Corrective Action Plans

Finding 2022-040 Formula Grants for Rural Areas and Tribal Transit Program, ALN 20.509 - Subrecipient Audits Management Views MDOT agrees with the finding. Planned Corrective Action MDOT will update and implement its procedures to include management decision letter timelines that are consistent with the Uniform Guidance related to subrecipient report review. Anticipated Completion Date September 30, 2023 Responsible Individual(s) Adam Feldpausch, MDOT Dave Wearsch, MDOT

Finding 2022-039 Formula Grants for Rural Areas and Tribal Transit Program, ALN 20.509 - PTMS Security Management and Access Controls Management Views MDOT agrees with the finding. Planned Corrective Action MDOT?s Office of Enterprise Information Management (EIM) and Office of Passenger Transportation (OPT) will collaborate and provide oversight to ensure there is properly approved access for Public Transportation Management System (PTMS) users and that PTMS user access is reviewed semiannually for privileged accounts and/or annually for all other accounts. MDOT EIM and OPT will do this by reviewing security management and access control procedures and making any necessary updates, providing training on the process and documentation requirements, and designating a PTMS system security administrator(s) and back-up(s) as needed. Anticipated Completion Date August 1, 2023 Responsible Individual(s) Kyle Nelson, MDOT Andy Esch, MDOT OPT Business area system administrator(s)

Covid-19 Coronavirus State and Local Fiscal Recovery Funds ? Assistance Listing No. 21.027 Recommendation: The Town should update all contracts to include a suspension and debarment paragraph to verify status with every renewal. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town agrees that suspension and debarment documentation was not properly kept. The Town has met with their legal counsel to update all contract templates to include a clause or conidiation regarding suspension and debarment. This review will be completed by the finance department prior to entering into the contact with each entity. The documentation should include the certification from the vendor or reference the contract that includes the clause or condition regarding suspension and debarment. Name of the contact person responsible for corrective action: Stefanie Furman, Finance Director Planned completion date for corrective action plan: 7/31/2023 If the Department of Transportation or the Department of the Treasury have questions regarding this plan, please call Stefanie Furman, Finance Director at 303-926-2750. Town

Highway Planning and Construction Cluster ? Assistance Listing No. 20.205 Recommendation: The Town should update all contracts to include a suspension and debarment paragraph to verify status with every renewal. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town agrees that suspension and debarment documentation was not properly kept. The Town has met with their legal counsel to update all contract templates to include a clause or conidiation regarding suspension and debarment. This review will be completed by the finance department prior to entering into the contact with each entity. The documentation should include the certification from the vendor or reference the contract that includes the clause or condition regarding suspension and debarment. Name of the contact person responsible for corrective action: Stefanie Furman, Finance Director Planned completion date for corrective action plan: 7/31/2023

The following corrective measures have been implemented: The Director of Financial Aid requests the amounts and number of students who received HEERF funding from the Business Office at the end of each quarter and reviews, confirms, and documents the date of request and review. A log of the website updates is maintained to document timely submission of data. The website was revamped to include all necessary reporting requirements including the number of eligible students for CRSSA HEERF II and ARP HEERF III. This updated process was implemented upon identification of the prior year finding, which occurred after the first quarterly report for fiscal year 2022 was posted.

Finding 2022-012 U.S. Department of Treasury AL No. 21.019 Coronavirus Relief Fund (CARES) Material Weakness over Subrecipient Monitoring Repeat Finding: Yes Auditee?s Corrective Action Plan: Per the auditor?s recommendation, the agency will seek training on the Uniform Guidance requirements related to sub-recipient monitoring. The agency will ensure that there is a written plan in place for how to monitor the sub-recipients that were awarded funds by the City from the CARES Act. Contact Person: Deputy Finance Director ? Bob Cenname Completion Date: December 2024

2022-003 Suspension and Debarment Control Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Assistance Listing #93.323; Special Education Cluster, Assistance Listing #84.027 and #84.173; Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Response and Corrective Action Plan: We agree with the finding. The Purchasing Director does check all new applicable vendors for potential debarment, but has not retained written documentation of his process. We will now ensure documentation is retained. Responsible Individuals: Cameron Cox, Director of Purchasing Anticipated Completion Date: Ongoing

