional responsibilities as outlined in 34 CFR 685.3096(b). Contact Person Responsible for Corrective Action: James Herr, Occidental College Registrar Anticipated Completion Date: December 12, 2024 (end of Fall semester but before next degree file is sent to NSC)

Corrective Action Plan: The Authority concurs with the finding. The following corrective actions are being implemented:  Reinstating and enhancing the inspection tracking log to monitor timely completion of all required inspections;  Utilizing property management software to schedule and track inspections;  Assigning oversight responsibility for inspections to the Property Manager and Safety Inspection Supervisor;  Conducting quarterly management reviews of inspection compliance;  Hired additional inspection sta􀀳, including Maintenance Operations Supervisor to complete any backlog and ensure ongoing compliance.  Requested funding from City, State, and County to assist in inspections compliance to address federal funding and revenue shortages due to rental income delinquency. Anticipated Completion Date: June 30, 2025 Responsible Party: Senior Manager of Housing Operations/Maintenance Manager

Corrective Action Plan: The Authority acknowledges the finding. Corrective actions to address the deficiencies are underway and include:  Updating internal policies and procedures related to tenant file documentation and income verification requirements;  Providing targeted sta􀀳 training on proper file documentation and third-party income verification procedures;  Implementing a mandatory checklist to ensure all required documentation is obtained and verified before finalizing recertifications;  Establishing a quality control process where supervisory sta􀀳 conduct periodic file reviews to ensure compliance;  Maintaining an audit trail of verification documentation to ensure proper retention.  Hired third-party service provider, Quadel to assist with tenant file documentation compliance, annual and interim recertifications and rent calculations.  Hiring Senior Housing Manager to assist with monitoring verification documentation, income calculation, citizenship and/or legal residency documentation, and signed release documentation compliance. Anticipated Completion Date: June 30, 2025 Responsible Party: Senior Manager of Housing Operations and PH Property Managers

2024-001 Special Tests and Provisions Name of Contact Person: Adam Miller, Chief Financial Officer Corrective Action: The JCC was unable to meet certain performance-based provisions of the contract, such as number of participants and break out of those participants by age category. The JCC acknowledges and agrees with the finding, and is in the process of developing procedures to ensure compliance with the grant/contract provisions and will start implementing this recommendation during the year ended June 30, 2025. The procedures: • The JCC will designate the responsibility of contract compliance to a specific individual at the JCC. • The JCC will ensure strict compliance with the IS49 Beacon program’s grant/contract provisions.

Name ofcontactperson: Julie B. Savino, Associate Vice President of Student Financial Assistance Corrective action: The University remains committed to maintaining compliance with federal requirements and ensuring accurate Free Application for Federal Student Aid (FAFSA) verification. Staff will continue to receive verification training through internal and external means to ensure the accuracy ofthe verification requirements. To address the identified issues, the University will strengthen verification policies and procedures by adding controls to prevent data entry errors. As part ofthese improvements, a secondary review process will require a Director level staff member to evaluate any Institutional Student Information Record (ISIR) updates or changes before finalizing the Student Aid Index (SAI) (previously known as Estimated Family Contribution EFC). Proposed completion date: April 15, 2025

