Corrective Action Plans

Views of Responsible Officials and Corrective Action Plan We concur. The District has filed a bug with IT to have this issue addressed and the programming fixed promptly. Corrections have already been made with NSLDS by the campuses.

Views of Responsible Officials and Corrective Action Plan We concur. Management has revised its procedures for R2T4, as well as added additional monthly review to ensure compliance.

Finding: 2025-004 Name of Contact Person: Renae Miller, Public Housing Director Corrective Action/Management’s Response: The Housing Choice Voucher (HCV) Program repeat findings identified in the audit are acknowledged. As part of the corrective action to address these findings and to strengthen program compliance and oversight, the City of Albemarle entered into a Memorandum of Agreement (MOA) with the Lexington Housing Authority (LHA) to administer the HCV Program on the City’s behalf. As part of this transition and corrective process, LHA conducted a comprehensive review and audit of the HCV Program covering the previous five (5) years, allowing for the identification of compliance gaps, operational deficiencies, and areas requiring corrective action. This review has informed the implementation of improved controls, processes, and reporting mechanisms. Moving forward, I, as the Director of Housing, will maintain direct and ongoing oversight of the HCV Program by working closely with LHA leadership to ensure the program is administered in full compliance with HUD regulations and applicable requirements. This oversight will include: • Receipt and review of monthly HCV performance and compliance reports • Regular briefings and status meetings with the Executive Director of the Lexington Housing Authority • Ongoing monitoring of corrective actions and compliance benchmarks • Prompt resolution of identified issues to prevent recurrence of findings These measures have been implemented to strengthen accountability, improve internal controls, and ensure sustained compliance of the HCV Program moving forward. Proposed Completion Date: Immediately and Ongoing

Finding: 2025-003 Name of Contact Person: Renae Miller, Public Housing Director Corrective Action/Management’s Response: The Housing Choice Voucher (HCV) Program repeat findings identified in the audit are acknowledged. As part of the corrective action to address these findings and to strengthen program compliance and oversight, the City of Albemarle entered into a Memorandum of Agreement (MOA) with the Lexington Housing Authority (LHA) to administer the HCV Program on the City’s behalf. As part of this transition and corrective process, LHA conducted a comprehensive review and audit of the HCV Program covering the previous five (5) years, allowing for the identification of compliance gaps, operational deficiencies, and areas requiring corrective action. This review has informed the implementation of improved controls, processes, and reporting mechanisms. Moving forward, I, as the Director of Housing, will maintain direct and ongoing oversight of the HCV Program by working closely with LHA leadership to ensure the program is administered in full compliance with HUD regulations and applicable requirements. This oversight will include: • Receipt and review of monthly HCV performance and compliance reports • Regular briefings and status meetings with the Executive Director of the Lexington Housing Authority • Ongoing monitoring of corrective actions and compliance benchmarks • Prompt resolution of identified issues to prevent recurrence of findings These measures have been implemented to strengthen accountability, improve internal controls, and ensure sustained compliance of the HCV Program moving forward. Proposed Completion Date: Immediately and Ongoing