The District is aware of the requirement in Federal Program legislation to ensure the inclusion of the prevailing wage rate provision in agreements, as well as to obtain certified payroll reports to verify prevailing wages were paid. At the time the District entered into the agreement with West Roofing to install and renovate the HVAC system at Columbia High School, which was January 7, 2021, ESSER funds were not awarded to the District planned on using Permanent Improvement funds (a non-federal program sourced fund) to pay West Roofing. The District initially paid West Roofing from the Permanent Improvement fund for the installation/renovation of the HVAC at Columbia High School as per the initial contract. Once the ESSER funds were awarded, they allowed for previous expenses related to improving air quality to be included as part of reimbursement through ESSER funds. The prevailing wage was not met under the existing contract. The District has implemented the following Action Plan for Correction: 1. The Treasurer will ensure all agreements intended to be sourced through Federal Funds will contain prevailing wage rate provisions prior to signing such agreements. 2. The Treasurer will ensure that invoices from contractors contain the necessary prevailing wage certified payroll reports prior to approving such invoices for payment from Federal Funds. 3. The Treasurer will educate all responsible parties in the District regarding prevailing wage documentation to ensure appropriate documentation is obtained prior to payment to the contractors and prior to requesting Federal Funds.

Consolidated Health Centers Grant ? Assistance Listing No. 93.24 and 93.527 Recommendation: Our auditors recommended the Organization review internal controls in regards to determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has accepted the recommendations and has scheduled time at bi-weekly front desk/billing meetings to retrain staff on processes that ensure appropriate sliding fee rates are utilized for each sliding fee encounter. Specifically, training will focus on confirming fee schedules are updated on a timely basis per the effective date of the fee change, and encounters with both an office visit and procedures are properly identified so that the procedure co-pay is adjusted off in entirety, leaving only the office visit co-pay as the patient responsibility. Name(s) of the contact person(s) responsible for corrective action: Annette Franta, CFO Planned completion date for corrective action plan: Fiscal year 2023 If the U.S. Department of Health and Human Services has questions regarding this plan, please call Annette Franta, CFO at 970-945-2840.

2022-005 Reporting ? Internal Control and Compliance over Reporting City?s Corrective Action Plan: A recent appointment to the Debt and Treasury department has allowed for restructuring of the processes present within the department. Debt and Treasury personnel have been made aware of the previous insufficiencies and will work with funding sources to identify which requirements are fulfilled by external project managers and which requirements need to be fulfilled by City staff. Responsible Person: Teri Chapa (Program Manager) Expected Implementation Date: March 2023

2022-003 Eligibility ? Internal Control Over Eligibility City?s Corrective Action Plan: For the cases identified, the auditors focused on a feature of the Intake System (Yardi) that allowed a reviewer to make modifications to the reported income. As part of the review process, conducted by a separate entity (El Concilio - Contractor) a number of documents (including income verification) were reviewed to ensure that the household was eligible for funding under the program. In all instances, the income was reviewed and determined to be under the eligibility threshold; however, the ?Monthly Income Correction? feature in the Intake System was utilized to make an income determination of $0. The ?Monthly Income Correction? feature being utilized does not mean that the income was not accurately verified for any of the cases. In none of the cases sampled did the households have income that was over the established income limits. Funding for this program has been fully disbursed as of December 2022. Responsible Person: Jordan Peterson (Program Admin), Raquel Chavarria (Fiscal) Expected Implementation Date: May 2023

2022-004 Procurement and Suspension, and Debarment ? Internal Control over Verification Against the System for Award Management (?SAM?) City?s Corrective Action Plan: The City conducts debarment checks but has not been previously documenting the verification. The procurement department has been alerted to this requirement and has changed their process to include documentation of the suspension and debarment checks. Responsible Person: Alexandria De Lashmutt (Procurement Supervisor) Expected Implementation Date: May 2023

2022-006 Special Tests and Provisions ? Internal Control and Compliance over Obligation, Expenditure, Payment Requirements City?s Corrective Action Plan: When invoices from subrecipients are received, they are reviewed thoroughly by staff. Documentation sent may range from a few pages to several hundred pages. The larger the packet submitted, the longer the review process. In the review process, it may be determined that the information sent is not sufficient to support the claim/amount for reimbursement. This initiates a back and forth between staff and the subrecipient that could take up to several weeks to resolve. The department continuously holds workshops with all vendors/subrecipients on best practices, and invoicing procedures to cut down on the time spent reviewing invoices. The department makes great effort in working with all subrecipients to expedite documentation review and payment process and continues to make great improvement in this area. Staff will also maintain records of any delays in processing as a result of insufficient documentation submitted by the subrecipient. Responsible Person: Julisa Villalobos (Program Admin), Raquel Chavarria (Fiscal) Expected Implementation Date: July 2023