RESET is a cost reimbursement grant. The agency maintains an Excel workbook that tracks costs over the course of the 12-month award year. The workbook is updated prior to each month's request for reimbursement. The grant accountant accrued a reimbursable expense for clothing for September, then inexplicably entered a slightly different amount into the workbook. This l ne item was selected for audit, and the agency is unable to provide support for the difference. In addition, in October the grant accountant improperly recorded a payroll cost in the General Ledger and the grant workbook. While the documentation clearly shows how the amount was calculated, it was nor a legitimate period cost. The agency charges expenses to a unique department number in the General Ledger. Costs are assigned in the workbook to one of three categories: reimbursable, ineligible, and pending. The control process calls for the grant accountant to assign each GL expense to a category, then to ensure the workbook ties to the GL for the month and award year-to-date. An initial review indicates the control worked because the cost column for the month consistently matches the GL. A closer review shows that for September, the accountant matched the GL by entering a rounding error. Rounding errors should be limited to a penny or so. The control failed. The lack of accuracy and attention to detail is regrettable. The grant accountant is no longer with the agency. The grant accountant is responsible for the integrity of the workbook. The CFO is responsible for the overall integrity of the financial statements. The CFO and grant accountant meet monthly to review the workbook. The CFO reviews the workbook for reasonableness and completeness. This review includes observing the grant accountant's assertion that the workbook matches the GL. To reduce the risk of future errors, the CFO has 1. Reviewed the monthly process with the new grant accountant, emphasizing the need to match the GL. Status: Complete. 2. Created an agenda template for monthly workbook reviews. This agenda includes confirmation that the workbook matches the GL and identification of any amount of rounding for the month and award year-to-date. Status: Complete. 3. Added a step to the workbook. In addition to the current process of entering GL information to the workbook, the grant accountant will enter date of confirmation and save a copy of the GL that matches the workbook. Status: complete, effective as of January 2025 activity. 4. Added a step to the department's close checklist. The grant accountant explicitly confirms that Step 3 is done. Status: complete, effective as of January 2025 activity.

RESET is a cost reimbursement grant. The agency maintains an Excel workbook that tracks costs over the course of the 12-month award year. The workbook is updated prior to each month's request for reimbursement. The grant accountant accrued a reimbursable expense for clothing for September, then inexplicably entered a slightly different amount into the workbook. This l ne item was selected for audit, and the agency is unable to provide support for the difference. In addition, in October the grant accountant improperly recorded a payroll cost in the General Ledger and the grant workbook. While the documentation clearly shows how the amount was calculated, it was nor a legitimate period cost. The agency charges expenses to a unique department number in the General Ledger. Costs are assigned in the workbook to one of three categories: reimbursable, ineligible, and pending. The control process calls for the grant accountant to assign each GL expense to a category, then to ensure the workbook ties to the GL for the month and award year-to-date. An initial review indicates the control worked because the cost column for the month consistently matches the GL. A closer review shows that for September, the accountant matched the GL by entering a rounding error. Rounding errors should be limited to a penny or so. The control failed. The lack of accuracy and attention to detail is regrettable. The grant accountant is no longer with the agency. The grant accountant is responsible for the integrity of the workbook. The CFO is responsible for the overall integrity of the financial statements. The CFO and grant accountant meet monthly to review the workbook. The CFO reviews the workbook for reasonableness and completeness. This review includes observing the grant accountant's assertion that the workbook matches the GL. To reduce the risk of future errors, the CFO has 1. Reviewed the monthly process with the new grant accountant, emphasizing the need to match the GL. Status: Complete. 2. Created an agenda template for monthly workbook reviews. This agenda includes confirmation that the workbook matches the GL and identification of any amount of rounding for the month and award year-to-date. Status: Complete. 3. Added a step to the workbook. In addition to the current process of entering GL information to the workbook, the grant accountant will enter date of confirmation and save a copy of the GL that matches the workbook. Status: complete, effective as of January 2025 activity. 4. Added a step to the department's close checklist. The grant accountant explicitly confirms that Step 3 is done. Status: complete, effective as of January 2025 activity.

The City acknowledges the finding regarding the untimely completion of Quality Assurance Program (QAP) checklists (Appendices K, E, and L) for federally funded projects. Although the required Quality Assurance Tests were performed, documentation of the checklists was not completed in real time. To correct this, the City has reinforced internal procedures to ensure that these checklists are completed and signed at the appropriate project milestones. Staff have been retrained on QAP requirements, and a tracking system has been implemented to ensure timely completion of all necessary documentation. Responsible Person: Susan Michael, Capital Improvement Programs Manager Expected Implementation Date: March 2025