FINDING 2025-001 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card/High School Graduation Rate Contact Person Responsible for Corrective Action: Mike Krutz Contact Phone Number and Email Address: 219-650-5300 x5370, mkrutz@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our processes for the future. Description of Corrective Action Plan: The High School Staff implemented procedures to ensure adequate documentation is received to support a student’s removal/withdrawal from a cohort. The Student Withdrawal Report Form has been updated to include the most current State Withdrawal Codes as well as a high school administrator’s signature for approval. The procedures for removal/withdrawal from a cohort are as follows: 1. The student and/or parent complete the Withdrawal Report Form with the assistance of the attendance secretary. The Withdrawal Checklist Form is started and initialed by the attendance secretary. 2. The student and/or parent meet with an administrator or designee to review the Withdrawal Report Form and complete the Exit Interview Form. The Checklist Form is initialed by administrator or designee signifying completion of this step. 3. The attendance secretary scans the forms into the current student management system. The Checklist Form is initialed by the attendance secretary signifying completion of this step. 4. The original forms are hand delivered to the Registrar who then completes transfer requests and verifications to receiving schools. The Checklist Form is initialed by the Registrar signifying completion of this step. 5. The Registrar upon receiving the original documents hand delivers the Checklist Form to an administrator who reviews and signs the form approving the withdrawal. 6. The original documents are filed in the student’s permanent record folder. 7. Cohorts are reviewed after each trimester by grade level administration and cross referenced with the student management system to check for anomalies. Grade level administration will report their findings to the head principal or designee. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate" BOARD OF SCHOOL TRUSTEES Judy C. Dunlap James Donohue DeLena N. Thomas Alex Dunlap III Robert J. Krause President Vice-President Secretary Member Member INDIANA STATE BOARD OF ACCOUNTS 28 MERRILLVILLE COMMUNITY SCHOOL CORPORATION 6701 Delaware Street, Merrillville, IN 46410 (219) 650-5300 FAX (219) 650-5320 www.mvsc.k12.in.us If a student stops attending school and the student/parent does not come in to complete the process, the following procedures are followed: 1. The guidance office secretary attempts (and documents attempts) to contact the parent via phone calls, emails (with read receipt), and certified letters. All paperwork is printed and put in the student file. 2. The guidance office secretary searches the Education ID Portal site to determine if the student is attending another high school. 3. Continual effort is made to contact the parents by the guidance secretary or grade level dean. 4. Once the parent is reached, the above procedures are followed (see step1-7 above). 5. After 3 methods of contact are made (call, email, certified letter), the Student Withdrawal Report is completed and signed by an administrator and withdrawal codes 14 (Unknown/No Show 18+) or 15 (Truancy-Underage No Show) are used. 6. When the school is unable to get in contact with the parent, reports are made to DCS, Merrillville Truancy Court, and the updated procedures for Missing Students/Unknown Location are to be initiated immediately. Additional Step to Corrective Action Plan: We are establishing an annual internal audit, to be completed by central office staff, to ensure that all procedures related to the removal or withdrawal of individuals from a cohort are consistently and properly followed. The internal audit will consist of 10-15 randomly selected withdrawn student’s records. This audit will review documentation, decision-making processes, and compliance with established guidelines to confirm alignment with policy and regulatory requirements. The goal is to promote accountability, maintain program integrity, and identify any areas for improvement or need for additional training. Anticipated Completion Date: June 15, 2026

Management concurs with Audit Finding 2025-004 and will strengthen controls over USDA commodity receiving documentation and related reporting to ensure compliance with Food Distribution Cluster special tests and provisions and reporting requirements. Management will implement the following corrective actions: 1. Required Receiving Worksheets for USDA Commodity Receipts Management will reinforce the requirement that a completed receiving worksheet be prepared for all TDA USDA commodity receipts. Each receiving worksheet will be signed or initialed by the receiving employee at the time of receipt to evidence verification of quantities received. 2. Reconciliation of Receiving Documentation to CERES Management will implement a formal reconciliation process to ensure all USDA receiving documentation is reconciled to CERES inventory entries prior to submission of monthly TEFAP reports. Any discrepancies will be promptly investigated, resolved, and documented. 3. Supervisory Review and Approval Supervisory personnel will perform periodic documented reviews to verify that: o All USDA commodity receipts are supported by completed and signed receiving worksheets; and o Receiving activity is accurately and completely recorded in CERES. Evidence of supervisory review will be retained. 4. Documentation Retention and Standardization All receiving worksheets and supporting documentation will be retained in accordance with Food Distribution Cluster record retention requirements. Management will standardize receiving forms and procedures to promote consistency and completeness. 5. Training and Ongoing Monitoring Management will provide refresher training to warehouse and inventory staff on USDA receiving requirements and the importance of timely, accurate documentation. Management will periodically monitor compliance with these procedures to ensure controls are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following corrective actions: 1. Required Agency Acknowledgment at Delivery Management will reinforce procedures requiring recipient agency signatures or equivalent acknowledgment on all USDA food distribution invoices at the time of delivery. Distribution staff and drivers will be reminded that unsigned delivery documentation is considered incomplete. 2. Post-Delivery Follow-Up Control Management will implement a follow-up control, such as a delivery log or checklist, to track all USDA distributions recorded at the time of delivery. The log will include verification that a signed receipt has been obtained and returned for each transaction. 3. Reconciliation of Distributions to Signed Documentation On a periodic basis, management will reconcile USDA distribution activity to signed agency invoices to identify any missing acknowledgments. Missing signatures will be promptly investigated and resolved, with documentation of follow-up retained. 4. Supervisory Review and Oversight Supervisory personnel will perform periodic documented reviews of distribution documentation to verify that signed agency receipts are obtained, complete, and retained. Evidence of review will be maintained. 5. Training and Awareness Management will provide refresher training to distribution staff and drivers on USDA documentation requirements and the importance of obtaining signed acknowledgment to support program accountability and reporting accuracy. Expected Completion Date: Within 60-90 days Responsible Parties: Andrelle Bowen, Transportation Manager, (901-373-0402)