2022-002 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: We recommend that the School Corporation ensures that documentation of Procurement's decisions on any purchases that are excluded from the requirements noted in the Procurement Policy are retained for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was an unusual situation and will be corrected. The procurement transaction in question was originally include in a large building project and would not have been paid with federal dollars. Due to issues with the general contractor, timeliness of completion, and the beginning of the school year, one portion of the project in the school kitchen was pulled from the general contractor and a quote was obtained from one vendor. Quotes from at least three (3) vendors and documentation of any unusual circumstances will be maintained for auditor review. Name(s) of the contact person(s) responsible for corrective action: Louise S. Smith and Jennifer Niese Planned completion date for corrective action plan: March 31, 2023

CORRECTIVE ACTION PLAN For the Year Ended September 30, 2022 January 24, 2023 Move United (the Organization) respectfully submits the following Corrective Action Plan for the year ended September 30, 2022. Name and address of independent public accounting firm: CST Group CPAs, PC 10740 Parkridge Blvd, Fifth Fl Reston, VA 20191 Audit period: 10/1/2021 ? 9/30/2022 The findings from the Schedule of Findings and Questioned Costs for the year ended September 30, 2022 are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section III ? Federal Award Findings and Questioned Costs Significant Deficiency: 2022-02 ? Timely Submission of Quarterly SF-425 Report Recommendation: We recommend that the Organization review its monitoring process for the quarterly reporting of SF-425 reports, and ensure reports are filed timely within the requirements of the reporting deadlines. If an extension is necessary for any instances of reporting, a request for extension should be filed with the federal agency, along with a justified explanation for the additional time needed. Otherwise, all quarterly reports should be filed timely no later than 30 days after the end of each calendar quarter. Views of Responsible Officials and Planned Corrective Action: Move United will put in place a three tier redundancy plan for ensuring that filings, both within the VA Salesforce system and within the Payment Management System, are filed prior to or on time each quarter. The Chief Financial Officer, Programs Director and Grants Administrator will work collaboratively to complete the necessary data compilation at least one week prior to the filing deadline. All three individuals will be trained on and have access to the two systems. In the event one individual is incapacitated at the time of filing, one of the other two will complete the filing on time. Person Responsible: Chief Financial & Operating Officer Planned Completion Date: Immediately

"Finding No. 2022-004: Inadequate Controls Over Subrecipient Monitoring of Nutrition Service Providers Corrective Action Plan: DHS LTSS in partnership with Budget and Finance will review and enhance internal controls to ensure adequate policies are in place for subrecipient monitoring of nutrition service providers. DHS LTSS will ensure that monitoring procedures for nutrition service providers are consistently applied and adequately documented. These procedures will include documentation tying pre-award risk assessments to the monitoring procedures to be performed for all subrecipients, including tribal governments, and properly follow up on any issues identified with subrecipients as a result of monitoring performed. Contact Person: Jeff Overcash, Chief Financial Officer, Heather Krzmarzick, Director of Long-Term Services, and Supports Greg Evans, Audit Manager Anticipated Completion Date: June 30, 2023"

Finding Reference Number: SA2022-002 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP2014 ? Name(s) of the contact person: Marsha Ley ? Corrective Action Plan: City Finance Staff will notify all departments which are managing Federal Grants that prior to entering into subawards and contracts with Federal award funds, City?s Departments must verify that recipients/vendors/contractors are not suspended or debarred. All verification support/evidence should be saved for future reference and audit. ? Anticipated Completion Date: June 30, 2023

