Corrective Action Plans

Finding 2024-002 Federal Agency Name: U.S. Department of Education Pass-Through Entity: n/a Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Program Name: Student Financial Assistance (SFA) Cluster Finding Summary: In auditor testing of 60 samples, 9 students did not receive a timely notification of their award from the College Corrective Action Plan: The Director of Financial Aid will implement procedures to ensure timely notification of financial aid awards: • In August 2024, the Director collaborated with IT to fix a notification system glitch. • IT added a control that sends an email alert to IT, the Director, and tech support if there is a mismatch between student IDs for loan disbursement and notifications sent. This ensures immediate review and resolution of any missed notifications. Responsible Individual(s): Christopher Natelborg, Director of Financial Aid Anticipated Completion Date: February 2025.

Segregation of Duties – Child Nutrition Cluster Recommendation: We recommend the district designate an individual to review eligibility determinations for accuracy and proper input into software. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: To enhance segregation of duties, we have designated a specific individual (Director of Food Services) responsible for reviewing eligibility determinations. This designated person is tasked with verifying the accuracy of information and ensuring proper input into the relevant software. These measures effectively separate key responsibilities, establishing a robust system of checks and balances. Through these implemented practices, our district aims to minimize errors, enhance accountability, and ensure the integrity of the grant management process. Name of the contact person responsible for correction action: Lavesa Glover-Verhagen Planned completion date for corrective action: June 30, 2025

Finding: 2024-002 Name of Contact Person: Michael Coone, Assistant Social Services Director Criteria: In accordance with 20 CFR 681.590, local youth programs must expend not less than 20 percent of the funds allocated to them, except for the local area expenditures for administration, to provide paid and unpaid work experiences. Recommendation: Require the County Program Directors to implement procedures to ensure that earmarking requirements are met. Corrective Action/Management’s Response: Management concurs with this finding and will adhere to the Corrective Action Plan in this audit report. The County has implemented the following process: Gaston County Workforce Development Board staff worked closely with the previous Youth service provider requesting them to assign 100% of their WEX specialist salary towards work-based learning expenses to obtain this goal. With a new service provider, Two Hawk Employment Services, their financial staff have budgeted 20% of all WEX related activities, salaries, staff costs, participant costs, etc. to meet the 20% goal. Gaston County WDB and Two Hawk Employment Services have adjusted staff day sheet logs to reflect 20% of staff activities to ensure all staff are assigning the work appropriately. The Gaston County Workforce Development Board mandated in the service provider Youth contract to meet the 20% WEX Expenditure and future contract awards are determined on successfully meeting the expenditure requirement. Per the state’s most recent Youth Expenditure Report at the end of October 2024, Gaston County Workforce Development Board is 76% towards meeting the goal. The Workforce Development Board staff and management will continue to monitor monthly that 20% of all salaries and WEX activities are accurately reflected on all invoices and financials from Two Hawk Employment Services. Proposed Completion Date: Management and the Board will implement the above procedures immediately with a completion date of June 30, 2025.

Finding: 2024-001 Name of Contact Person: Michael Coone, Assistant Social Services Director Criteria: In accordance with the Division of Social Services Fiscal Manual, DSS employees should control physical access to the state network terminals or personal computers that are connected to the state mainframe. Recommendation: Require the County Data Processing Department to implement procedures to require logout of workstations where access to the state DSS system is granted. The control procedures should include random verification of logout in instances where offices are unattended. Corrective Action/Management’s Response: Management concurs with this finding and will adhere to the Corrective Action Plan in this audit report. The County has implemented the following process: Awareness has been brought to the staff’s attention by addressing the issue at the DSS all staff meetings. The DSS Business Services staff have been assigned areas to complete monthly random walk-throughs to ensure computers are locked when workers are away from their desks. Any workers found with unattended workstations are being recorded on a spreadsheet and reviewed by upper management. A progressive disciplinary process will follow for anyone found on this list. Proposed Completion Date: Management and the Board will implement the above procedures immediately.