Finding 2025-004 Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. During testing of compliance for Enrollment Reporting, there were 3 instances out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time limit of 60 days from the effective date of the student’s change in enrollment status. Corrective Action Plan: Enrollment reporting has been centralized under a single point of contact, thereby mitigating risk, ensuring consistency, accountability, and regulatory compliance. This structure was formally implemented last summer with the hiring of an Academic Records Compliance Specialist, significantly strengthening oversight and operational controls. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Noah Briscoe – Assistant Registrar Anticipated Completion Date: 12/31/2025

Finding 2025-002 Finding Summary: 34 CFR 668.164(h)(2)(i,ii) states that A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than—Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. During our testing of compliance for HEA Credit balances, there were 5 instances out of 60 where the College did not refund a student’s within the required time frame of 14 days from the first day of class or 14 days after the credit balance was created. Corrective Action Plan: The institution has taken and has fixed this issue by: • Dedicated Staffing: A full-time position has been approved and filled to manage stipend processing, ensuring consistent oversight and timely disbursement. • Process Documentation: Stipend processing procedures have been documented to ensure continuity, accountability, and clarity of responsibilities. • System Review and Planning: The system is up and running as it should have been. • Ongoing Monitoring: Leadership will continue to monitor stipend processing timelines and staffing capacity to ensure compliance and timely student support. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Bethany Parmer – Assistant Dean of Enrollment Services Anticipated Completion Date: 12/31/2025

Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit finding and is committed to strengthening internal controls over enrollment status reporting to ensure continued compliance with federal requirements. During management’s review of the audit results, the Registrar’s Office was unable to reproduce the specific enrollment status reporting errors identified during audit testing and could not definitively determine how the errors occurred. Notwithstanding this, the College recognizes that weaknesses in monitoring and documentation contributed to the inability to detect and prevent the reporting discrepancies in a timely manner. Accordingly, management has developed the following corrective actions. The College will enhance coordination among Registrar’s Office, Financial Aid, and Information Technology to ensure enrollment status changes including graduation, withdrawal, and changes in enrollment status are identified promptly and reported accurately to the National Student Loan Data System (NSLDS) within the required 60-day timeframe in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. For over 20 years, the College of Idaho has been a member of the National Student Clearinghouse (NSCH). One of the many advantages of membership to the NSCH is that the NSCH serves as a conduit to NSLDS and sends reports to the NSLDS for the college. Ellucian Colleague has written a series of reports that result in a .txt file that is uploaded to NSCH who in turn uploads to NSLDS. The College of Idaho submits regular transmissions to NSCH so that the 60-day timeframe is met. Corrective Action Plan: • Process Review and Clarification of Roles The Registrar’s Office will review and formalize procedures related to enrollment status determination and reporting. Roles and responsibilities for identifying enrollment changes, preparing NSLDS files, and submitting updates will be clearly documented to ensure accountability and continuity. • Student Information System Reporting Improvements The College will refine and validate student information system (SIS) reports used for enrollment reporting to ensure accurate capture of enrollment status changes and effective dates. Reports will be reviewed regularly to confirm continued reliability. • Internal Review and Oversight Controls Prior to submission to NSCH, enrollment status reports will be reviewed by the Registrar supervisory personnel to confirm accuracy and completeness. Evidence of review will be retained in accordance with institutional record retention practices. • Established Reporting Timeline A recurring reporting calendar will be implemented to ensure enrollment status updates are submitted within required federal timeframes. Backup personnel will be identified to support continuity during staff absences. • Training and Ongoing Communication Staff involved in enrollment reporting will receive periodic training on federal enrollment reporting requirements and institutional procedures. Regular communication between Enrollment Services and Financial Aid will support timely identification and resolution of discrepancies. Responsible Official(s): Mark Heidrich (Registrar/Associate Vice President for Institutional Effectiveness), in coordination with Stephanie House (Director of Financial Aid) and Imad Sweidan (Chief Information Officer), as appropriate. Anticipated Completion Date: June 30, 2026 Current Status: Corrective action is in progress. Management expects these actions to be fully implemented prior to the next audit period and believes the strengthened controls will prevent recurrence of this finding.