Compliance requirement ? Earmarking Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because all initiatives and expenditures related to the HEERF funds were precisely and strictly used to monitor, suppress the COVID-19 emergency and additionally to outreach students about the opportunity to receive financial aid, (and they indeed received) due to recent unemployment and financial hardship during the pandemic times. Part of this initiatives were documented in our web page and disseminated through e-mails, phone calls, word of mouth among the community. The institution followed the recommended state and federal government guidelines on maintaining an active program to prevent and respond to the COVID-19 emergency. The institution uses HEERF funds to establish and maintain the following preventive and suppressing measures to fight the COVID-19 emergency, among others: a. Screening temperature b. Purchase covid test kits c. Created and posted many warning banners and instructions d. Purchase prevention and protection supplies for students, faculty, visitor and staff a. Hand sanitizer b. Alcohol auto sprayers c. Face Shields d. Thermometers e. Protective plastic shields for the desks e. Implemented remote education a. Habilitated smart educational rooms for remote education i. Smart TV's ii. High quality microphones iii. Acquired "Zoom" platform licenses iv. Laptops for remote education f. Provided student financial aid to support recent unemployment g. Provided counseling and psychology services to assist students to deal and recover from the emergency. h. Supported a clean and sanitary campus environment with hand sanitizers, handwashing stations, cleaning and disinfection. i. Implemented physical distance j. Keep continued communication with students k. Paid for time off to get vaccinated l. Provided sick leave for COVID treatment and to get vaccinated m. Procured additional space for remote education n. Support costs associated with remote education for students providing laptops and remote communication equipment and hardware Actions Taken or Planned: The institution understands that no further action is necessary or required.

Compliance requirement ? Allowed Cost /Cost Principle Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the referenced transaction was below the "Micro-purchase" threshold and does not require a quotation. The FAR increase the "Micro-purchase" threshold for natural disasters and national emergencies, among others. The invoice amount of $5899 was a continuation of an initial project under this contractor which have the unique security passwords, IT protocols and other IT requirements for the uniform implementation of intelligent classrooms for remote distance education. Accordingly, the institution does not request a quote. The institution followed the referenced guidelines in the determining the allowability of costs. Additionally, an external consultant reviewed the transaction and costs prior to request reimbursement. The 2 CFR Part 200, Appendix XI Compliance Supplement guide, issued April 2022, makes referenced to the FAQ's and Other Guidance containing information pertinent to the compliance requirements described in the document and encouraged auditor to regularly check the HERF Websites for updated FAQ's and other pertinent guidance and reporting information. The institution followed those referenced FAQ's and guidelines, among other sound administration practices, in the use of the grants. The referenced Compliance Supplemental, under "Activities Allowed or Unallowed" states: "Institutions must demonstrate that costs incurred are allowable under the relevant statutory provision and consistent with the purpose of the ESF "to prevent, prepare for, and respond to coronavirus"". The institution used $5,899 paid to the guidelines as indicated to contractor, to continue enhancing the distance learning program in preventing the spread and contamination of the coronavirus among professors and students by enabling remote distance education. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 2. The institution does not concur with the auditor finding because of what is discussed in No 1 above. In the two cases mentioned, the cost quote may not agree with the invoice, because of some additional services requested, but the amount of the invoice was the correct amount paid and actual cost used to draw the HEERF funds. These invoices were for furniture and partitions divisions, to enable the remote distance education, avoiding physical contact of students and professors, to prevent, prepare for and respond to the COVID-19 emergency. Once again, these incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines. 3. The institution does not concur with the auditor finding. The referenced three cases may not have a specific or expressed "acknowledgement of receipt" statement, but the acknowledgement was validated by UTC management and with the signatures when the check was issued. Nevertheless, the costs incurred in these invoices were authorized and incompliance with HEERF program and ESF purpose. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 4. Institution does not, firmly, concurs with the auditor finding. This should not even be a finding because the institution strictly followed the FAQs published on March 19, 2021 to calculate the lost revenue and using a comparison between FY-20 and FY 21. That guideline described "Loss of Revenue" as "...those revenues and institution of higher education otherwise expected but were reduced or eliminated as a result of the novel coronavirus 2910 (COVID-2019) pandemic. As such, lost revenues can only be estimated". Nerveless, the result would have been relatively the same if we have use FY21 audited financials. Given the many factors and complexities of the unusual process, the institution followed a conservative approach and reduced those revenue items that have an increase between fiscal year from those with a loss of revenue. Therefore, the institution netted the potential amount of lost revenue to claim. Accordingly, the net amount resulted in $280,929.84. The potential loss of revenue amount could be greater but the institution decided to only claim the referenced estimated amount. These calculations and analysis were further discussed and evaluated by an officer of the Department of Education, with no recommendation on claiming a higher amount because the amount claimed was less than the estimated potential. The guideline indicates: "Reimbursement for lost revenue is allowable for the Institutional Portion program...". The institution claimed this loss of revenue amount from their institutional portion, complying with the HEERF guidelines and the authorized use of the funds. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. a. The institution used unaudited figures for FY21 because the audited financial statements were not completed at the time of the calculation. The institution revised the calculations with the audited financial statements, and the results were the same and the claimed estimated amount did not changed. Once again and in accordance with the guidelines, we were estimating the lost revenue with the data available at the moment. b. The institution followed the recommended HEERF guidelines for this complex and novel exercise. The institution considered under the analysis; those revenues otherwise expected but that were reduced as a result of the novel COVID-2019. The contributions as "Support Revenue" from related entities, which were a significant source of revenue for the institution, was not claimed as loss of revenue. The institution specifically claimed those lost revenue items as authorized in the guidelines. Therefore, once again, the UTC was in compliant with the lost revenue referenced guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. c. As explained above, the institution followed a conservative approach and only claimed a net amount of all lost revenue items. The institution only claimed those estimated revenue items, as authorized in the guideline, that suffer a loss between the two fiscal years considered in the evaluation. This was further evaluated by an officer of the DOE. As the guidelines described, since the lost revenues can only be estimated, the institution correctly, analyzed and calculated the best conservative/reasonable estimate of loss revenue with the available data at the moment. Even if we used the auditors' recommended items, the results would have been the same and no revenue item was claim out of the authorized or allowable costs from the guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. Actions Taken or Planned: The institution understands that the incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines and no further was required.

