Corrective Action Plans

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

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

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

Cash Management Management agrees with the finding and the auditor's recommendation. There was confusion at the time of this agreement as the nature of the work was in line with providing institutional services rather than a federal grant agreement. This led to a misunderstanding of cash management requirements due to the nature of the award. Mass General Brigham (MGB) has removed the $215K of questioned costs from the Schedule of Expenditures of Federal Awards (SEFA). The funding will be returned to Advanced Regenerative Manufacturing Institute, Inc. in January 2025. Additionally, management will review the limited instances where departments have been previously approved to request federal cash. This review is to confirm that an exception to the standard practice of managing this through the central Research Finance team is appropriate. Based on results of this review, to be completed by March 2025, management will determine criteria and prior approval requirements for departments to request federal cash if MGB concludes this practice will continue on a limited exception basis. The review will be conducted with oversight by the MGB Vice President of Research Management and Research Finance and the MGB Research Controller.

The District will have a policy to never hold checks or prepare checks prior to completion of applicable work. Checks will be sent out immediately upon approval by the Board of Education. Furthermore, the District will ensure there is proper oversight to ensure checks are not being held.

2024-001: Reporting This finding is the result of human error when completing the Fiscal Operations Report and Application to Participate (FISAP). An extra digit was added to the tuition/fees charged, changing the tuition and fees charged from $6,880,369 to $68,880,369. This was missed in the review of the FISAP prior to submission. Corrective Action: The Financial Aid Office took great care in reviewing the 2023-2024 (for 2025-2026) FISAP for accuracy. Additionally, the amount requested for SEOG and FWS is the exact same as requested on the 2022-2023 (for 2024-2025) FISAP, rather than the inflated fair share. The Financial Aid Office will request up to the fair share on the 2024-2025 (for 2026-2027) FISAP. This issue has been successfully addressed. Anticipated Date of Correction: 9/30/2024 Contact Person: Shanna Vargas, Director of Financial Aid

2024-002: Reporting This finding is a result of transferring Primary Data Point Administration from Amy Murphy to Shanna Vargas. Part of this issue reflected SAIG/CPS/COD/NSLDS access from being set up correctly and resulted in many hours of contact and meetings with SAIG professionals to correct. Corrective Action: The Financial Aid Office has worked with SAIG professionals to correct this issue. The Financial Aid Office has developed a schedule and process to complete monthly direct loan reconciliation, as well as ensuring other members have access to complete this should the PDPA’s access not be available. Anticipated Date of Correction: Immediately Contact Person: Shanna Vargas, Director of Financial Aid

2024-005: Enrollment Reporting Unofficially withdrawn students (students who failed to earn credit during the term) are reviewed after the end of the semester, and R2T4 is calculated, where required. However, there was not a process in place for the Registrar to update the Enrollment Reporting as a result of the review process. Corrective Action: As part of the process of reviewing these students and performing the R2T4 calculation, the Financial Aid Office will send a report of unofficially withdrawn students to the Registrar to ensure that enrollment reporting is appropriately updated. Anticipated Date of Correction: Immediately Contact People: Shanna Vargas, Director of Financial Aid, and Kayla Miller, Registrar

2024-004: Return of Title IV Funds This student’s late calculation was due to the failure to review withdrawal reports during the changeover in director responsibilities. All students that fail to earn any credit during the semester are reviewed at the end of each semester. This student was found at that point, and the calculation was completed. Corrective Action: The withdrawal report is reviewed at minimum each week by the Financial Aid Office and R2T4s are calculated timely. This issue has been resolved. Anticipated Date of Correction: Immediately Contact Person: Shanna Vargas, Director of Financial Aid

2024-003: Cash Management This finding is the result of transferring Primary Data Point Administration from Amy Murphy to Shanna Vargas. Corrective Action: The Financial Aid Office has developed a schedule and process to complete monthly direct loan reconciliation, as well as ensuring other members have access to complete this should the PDPA’s access not be available. Anticipated Date of Correction: 8/19/2024 Contact Person: Shanna Vargas, Director of Financial Aid