The College will diligently check each financial aid disbursement roster to review and refund any student account credit balances generated from a disbursement. This process is to maintain compliance with this requirement. The College will also create an Infomaker report each week to identify any credit balances that need refunded.

The Cooperative will make deposits to the general operating reserve to meet the HUD regulatory agreement. The management agent will implement a process to ensure deposits are made as required by the regulatory agreement.

The Cooperative will make deposits to the general operating reserve to meet the HUD regulatory agreement. The management agent will implement a process to ensure withdrawals are made as required by the regulatory agreement.

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Cause: Within the University's student information system, PowerCampus, the degree verifier report was not cross referenced with the graduation report. This student was on the degree verifier report but did not appear on graduation report, which is the report that is sent to the National Student Clearinghouse ("NSC") who then transmits information to NSLDS on behalf of the University. Condition: One student was excluded from the report used for the Clearinghouse as a graduated student. As they did not appear on the report twice, the Clearinghouse changed their status to withdrawn. The School then became aware of the change and the graduated status was transmitted to the clearinghouse on 2/7/25 and not received by NSLDS until 7/24/25. Criteria: The Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Corrective Action Plan to be Taken: After each graduation period the Registrar’s Office will compare the Degree Verify file against the Graduation Enrollment file as both files are uploaded to the National Student Clearinghouse. The Degree Verify file is generated and uploaded after the Graduation Enrollment file; this process of report comparison will allow us to capture any student not reported in the Graduation Enrollment file. Thereby ensuring all graduating students are reported correctly to the National Student Clearinghouse. We’ll begin this process, on October 3, 2025 with the August 2025 graduates as they were just reported to the National Student Clearinghouse this past month. Sincerely, Linda M. Arce Registrar

Views of Responsible Officials and Planned Corrective Actions – Total Health Care will conduct regular testing of its application process for the sliding fee discount. This will include reviews of the documents and support provided by applicants for the sliding fee. These reviews will be conducted randomly throughout the year and will be based on sample selections. Total Health Care is committed to insuring that every applicant who is eligible for its sliding fee discount is accurately identified, and the sliding fee benefit is correctly awarded. These steps will also include random and unannounced observation and inspection of the sliding fee process. Organization Contact Person Responsible for Corrective Action – Richard Greene, CFO Anticipated completion date: 6/30/26

Reference Number 2025-02 Return of Title IV Funds (R2T4) Since the 2025 audit, there have been significant improvements in oversight and process management for R2T4 calculations. A leadership transition occurred, and the Associate Director - bringing over 30 years of higher education experience, including prior service as a Financial Aid Director - has assumed responsibility for R2T4 calculations for the 2026-27 academic year. To ensure compliance and accuracy, the Associate Director completed a Department of Education training refresher on R2T4 calculations during Spring 2025. Additionally, the interim Financial Aid Director implemented a structured plan to monitor all student withdrawals and guarantee timely completion of calculations. For Fall 2025, the process has remained on schedule. A two-tier accountability system is in place: the Associate Director manages calculations, and the Director provides immediate support if any delays occur. A comprehensive tracking spreadsheet was developed to record each withdrawal, including the withdrawal date, federal aid status, and the date the R2T4 calculation was completed. This tool ensures real-time monitoring and accuracy. The daily withdrawal report introduced after the 2024 audit continues to be a valuable resource; however, the combination of this report with the new tracking system and dual oversight has proven to be the cornerstone of compliance. All calculations are current, accurate, and completed within required timelines. Based on these improvements, we do not anticipate any findings in the upcoming audit.

Views of Responsible Officials and Planned Corrective Actions – The Registrar and Institutional Researcher will both ensure that any students that have updated their status are updated on a weekly basis. The Institutional Researcher will log into NSLDS to upload the file, and the CFO, Registrar, and Institutional Researcher will monitor updates monthly.

Views of Responsible Officials and Planned Corrective Actions – The CFO and the Students Account Manager will add a checklist step to verify the correct inclusion of all scheduled breaks in the R2T4 calculation, will implement a secondary review process to confirm data accuracy before finalizing R2T4, and will provide training to relevant staff.