Compliance requirement ? Reporting Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the institution strictly followed and used the recommended HEERF methodology and reporting guidelines to prepare the quarterly and annual reports. Since the institution used the reimbursement method, the drawdown were the actual expenditures/costs incurred and requested for reimbursement. The HEERF reporting requirement does not make any indication nor reference to GAAP. The Institutional aid portion expenditures were supported by the proper invoice or check. The evidence was available to the auditors. 2. The institution concurs with the auditor finding. The institution inadvertently, did not include a line item from one of the quarterly reports. The period to make corrections was closed and we sent an e-mail to the department to amend this annual report. 3. The institution concurs with the auditor finding. The annual report contains detail statistical information that not necessarily is supported by our institutions data base and programs. As the ED expressed, this information was unique and challenging, and accordingly, the institution made some reasonable estimates and derivatives in the information provided. As you may notice in the referenced table by the auditor, the differences were minimal. 4. a. The institution concurs with the auditor finding on the difference in Item #5 of the quarterly report. The institution will accordingly amend the report. b. The institution does not concur with the auditor finding on the timely and accurate reporting in publicly posting the quarterly Student Aid Portion. The four quarterly reports were timely submitted with an e-mail to the HEERF reporting staff and timely posted in the institution web page as required by the HEERF reporting instructions. The reports were further reviewed by an officer of the Department of Education (ED). The ED expressed that this information may be unique and challenging to an audit, and indicated that for these public reporting requirements, the auditors may accept as evidence of compliance, contemporarily produced e-mails, webmaster logs, or other relevant documentation establishing good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements. Copy of the e-mails were available to the auditors as evidence of compliance. ED understands that this information may be unique and challenging to audit, particularly because auditors are asked to verify information posted on a webpage which may not be accessible during audit fieldwork. For these public reporting requirements, auditors may accept as evidence of compliance, contemporarily produced emails, webmaster logs, or other relevant documentation establishing a good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements (HEERF Grant Program Auditing Requirements, General Requirements and Information - All HEERF Grantees). 5. The institution does not concur with the auditor finding because the referenced payment was made in accordance with the Institution's fund distribution and the student financial needs, among other factors, at the time of the evaluation and distribution of the funds. The student financial circumstances may have change after the distribution and payments of the financial aid. Additionally, this is an immaterial amount as compare to the total amount of the funds distributed ant the quantity of students served (1 out of 460). Actions Taken or Planned: The institution understands that no further is needed or required.