CORRECTIVE ACTION PLAN December 11, 2024 Southwestern Virginia Transit Management Company (SVTMC) respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs (the "Schedule “) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS- FINANCIAL STATEMENT AUDIT 2024-001: Segregation of Duties and Management Oversight (Material Weakness) Condition: Due to staff turnover, duties handled by the Director of Finance included incompatible duties during the year under audit such as: collection of cash, post receipts to general ledger, and prepare bank deposit slips. ln addition, the Inventory Manager has access both to physical inventory and to the inventory tracking system. Criteria: A fundamental concept of internal controls is the separation of duties. No one employee should have access to both physical assets and the related accounting records, or to all phases of a transaction. ln addition, all significant transactions and controls should involve reconciliations and supervisory, or management level, reviews of those processes. An effective and timely review process is intended to prevent and detect both fraud and errors. Cause: Turnover in key positions can result in individuals performing duties that are not appropriately segregated. In addition, turnover can also create challenges in the oversight or review function. Effect: Internal controls are designed to safeguard assets and detect losses from employees dishonesty or error. Recommendation: Steps should be taken to eliminate conflicting duties and implement compensating controls, where possible. Corrective Action: Although turnover in key positions increased the need for staff to undertake incompatible duties, small staff sizes will likely perpetuate the need for the Director of Finance and Inventory Manager to occasionally perform duties which would be ideally segregated. To help alleviate the risks involved, management will develop additional compensating controls around these activities, including working with system vendors to identify activity logging capabilities and additional reports for periodic review by management. 2024-002: Grant Management and Operating Assistance (Material Weakness) Condition: During 2024, various functions related to financial management were not performed timely resulting in difficulties and delays in completion of the annual audit. Additionally, the untimely nature of grant reconciliations and drawdowns has led to significant cash and grant management issues. Criteria: Internal controls related to financial management should be designed to ensure timely reconciliations are performed, including submission of reimbursement requests and reconciling grant and local revenue. Cause: Turnover in financial positions and increased levels of federal and state grant usage caused significant delays in performance of and reduction in effectiveness of certain financial duties. Effect: Untimely drawdowns could result in vendors not being paid timely, result in cash shortages, and inability to pay payroll. Recommendation: We recommend that the Company establish financial management procedures to ensure that timely reconciliations and submissions of reimbursement requests. We would recommend these procedures be performed monthly and include tracking and reconciling grant activity by type (federal, state, and local). Corrective Action: The Interim Director of Finance and Accounting Supervisor are currently reviewing operating procedures and implementing methods to streamline work and eliminate duplicate activity. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. Additionally, detailed spreadsheets tracking grant activity have been developed, which will allow staff members to better monitor reimbursement requests and ensure vendors are paid timely moving forward. 2024-003: Bank Reconciliations (Material Weakness) Condition: Monthly bank reconciliations were not prepared by an accountant and reviewed and approved by a supervisor in a timely manner. Criteria: Monthly bank reconciliations should be performed by the 15th of the next month. Cause: Staff shortage and lack of cash flow management. Effect: Poor cash flow management resulting in vendor and contractor invoices not being paid timely. Recommendation: We recommend bank reconciliations be prepared by an accountant and reviewed by a supervisor to ensure unreconciled or unusual items, or other matters noted in the reconciliation, are detected and addressed in a timely manner. Corrective Action: The Interim Director of Finance and Accounting Supervisor are currently reviewing operating procedures and implementing methods to streamline work and eliminate duplicate activity. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. Currently, the Interim Director of Finance is preparing all company bank reconciliations. 2024-004: Trade Receivables and Revenue- Billing (Material Weakness) Condition: There were multiple customer accounts that were not billed throughout the year as services were provided by the Company. Criteria: Customers should be billed in a timely manner after being provided with services by the Company. Cause: Staff shortage, lack of revenue cycle oversight, and lack of cash flow management. Effect: Poor revenue cycle management, leading to customers not being billed. This leads to cash shortages from operations and a further reliance on grant funding for operations. This could also lead to the Company being unable to collect billed balances, as certain customers were hit with substantial bills when invoices were caught up in June 2024. Recommendation: We recommend billing customers for services rendered in a timely manner to improve cash flow and prevent collection issues. Corrective Action: Management is working to fill vacant Finance positions, including Accounts Receivable Associate. Until that time, the Interim Director of Finance has taken over responsibility for both advertising and operating billings. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2024-005: Federal Transit Cluster - AL# 20.507, Cash Management - Material Noncompliance/Material Weakness in Controls over Compliance Condition: A lack of cash flow and grant management oversight resulted in contractors and vendors not being paid timely during FY2024 . We noted 14 instances where contractors and vendors were not paid for over 30 days. We also noted four vendors were not paid for over 90 days. Criteria: All grant activities should include management level oversight to ensure timeliness, accuracy, and compliance with specified grant requirements. Cause: Lack of proactive cash flow and grant management occurred when invoices were received. Effect: Multiple contractors and vendors were not paid for over 30 days after receipt of invoice. Four vendors were not paid for over 90 days. Recommendation: A designated management level individual should have oversight to require timely drawdowns of capital grants and timely payment of invoices. Corrective Action: Issues with the implementation of new Federal and Commonwealth transportation grant portals hindered staff from being able to submit grant draw requests in a timely manner. Management is addressing these issues as they arise. The Interim Director of Finance and Accounting Supervisor are currently reviewing operating procedures and implementing methods to streamline work and eliminate duplicate activity. A Monthly Close Checklist is under development, which will create consistency in the timing and manner of recording financial activities. Additionally, detailed spreadsheets tracking grant activity have been developed, which will allow staff members to better monitor reimbursement requests and ensure vendors are paid timely moving forward. 2024-006: Federal Transit Cluster - AL# 20.507, Period of Performance - Significant Deficiency, Controls over Compliance Condition: There were numerous grants awarded to the Company that had award end dates prior to June 30, 2024, that had not been appropriately closed out at year-end. Criteria: All grants that are not active should be closed out within the grant awards management system after their award end date. Cause: Lack of proactive cash flow and grant management. Effect: Out of 18 federal grant awards tested, 6 had award end dates prior to June 30, 2024. All 6 were still marked as active in the grant award management system as of June 30, 2024, with total remaining funds on these awards totaling $673,179. Two of these grant awards had award beginning dates over 15 years old, had no activity during FY2024, and had not been closed out by June 30, 2024. Recommendation: A designated management level individual should close out all grant awards whose period of performance has expired within the grants management system. Corrective Action: Five FTA grants are in Active Award/Ready for Closeout (as of August 1 3, 2024), including VA-202 1- 038-01, YA- 2016-009-0 1, VA-202 1- 037-01, YA-2016-016-01 and YA-04-0027-01. Additionally, an inquiry was sent to the FTA on August 19, 2024, on what could be done with the remaining funds in VA-2019-018. Grant VA-2023-002- 00 has experienced delays due to the all-electric vehicle demand and supply chain issues. GRTC has been in communications with the FTA regarding this situation. All other active FTA grants have end of performance dates in 2025. 2024-007: Federal Transit Cluster - AL# 20.507, Procurement - Finding, Non-material Non-compliance Condition: As award recipients of Federal Transit Administration (FTA) funds, the Company is required to include certain clauses in contracts funded by FTA funds. We noted that the Company did not include the required " prohibition on certain telecommunications and video surveillance services or equipment" clause and the " notification of legal matters " clause as required clauses in their procurement manual and did not contain these clauses in one contract tested. Criteria: The FTA mandates that contracts funded with FTA awards must contain certain clauses related to prohibited vendors under the Code of Federal Regulations section 200.216 and requires contractors to notify the Company and the FTA of any current legal matters. Cause: Lack of compliance with FTA contract regulations. Effect: Contracts do not meet FTA contract regulations and are non-compliant. Recommendation: We recommend that the Company incorporate these required FTA clauses in their procurement manual and their standard contracts to properly incorporate in any future FTA funded contracts. Corrective Action: Missing FTA clauses will be addressed via revisions / updates to all of GRTC ' s solicitation and contract templates. As templates can often be edited by mistake, another tool to proof contracts is the " FTA Clause Matrix 2023 Applicability of Third-Party Contract Provisions" . The current version of this matrix includes provision from 2 CFR 200, Master Agreement 30 (FY 23) and Circular 4220.1 F. Procurement received this matrix during an NTI Procurement 101 training course December 2023. Referencing this matrix has been added as a step in project checklists. If the Federal Audit Clearinghouse has questions regarding this plan, please call Kevin Price , General Manager at 540-982-0305. Sincerely Kevin Price General Manager