2025-001 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that required HQS are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: See narrative below. SC Housing’s inspection team strives to represent both the organization and HUD at the highest level. The HCV inspections team takes pride in being timely, professional, and thorough, as evidenced by the single finding noted in our most recent audit. SC Housing has taken several corrective steps to mitigate and prevent late inspections. First, we implemented modifications to our organizational structure. Late inspections resulted from the previous structure and business practices, which assigned staff to specific families and required them to oversee all HCV-related tasks for those families, including inspections. While this approach promoted continuity, it created challenges when staff were absent for extended periods, as there was no backup capacity to absorb the workload. As a result, SC Housing reorganized the HCV program to significantly reduce the likelihood of late HQS inspections. Inspections are now centralized as a primary function, and the inspection team has been restructured to be smaller, more flexible, and more responsive. Second, SC Housing has enhanced its monitoring processes. In addition to regularly pulling system-generated reports to identify inspections due, staff are now fully utilizing PIC reports to proactively identify families approaching the maximum 24-month inspection timeframe, thereby reducing the risk of late inspections. Lastly, staff leaves and absences are being managed more effectively to ensure adequate coverage at all times. This approach ensures that sufficient staffing is available to complete all inspection types timely and without delay. Name(s) of the contact person(s) responsible for corrective action: Lisa Wilkerson, Director of Rental Assistance and Compliance Lenzy Morris, HCV Inspections Manager Planned completion date for corrective action plan: Immediately and Ongoing If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Lisa Wilkerson at (803) 896-7030.

FINDING 2025-002 Finding Subject: Education Stabilization Fund – Wage Rate Requirements Contact Person Responsible for Corrective Action: Tanya Pearson Contact Phone Number and Email Address: (765) 522-6218 / tpearson@nputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Although the Education Stabilization Fund projects have been completed, the School Corporation will implement procedures to ensure compliance with Davis Bacon and wage rate requirements for all future federally funded grants that have this stipulation. Anticipated Completion Date: Immediately (February 1, 2026)

Identification Number: 2025‑004 – Return of Title IV Funds Finding: Incorrect spring break days were used in Return of Title IV calculations for Spring 2025, resulting in inaccurate return amounts and funds not properly returned to the U.S. Department of Education. Corrective Action Plan: Management agrees with the finding. The University will revise Return of Title IV calculation procedures to ensure accurate identification of payment periods, including scheduled breaks. A secondary review of all Return of Title IV calculations will be implemented prior to processing returns to confirm accuracy and compliance with federal regulations. Identified funds due will be returned to the U.S. Department of Education. Responsible Officials and Implementation Date: The Director of Student Financial Services will be responsible for implementing the corrective action, with oversight from the Vice President for Administration and Finance. Revised procedures and secondary review controls will be implemented by February 16, 2026.

Identification Number: 2025‑003 – Enrollment Reporting (Repeat Finding) Finding: The University did not report one student status change timely and reported inaccurate program‑level record data for four students, resulting in inaccurate or untimely enrollment reporting to the U.S. Department of Education. Corrective Action Plan: Management agrees with the finding. The University will enhance controls over enrollment reporting to ensure all student status changes and program‑level data are reviewed for accuracy and reported timely. Additional reconciliation between the Registrar's Office and Student Financial Services will occur before submission to the National Student Clearinghouse and the U.S. Department of Education. Responsible Officials and Implementation Date: The Registrar and Director of Student Financial Services will be responsible. Improved review and reconciliation procedures will be implemented by July 1, 2026, prior to the Fall term.

Name of Contact Person: Daniel Nolan, Finance Officer Corrective Action Plan: The Board of Education will implement controls to ensure that federal budget amendments are completed in accordance with program requirements. Proposed Completion Date: Immediately

Finding 2025.001 Special Tests and Provisions - Sliding Fee Discounts Recommendation Kalihi-Palama Health should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken: Effective February 9, 2026, we will implement the following changes to ensure clients are appropriately charged according to the sliding fee scale. -Update the frequency of our sliding fee scale employee training sessions -Implement monthly spot checks to ensure compliance to the sliding fee scale and provide timely feedback

Upon notification of the reporting error, the institution corrected the enrollment status effective date in both the National Student Clearinghouse (NSC) and NSLDS to reflect the student's actual withdrawal date of November 15, 2024. To prevent future reporting errors, the Registrar's Office will implement an additional procedural verification step in the enrollment status reporting process. This step will include a review of effective dates prior to submission to NSC and NSLDS. The Registrar will also ensure appropriate staff training and oversight as process documentation is developed and implemented in the new student information system.