1. The institution does not agree, nor concurs, with the auditors on this finding because the institution used the reimbursement payment method. This method was the preferred one when the non-federal entity, as our institution, cannot meet the requirements in 2 CFR, section 200.305(b)(1) for advance payment and the federal awarding agency sets a specific condition for use of the reimbursement. Title 2 of the CFR Part 200.305(b)(1), establish among others: "The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part". Furthermore, 2 CFR Part 200.305(b)(3) states: "Reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. " Since our institution was not able to meet 2 CFR, section 200.305(b)(1), and the HEERF guidelines has specific condition on how to use the funds; we choose the reimbursement method in the execution of the funds. Our institution adopted all HEERF instructions and guidelines as their policies to comply with the HEERF requirements, in addition to the CFR's regulations. Below some of the guidelines, instructions ad FAQs we adopted followed" a. Higher Education Emergency Relief Fund III, Frequently Asked Questions, American Rescue Plan Act of 2021, Published May 11, 2021, Questions 7 and 11 updated May 24, 2021, Question 36 updated September 30, 2021 b. US Department of Education, Notice of Proposed Institutional Eligibility Criteria, February 25, 2021 c. Federal Register Notice of Interpretation (NOI), regarding Period of Allowable Expenses for Funds Administered under HEERF Program, March 22, 2021 d. HEERF Notice of Interpretation for Period of Allowable HEERF Expenses (March 22, 2021) e. HEERF Lost Revenue FAQs (March 19, 2021) f. HEERF Period of Allowable Expenses Grant Records Notice (March 19, 2021) g. HEERF Grant Program Auditing Requirements (March 8, 2021) h. CRRSAA HEERF II Section 314(a)(1) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) i. CRRSAA HEERF II Section 314(a)(2) Frequently Asked Questions (January 14, 2021) j. CRRSAA HEERF II Section 314(a)(4) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) k. HEERF I and HEERF II Comparison Fact Sheet (Published January 14, 2021 and Updated: March 19, 2021) 1. HEERF Lost Revenue FAQ's, Published March 19, 2021 m. HEERF II, Public and Private Nonprofit Institution (a)(2) Programs (CFDAs 84.425K), FAQ's, Published January 14, 2021 n. HEERF II, Proprietary Institution Grant Funds for Students (CFDA 84.425Q) ((a)(4) Program), FAQ's Published January 14, 2021, Updated March 19, 2021. o. HEERF II, Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F), FAQ's Published January 14, 2021, Updated March 19, 2021. p. CAREST Act HEERF Rollup FAQs (issued October 14, 2020 and revised November 20, 2020) q. CARES Act HEERF Round 3 FAQs (Issued October 14, 2020 and revised November 20, 2020) r. CARES Act HEERF Supplemental FAQs (Issued June 30, 2020 and revised September 08, 2020) s. CARES Act HEERF Student FAQ's (Issued May 15, 2020) t. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) u. CARES Act HEERF Emergency Financial Aid Grants to Students under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) v. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, Issued April 9, 2020 w. COVID-19 FAQ's for Title III, IV, V and VII Grantees, June 16, 2020 x. COVID-19 Letter to HEP Grantees on Flexibilities Available Under CARES Act Section 3518, July 1, 2020 2. The institution does not agree, nor concurs, with the auditors on this finding because, as we mention in number 1 above, the institution adopted and followed the federal award and HEERF guidelines in the execution of the funds. The HEER funds were provided during the special national emergency caused by COVID-19. The DOE and HEERF officials issued many written guidelines, instructions, and FAQ's (Frequently Asked Questions) documents, due to the nature and novel of the national emergency situation. The institution adopted, followed, and relied on the many referenced guidelines and exercise extreme judgment to ensure compliance with the federal requirements and use of the funds. The institution belief this referenced guidelines and instruction were very specific and sufficient to execute the use of the funds. All direct charges to federal awards were for allowable costs under the guidelines and instructions from the Department of Education. Some of the allowable costs were verified and validated by an officer of the Department of Education and reviewed by an independent consultant. 3. The institution concurs with the auditor finding. Actions Taken or Planned: The institution begins in addition to the adopted HEERF guidelines, instructions, and CFRs; to develop additional procurement policies and are in the process of completing those policies. The institution expects to have those completed by May 31, 2023.