Finding Number: 2024-004 Prior Year Finding: No Federal Agency: US Department of Education Federal Program: Eduation Stabilization Fund Assistance Listing: 84.425 Pass-Through Entity: Maryland Statement Department of Education Pass-Through Award Number and Period: 211935 3/24/21 - 9/30/23 Compliance Requirement: Davis-Bacon Act Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, we will start recording on a spreadsheet the Contract number and weeks covered for certified payrolls we receive that falls under the Davis-Bacon Act. This spreadsheet will have an approval column and date column to document our monitoring procedures for tracking and audit purposes. Name(s) of the contact person(s) responsible for corrective action: Adam Pelc, Supervisor of Accounting and Rob Rollins, Director of Facilities Planned completion date for corrective action plan: For immediate implementation and ongoing.

U.S. Department of Agriculture Summer Food Service Program - Child Nutrition Cluster Assistance Listing Numbers: 10.559 Recommendation: While the program did perform the monthly FNS418 reporting, we recommend the program ensure follow-through with the FFATA reporting requirement by entering the data collected from the subrecipients into the FSRF portal. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the time of audit completion, the relevant FFATA information from the Food and Nutrition Bureau was submitted to the Grant Manager for proper reporting, ensuring compliance for FY2025. To support this process, Legal will collaborate with the program to ensure that award letters accurately identify the awardee. Additionally, the CFO conducted Federal Grant Management training in May 2024, which included FFATA documentation and reporting, along with an overview of ECECD’s final policies and procedures for Grant Management. The CFO and ASD will continue to update training materials to maintain compliance moving forward. Name(s) of the contact person(s) responsible for corrective action: Carmel Pacheco-Aragon, Chief Financial Officer; Valerie Garcia, Budget Director; Amanda Carlisle, Grants Manager; ECECD Program Managers. Planned completion date for corrective action plan: The CFO has already implemented some of the review processes in collaboration with the Budget Director, Grant Management team, and relevant programs. The remaining processes will be addressed and fully implemented by June 30, 2025. If the U.S. Department of Agriculture has questions regarding this plan, please contact: Carmel Pacheco-Aragon Chief Financial Officer New Mexico Early Childhood Education & Care Department 1120 Paseo de Peralta Santa Fe, NM 87501 Phone: (505) 901-8226 Carmel.Pacheco1@ececd.nm.gov

Finding 2024-001 Significant Deficiency in Internal Control over Compliance and Other Matters Odessa College will implement the following to ensure compliance with federal regulations, improve internal processes, and prevent future occurrences. Additionally, the college is moving forward with comprehensive financial aid advisory services with Ellucian, the College’s enterprise student information system. The engagement/advisory priorities include establishing an R2T4 Process that complies with the 45-day reporting requirement. The engagement period is contracted for the next 14 months. Review and Update Withdrawal Procedures:  Conduct a comprehensive review of current student withdrawal procedures to identify any weaknesses or delays in processing withdrawal dates and the return of Title IV funds.  Ensure that the withdrawal process is thoroughly documented, and that all departments (registrar, financial aid, student accounts) are aligned on their responsibilities related to withdrawal processing. Strengthen Communication between Departments:  Establish a clear communication protocol among the registrar’s office, financial aid office, and student accounts to ensure that withdrawals are processed promptly.  Designate specific individuals to monitor the return of Title IV funds and ensure deadlines are met.  Implement an internal checklist for verifying that all Title IV funds are returned within the required time frame. Implement a Monitoring System:  Set up an automated system or a shared calendar to track Title IV refund timelines for students who withdraw.  Use alerts or reminders to notify responsible staff members when a Title IV refund is due to be returned within the 45-day window.  Monitor and document all returns of Title IV funds to maintain compliance. Staff Training:  Conduct training for staff involved in student withdrawals, financial aid, and compliance to ensure they are knowledgeable about the 45-day return requirement and the importance of adhering to it.  Include a review of the audit finding and corrective actions during departmental Develop a Compliance Audit Checklist:  Create a detailed audit checklist for Title IV refund procedures to be used in periodic internal audits to ensure that all financial aid disbursements, returns, and related processes comply with federal regulations.  Review the checklist regularly to ensure the process is effective and compliant with regulatory changes. Monitoring and Reporting:  Schedule and conduct regular internal audits of Title IV funds return procedures and withdrawal processes to ensure ongoing compliance.  Review audit findings, staff performance, and timelines to identify potential areas for improvement. Compliance Reporting:  Prepare a report for the administrative team outlining corrective actions taken, including the return of funds, updated procedures, and staff training. Responsible Officials: Kim McKay – Vice President Student Services Anticipated Date of Completion: May 2025 meetings to reinforce the importance of compliance.

