Corrective Action Plans

In the summer of 2024, the Organization adopted a procurement policy compliant with the Code of Federal Regulations 2 CFR 200.214. The policy was formalized, announced, and implemented with the entire Organization's staff. At this time, all current contractors of federal grants were reviewed for eligibility by reviewing them against the debarred, suspended and otherwise excluded list. Management recruited a procurement officer in December 2024 to design and implement best practice procurement processes effective the first quarter 2025. Procurement policies will ensure full compliance with Federal and State requirements. Procurement policies will incorporate clearly defined procedures around all contractors ensuring appropriate selection processes and contractual terms. Anticipated completion date: March 31, 2025

Management recruited a procurement officer in December 2024 to design and implement best practice procurement processes effective the first quarter 2025. Procurement policies will ensure full compliance with Federal and State requirements. Procurement policies will incorporate clearly defined procedures around all contractors ensuring appropriate selection processes and contractual terms.

FINDING NO. 2023-002 - TRANSFER OF FUNDS BEYOND THE REQUIRED TIME LIMITS CONDITION During our field work in the cash management area, we noted funds that were requested to G-5 but not disbursed by UPM to minimize the time elapsing between the transfer of funds and disbursement as follows: Descriotion Dates Amount Funds received from G-5 on June 8, 2022 6/8/2022 $610,710.35 Funds disbursed during 2022-2023 Fiscal vear 2022-23 (525,362.27) Available balance from funds received in 6/8/2022 6/30/2023 $75,348.08 Funds received from G-5 on June 22, 2023 6/22/2023 $319,251.71 Funds disbursed at the end of fiscal year 2022- 2023 6/30/2023 (45,000) Available balance from funds received in 6/22/2023 6/30/2023 $274,251.71 RECOMMENDATION The University should reinforce the procedures the draw down of funds to comply with the regulation applicable for the transfer of funds through the G-5 system. Corrective Action Plan: "Corrective Action Plan: UPM acknowledges that recommendation 2023-002 by Mr. Santiago is correct; however, the Dean of Administration and Finance, who assumed this position on February 21, 2023, wishes to explain the reasons behind this occurrence. UPM managed the HEERF funds without prior experience and knowledge of their administration. The officials at that time were unclear about the rules and procedures for managing these funds because the contract details were not received by UPM, preventing them from establishing spending and disbursement policies. Additionally, UPM was without a president for 6 months, and after appointing a president, it operated for approximately a year without a permanent Dean of Administration and Finance. The employees in the Dean's office were not authorized for this level of decision-making, while time continued to pass. Furthermore, there were several changes in the members of our Higher Education Council. As soon as the Dean of Administration and Finance was appointed, consultations with the president were held to make decisions regarding the disbursement and expenses of these funds, which were implemented in June 2023. As a corrective action plan for the future, we will review all certifications related to federal funds management, prepare a comprehensive folder, and administer these funds while adhering to each of these measures. We will proactively identify our needs and align them with the award, clearly defining each process and protocol with the intention of compliance." During the last fiscal year. the Council of Theological Education approved new regulations for: 1. Regulation for the Acquisition of Equipment, Materials, and Non-Personal Services at UPM. 2. Regulation for the Administration of Movable Property (Equipment) at the UPM. hese new regulations complement the existing rules to ensure the integrity, preservation, accessibility, legibility, and legality of our financial actions. We will continue to work together to standardize our processes and address any non-compliance on our part.

2022-002 Equipment and Real Property Maintenance ? Education Stabilization Fund CFDA No. 84.425 Contact Person: Colette Vickers, Business Manager Recommendation: The District has developed a specific set of procedures to ensure the proper inventorying and safeguarding of real property and equipment. We recommend the District adhere to these procedures, and have written policies in place to ensure this is not overlooked in the event of changes in personnel. Action: The District will review the equipment and real property maintenance procedure with appropriate personnel. These employees will be required to review the policy at a minimum once a year and acknowledge through signature that they have been made aware of the procedure. These signature records will be maintained with their annual training records. Inventory updates and lists will be reviewed at least quarterly by administration to ensure compliance. Date for Completion: June 30, 2023

U.S. Department of Education 2022-002 21st Century Community Learning Centers ? Assistance Listing No. 84.287C Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review amounts charged to the grant prior to submitting for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A new Chief Financial Officer was hired in March 2022 with appropriate expertise to evaluate financial reporting processes and controls. Additional controls over the preparation of financial statements to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP have been implemented.. Name(s) of the contact person(s) responsible for corrective action: Jerri Kautsky Planned completion date for corrective action plan: completed as of date of audit report, December 8, 2022. If the U.S. Department of Education has questions regarding this plan, please call Jerri Kautsky, CFO, at 239-255-7223.

REFERENCE # 2022-004 CASH MANAGEMENT – MATERIAL WEAKNESS- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Non-Federal Entities Other Than States- Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition/Context: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Questioned Costs: Cannot be determined Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Corrective Action Plan: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710