Compliance requirement - Special tests and provisions ? Gramm-Leach Bliley Act- Student Information Security Institutional Comments on Findings and Recommendations: (a) The institution agrees with the auditor on this finding. The Information Security Program Coordinator's functions were not specified in a formal written contract, therefore, the consultant does not have a detail for the functions and responsibilities of his designation. (b) The institution agrees with the auditor on this finding. The Institution has yet to comply with, needs to terminate and correct some of the nine elements that are included in the FTC (Federal Trade Commission). Actions Taken or Planned: 1. A contract with the IT Program Coordinator is being finished with a breakdown of the responsibilities expected for the GLBA requirements. We should be starting it in May 2023. 2. There has been progress in the action plan where a set of estimated time of completion is provided. We will keep doing so and monitor every aspect of the risk assessment to cover and safeguard each area found with a document that indicates any advances. 3. The Institution with the IT Coordinator will keep monitoring each step for the progress and any delay with a task report where it will show any advance or delay for the pending findings so that we can track the development closely until finished. 4. Finally, we will continue with the efforts to document and complete the corrections to the risk assessment results.

Compliance requirement ? Special test and provisions - Return of Title IV Funds Institutional Comments on Findings and Recommendations: I. Compliance Requirements ? Applicable After a Student Begins Attendance: a. The institution agrees with the auditors on this finding in which there were two (2) cases where the auditors noted that the institution failed to determine that the students withdrew within 14 days after the student's last day of attendance. II. Compliance Requirements ? Applicable for a student who does not begin attendance: b. The Institution agrees with the auditors on this finding in which there was one (1) case were the student did not comply with the Incomplete course requirement and an unofficial withdrawal was not performed. Before the audit process was completed, the institution performed a R2T4 calculation and returned to the US Department of Education, the $439.00 associated with this finding. This process was evidenced to the auditors for their records. c. The Institution agrees with the auditors on this finding in which there was one (1) case were the student had stopped attending the enrolled courses without completing at least 60% of the payment period. Before the audit process was completed, the institution had returned to the US Department of Education, the $581.00 associated with this finding. This process was evidenced to the auditors for their records. d. The institution agrees with the auditors that in the cases mentioned in item b and c in that it failed to determine that the students withdrew within 14 days after the student's last day of attendance. e. The institution agrees with the auditors that in the cases mentioned in item b and c in that it failed to return Title IV funds after the 45 days' time frame. Actions Taken or Planned: The institution is aware of the importance to comply with Return of Title IV funds (R2T4) reporting requirements and deadlines. Also, the relation to students last day of attendance (date of withdrawal) vs date of school's determination that the students withdrew and the date of the return of any Title IV funds resulting from an R2T4 calculation. The issues as related to these findings were identified as ones being an oversight and lack in compliance with some of the academic processes as required by R2T4 and has already been discussed with the Academic Dean of the institution who in turn has revisited these matters with Faculty and administrative staff under her supervision including the Registrar. The already instituted task force that meets every Friday of each week to identify and review cases that could affect the R2T4 procedure and requirement has continued to review and evaluate information received from the faculty through the Academic Dean and from information the Registrar's office receives of students that are not attending classes in order to process all applicable withdrawals to assure that the return of Title IV funds procedures and the return of funds if any, are processed timely within the 14 days requirement of the student's last day of attendance and within the 45 days from the date that the institution determined that the student withdrew. Before the audit process was completed, the institution had returned to the US Department of Education, the $439.00 and $581.00 associated with this finding. This process was evidenced to the auditors for their records.

The Organization will continue to implement the following measures to ensure compliance with the sliding fee discount program, and consistently assess patient income and family size. The Organization will continue to provide on-going training to clinic staff who evaluate the sliding fee application at its clinic locations. The training consists of reviewing sliding fee program policies and procedures along with all applicable patient forms, sliding fee scale, and patient eligibility. The following quality control measures to ensure compliance will be implemented: 1. Front Desk Peer Review of sliding fee application and verification of patient income and family size. 2. Enhance training materials to support Front Desk Staff with assessing sliding fee applications. 3. Quarterly feedback to Front Desk Staff based on sliding fee applications reviewed. Person Responsible: Kristopher D. Zuniga Position of Responsible Party: Chief Financial Officer Anticipated Completion: April 30, 2023

Corrective Action Plan Manufacturing Extension Partnership Year-Ended September 30, 2022 Finding #2022-001: Type of Finding: Noncompliance Responsible Person Joey Massey, Director of MEP Implementation Date January 30, 2023 Views of responsible officials and planned corrective actions: ATN agrees with the finding and recommendation. As a result, ATN immediately submitted the FY22 Federal Funding Accountability and Transparency Act (FFATA) subawards in the FFATA sub-award reporting system (FSRS). Furthermore, ATN will implement procedures to ensure subawards will be reported in the FSRS system on a timely basis as required hereafter.