Ineligible Disbursements Planned Corrective Action: The Financial Aid Office will review the credit hours earned for each student to ensure the federal loan amounts awarded are appropriate for the number of hours the student earned. This will be done before the beginning of each semester and after final grades have been posted. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: 12/9/2024

Finding: 2024-004 – Inaccurate Reporting/Lack of Independent Review and Approval of Reporting Program: Community Development Block Grants/Entitlement Grants (ALN 14.218); U.S. Department of Housing and Urban Development; Direct award; All project numbers. Auditor Description of Condition and Effect: During our audit procedures over the City's annual PR-26 reports and the annual CAPER, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions. We also noted that the CAPER was submitted as required, but contained financial data that did not agree to the City's underlying accounting records for the reporting period as required. The City's annual PR-26 report did not agree to the annual CAPER by approximately $435,000 and needed to be resubmitted to HUD. As a result of this condition, the City did not fully comply with the requirements of the grant and filed reports that contained financial errors. Auditor Recommendation: We recommend that reports required to be submitted to the oversight agency that contain financial information be reviewed and approved by the finance department to ensure accuracy of the financial information. Corrective Action: The City acknowledges the issues noted with reporting in the Community Development Block Grant Program. Finance and Community Development will work together to strengthen programmatic and financial reporting so that it is both timely and accurate. Staff working on this grant are new to their positions since the last time the program was audited, and are committed to reviewing policies and procedures to make sure reporting is completed appropriately. Responsible Person: Aaron Kuhn, Revenue Services Director and Marcie Gillette, Community Services Director Anticipated Completion Date: June 30, 2025

Finding 2024-001 Name of Contact Person: Robin M. West, Assistant County Manager/Chief Financial Officer Corrective Action/Management Response: Davie County Health and Human Services staff will review documentation supporting claims entered into the NC Fast Enterprise Program Integrity (“EPI”) system for accuracy and completeness. The supervisor reviews all 1682 forms for accuracy and quality control prior to entering the claim into NCFAST. The cases identified in error were the result of training and processing issues related to a former employee. DSS will properly train employees and address any future processing issues immediately through quality control procedures. Proposed Completion Date: Immediately and ongoing.

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the Academy will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the Academy will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the Academy has received an executed copy of the form. Upon notification of construction commencement, the Academy will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the School will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the School has received an executed copy of the form. Upon notification of construction commencement, the School will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.

Reference Number: 2024-001 Finding: Other Instance of Noncompliance and Significant Deficiency Status: In-progress Corrective Action: Following our analysis, we have concluded that adjusting our data transmission schedule to NSC will help prevent future last minute data anomalies, ensuring that a final transmission for the term always occurs after the end date of each term. Additionally, we have identified a potential issue where NSC may fail to send graduate records to NSLDS for students who immediately re-enroll in the subsequent semester. Due to timing between the submission from NSC to NSLDS, the newer enrollment appears to be overriding the previously sent graduation record, preventing the graduation record from being sent to NSLDS. To address this, we will create a dedicated report to identify students in this situation and manually update NSLDS with the missed graduation data. Finally, there were isolated cases where a historical date adjustment was made to generate an auxiliary outcome (e.g., a grade change of Withdrawal instead of Withdrawal Failing), which made it appear as though a record change wasn't submitted in a timely manner. For these, we will discontinue this practice and employ an alternative method to derive the desired outcome (e.g., additional grade change transactions input after the withdrawal with no date adjustment). Person(s) Responsible for Implementing: Mike Acosta, Institutional Analyst, Nathan Dugat, Registrar, Lynda McKendree, Dean of Scholarships and Financial Aid Implementation Date: 11/01/2024

Finding Number: 2024-002 – Approval of Payroll Expense Transactions Corrective Action Plan: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted until proper approval is received. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2025

Responsible Officials: The acting Executive Director reported incident immediately and enforced quality improvement program in order to ensure that fraud, waste, and abuse do not occur.

Significant Deficiency Non-Compliance Finding 2024-004: Name of Contact Person: Jared Pyles, Finance Director Corrective Action: The City mistakenly reported budgeted costs rather than cumulative costs as part of the compliance reporting for ARPA Funds when closing several projects. The City will correct on its next reporting. Proposed Completion Date: Immediately.