Finding No.: 2023-038 AL Program: COVID-19 84.425H – Education Stabilization Fund – Governors (Outlying Areas) (ESF-Governor) Area: Subrecipient Monitoring Questioned Costs: $6,641,757 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-2: The CNMI Department of Finance agrees with this finding. CNMI submitted risk assessment and monitoring compliance documentation to the auditor on February 26, 2026, after the agreed February 19, 2026, deadline, resulting in evidence timing deficiency. CNMI established Standard Operating Procedures for subrecipient monitoring effective October 28, 2026. Management will implement standardized file labeling and retention procedures in accordance with the SOP so that each subrecipient file contains the subrecipient determination, required subaward clauses, the unique entity identifier, documented SAM.gov exclusion checks, and verification of audit requirements. In alignment with 2 CFR §200.332, CNMI will review financial and performance reports quarterly, conduct an annual performance assessment using a standardized checklist (updated annually or upon project completion), maintain documentation of all monitoring activities, and verify audit status for entities subject to the Single Audit Act. The risk assessment and monitoring compliance documentation for this grant is available to the auditor upon request. Proposed Completion Date: Completed

Finding No.: 2023-034 AL Program: COVID-19 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Subrecipient Monitoring Questioned Costs: $15,640,541 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-3: The CNMI Department of Finance agrees with this finding. During FY 2023, the Department of Finance became aware that existing practices for subrecipient monitoring did not fully meet federal requirements under 2 CFR 200.331–200.332. DOF began implementing corrective actions in the latter part of FY 2023 and continued strengthening procedures throughout FY 2024, including improvements in documentation, SAM.gov verification, and basic risk assessment elements. In response to these identified gaps, the CNMI formally adopted comprehensive Subrecipient Monitoring Policies and Procedures effective October 28, 2025, which fully incorporate federal pass through entity requirements and include standardized processes, templates, monitoring tools, and clear definitions. These procedures were not applied retroactively; however, they are fully in place for FY 2025 and ongoing operations. Finding No.: 2023-034, continued AL Program: COVID-19 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Subrecipient Monitoring Questioned Costs: $15,640,541 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: As a result, while we anticipate partial improvement and reduced findings for FY 2024 due to incremental implementation of best practices, we do not expect subrecipient monitoring findings beginning in FY 2025, as the adopted SOP directly addresses all elements identified in the FY 2023 audit finding. Proposed Completion Date: Ongoing

Management’s Response or Department’s Response The County agrees with the finding and recommendation. Views of Responsible Officials and Corrective Action Plan The County will implement a formalized monitoring program and agreement template to identify subrecipients based on criteria in § 200.332. The County will provide a comprehensive training to program managers to implement the monitoring program and subrecipient agreement template. In addition, the County will include direction to project managers to review current awards to identify existing subrecipients that were not provided a subrecipient agreement with all of the required elements from CFR § 200.332. Anticipated Completion Date/Completion Date June 30, 2026 Contact Information of Responsible Official Name: Donald McNair Title: County Clerk & Auditor-Controller Phone: 209-533-6593

The County Board is continuously monitoring award recipients and bas a process established that prevents disbursement of fonds until proof of use is provided to the County Board.

2023-006 Cash Receival – Proper Procedures Recommendation: Auditors recommend that CIES modifies its internal control policies for general review and approval of the reporting requirements set forth by the criteria listed. Criteria: 2 CFR 200.8(a) – Federal agencies responsible for ensuring that specific Federal award conditions and performance expectations are consistent with the program design. 2 CFR 200.208(c)(1) Specific conditions may include requiring payments as reimbursements rather than advance payments. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: As feasible, CIES will implement proper procedures and controls surrounding the receival of cash to ensure proper segregation of duties for funds received. Cash, including checks, received will be received and deposited by one of the CIES’ administrative staff and a different CIES’ administrative staff member will enter the data into the CIES’ financial records. Verification of entry and deposit will be conducted through monthly reconciliations of bank accounts. Name(s) of the contact person(s) responsible for corrective action: Michael Parker, Executive Director Planned completion date for corrective action plan: March 2026

