Corrective Action Plans

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

Finding 2024-003 – Capital Fund Grant Reconciliations – Special Tests – Significant Deficiency Capital Fund Program – ALN #14.872 Corrective Action Plan: The Housing Authority has brough forward all schedules related to Capital Fund Grant as of March 2025. Person Responsible: Sheila Crisp, Executive Director Anticipated Completion Date: June 2025

Cash Management – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Director will ensure that when processes are completed, they are verifiable through documentation. Credit Balance refunds as well as drawdowns will be tracked for proper compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

Special Tests and Provisions Direct Loan Reconciliation – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid director will institute a documented review of the Direct Loan reconciliations prepared by Campus Ivy or future third-party processors. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

Special Tests and Provisions 240 Day Checks – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office along with Student Accounts and the Business Office at Urshan University will collaborate on an SOP which will establish a process of reviewing any outstanding Title IV checks. Checks will be reissued as necessary to ensure the university stays compliant with all Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office will be implementing an SOP which will document a review process of work done by the third-party processor, to include COD reporting, and Verification procedures. We will also be implementing a process to review students who need to complete their exit counseling. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

Special Tests and Provisions Gramm-Leach-Bliley Act– Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The IT department continues to improve its processes; an annual review of the WISP has been started and will continue. The Financial Aid Office will work with IT to make sure that the WISP is improved to include and provide secure disposal of customer information and make sure the review is documented. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

Special Tests and Provisions Enrollment Reporting – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A new Standard Operating Procedure (SOP) is being created, which will address enrollment reporting concerns. The Financial Aid office will work with the Registrar to increase communication between offices and eliminate enrollment reporting errors. The Financial Aid office will also improve reporting to the third-party processor, so that timely and accurate information is uploaded to NSLDS. Furthermore, a recurring review of the third-party’s reporting to NSLDS will be instituted. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

While the audit notes improvements in this area, we continued to face some challenges in properly allocating indirect costs and fringe benefits to individual contracts. We will close the remaining gap between the costs properly billed to individual contracts and the process of reflecting these costs in our accounting system by refining our cost allocation plan. This revision will include consistent rules for allocating indirect and fringe plus a quarterly review by accounting staff and management. We will also use newly formatted grant worksheets shared with us by Whittlesey to help us identify and correct any allocation issues before closing out our accounting records for this fiscal year.

Condition: Of the 40 students selected for enrollment reporting testing, 1 student did not have their program-level status change updated appropriately and another student was not updated from less than half time to withdrawn by the University's third party administrator. Planned Corrective Action: Clearinghouse reporting process has been reassessed, and error reporting will be completed weekly. Training will be done for registrar staff on process, and how to verify information has successfully been accepted by NSLDS. The Registrar's office will work closely with Financial Aid to verify enrollment updates and complete error resolution. Contact person responsible for corrective action: Callie Zake, Senior Director Student Financial Services Anticipated Completion Date: June 30, 2025