2024‐001 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Name of Contact Person The Director of Financial Aid, Christin Mustard, is responsible for the corrective action plan for this finding. Corrective Action Plan We agree with this finding. After review of this student’s Return to Title IV calculation, it was determined that upon beginning the calculation in the PowerFAIDS system, the Refresh button was not used which would have recalculated the completed days to include the 9-day Spring Break. After reviewing this procedure with PowerFAIDS, it was recommended that we also enter the withdrawal date on the R2T4 tab of the POE screen which forces the system to recalculate the completed days prior to beginning the R2T4 calculation. We have added this step to our Return to Title IV procedures. Anticipated Completion Date The corrected Return to Title IV calculation was completed, which resulted in an Unsubsidized loan return of $1,029. The loan funds were returned via the Common Origination and Disbursement (COD) system.

2024-003: Student Financial Audit Cluster - Reporting (Significant Deficiency) Corrective Action: Controls have been implemented to retain the documentation used in preparing the FISAP. All documentation for all pieces of the FISAP are now being stored electronically in a shared drive as well as on paper to be held in the Director’s office. Anticipated Completion Date: 9/13/2024 Contact Person: Laurie Johnstone

2024-005: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Upon investigation, we discovered that even though Casper College is reporting our enrollment to the National Student Clearinghouse (NSC) in a timely fashion, those reports are not always being sent to the National Student Loan Data System (NSLDS) swiftly. We understand that NSC is a third-party servicer and ultimately, the institution is responsible for ensuring NSLDS is being updated properly. As a failsafe, Casper College has developed an internal audit procedure to manually update students in NSLDS to be in compliance with CFR 690.83. Anticipated Completion Date: 9/18/2024 Contact Person: Laurie Johnstone

2024-004: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to or on Behalf of Students (Significant Deficiency) Corrective Action: Casper College’s award notifications have been updated to include when funds will be disbursed. In addition, the award notifications reference the Important Dates URL on the Casper College website for parents and students to refer to that include award disbursement dates. Anticipated Completion Date: 9/6/2024 Contact Person: Laurie Johnstone

Management is cognizant of the Agency’s internal control structure and continues to evaluate cost effective opportunities to further improve segregation of duties. The Agency has strengthened the internal control structure in recent years by revising the roles and responsibilities of multiple positions within the accounting department. The Agency continues to identify and implement effective mitigating controls when possible. Current Agency procedures for journal entries include one position that is primarily responsible for preparation of journal entries and posting. The Agency is working on implementing procedures that involve program personnel assisting with preparation and/or review of journal entries. Name of responsible official: Nick Curran, Director of Business Operations Expected completion date: Ongoing, no formal expected completion date.

Internal controls will be created for reviewing the determination of eligibility for participation in the Emergency Rental Assistance Program.

Finding 2024-002 - Significant Deficiency: Enrollment Reporting Condition For 1 of 17 students tested, the student’s status was reported incorrectly to the National Student Loan Data System (NSLDS). The student graduated however was reported to NSLDS as withdrawn. The student’s status was also reported late, after 60 days. In addition, another student’s status was also reported late. The sample was not a statistically valid sample. Corrective Action Plan The school agrees with the finding. While the withdrawn status was reported for this specific student, the follow-up graduated status was not. This student completed the graduation requirements much later. The school has implemented improved communication between registrar and financial aid to be sure these later graduations are reported. In addition, the timeframe for sending monthly enrollment reports through the National Student Clearinghouse will be altered to improve timely reporting of all statuses. The late statuses were by only a few days and should be resolved by adjusting this timeline. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeff Aalbers Anticipated Completion Date: January 31, 2025

Finding2024-001: FEDERAL WORK STUDY-WORKING DURING CLASS TIME Comments on Finding and Recommendation(s): We concur with this finding. Due to the error rate of FWS instances of noncompliance, the Institution should review and update its internal controls related to FWS to ensure that students are not working during scheduled class time and enhance communication between Federal Work Study supervisors and registration department to ensure instances of noncompliance do not recur. Action Taken or Planned: 1} The school IT department is setting up the WorkEasy clock in/clock out system for students to lock students out of being able to clock in during scheduled class times. 2} Supervisors will examine each time card to verify no student has worked during scheduled class hours unless as defined in Volume 6 Chapter 2: Working During Scheduled Class Time Prohibited - "Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community work-study experience. Any such exemptions must be documented." Documentation will be provided before the work is approved to be classified and paid as FWS wages earned. 3} Supervisors will be trained and required to sign a policy at the beginning of each award year or upon hire that states students are not permitted to work during scheduled class hours unless they meet one of the documented exceptions in Volume 6 Chapter 2. By signing this policy, supervisors agree that they may be subject to disciplinary action if they fail to abide this policy.