Finding Number: 2023-002 Planned Corrective Action: City Auditor has confirmed the ARPA 3/31/24 and 3/31/25 Project and Expenditure Reports submitted agree to City Accounting records. Anticipated Completion Date: July 3, 2025 Responsible Contact Person: City Auditor Sherri Hess

FINDING 2023-004 – Cash Management: Significant Deficiency over Internal Controls over Compliance Condition/context – The Organization draws down funds based on a profit and loss report to signify the excess expenses incurred over the grant revenue. The Organization identifies themselves as on the reimbursement method. The request for reimbursements are not reviewed to ensure amounts have been paid with the Organization’s funds prior to the reimbursement request because certain expense codes do not relate to expenses paid but rather expenses incurred. Additionally, the frequency of draws during mid-months creates potential for errors when the reporting period has not been reconciled and therefore coded expenses are subject to change. Corrective Action Plan: Policy & Procedure adjustments within Cash Management: • Reimbursement requests will be based solely on expenditures that have been paid using the Organization’s funds. • Financial reports used to prepare draw requests are reconciled to ensure expense coding accuracy. • Expense codes distinguish clearly between paid and accrued expenditures. • Mid-month draws are avoided or subject to additional reconciliation controls prior to submission. Name of Contact Person: Chris Flaherty, Chief Executive Officer 707.890.6491 Laura Williams, Chief Financial Officer 707.335.0010 Projected Completion Date: December 31, 2026

• Review all files for completeness before submission to auditors starting FY2024 onward. • Enhance systematic filing and accessibility of drawdown reports and supporting documentation. • Note: Re-review located >90% of cited "missing" documents; underlying support was available. Tagging is not mandatory. 12/15/25 (SPAF submitted) / Ongoing 09/30/26 Ms. Christina Elnei, Asst. Secretary of National Treasury Email: christina.elnei@dofa.gov.fm

The Morgan County Economic Development Office acknowledges status reports submitted by the required due date for the CDBG program.

Finding Number 2023-096 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees with this finding. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. Finally, OMES Finance has developed processes which provide for a more thorough coding of expenditures and proper review of expenditures when reporting on their GAAP Z. The State disagrees with the finding. The State had two Grant Award Notifications in place with the Boys and Girls Club which reflects the monies awarded to be used on the capital improvements and Club on the Go Mobile Clubhouses. This indicates the funds were obligated during the covered period. Per the email from the Keri for Jill Geiger Consulting, no signatures on the GANs were required and the Uniform Guidance does not require the GAN to be signed. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

The Municipality Administration is committed to identify the control of deficiency that allowed for the deficiency to happen. Additionally, the administration is committed to implementing the correct control sturcture to prevent the situation from happening in the future. The Municipality Management will continue the search of supporting documentation of the highlighted transactions. New proposed contrl strucure to be evaluated by Municipality for adequacy. The Municipality ensures the compliance with the Disaster Grants disbursement policies.

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will provide training to personnel on the requirements and regulations related to subrecipient monitoring. Recommendation to management will be implemented, internal controls and compliance measures that allow for the identification, reporting, and monitoring of subrecipient activities Prevention Activities/TANF. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

Finding Number: 2023-002 Planned Corrective Action: City Auditor has confirmed the ARPA 3/31/24 and 3/31/25 Project and Expenditure Reports submitted agree to City Accounting records. Anticipated Completion Date: July 3, 2025 Responsible Contact Person: City Auditor Sherri Hess

Chairman of the Board of County Commissioners: Oklahoma County will comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Anticipated Completion Date: 6/30/2025 Responsible Contact Person: Myles Davidson, BOCC Chairman

Finding Number: 2023-002 Planned Corrective Action: The Chief Financial Administrator will ensure all ARPA expenditures are included on the Project and Expenditure Reports. Anticipated Completion Date: March 31, 2025 Responsible Contact Person: Ben Cowdery, Chief Financial Administrator