Corrective Action Plans

The Department has instituted additional internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. This includes a monthly reconciliation of all federal sources performed by the Grants Manager and reviewed by the respective Budget Manager and Finance Director to address any identified issues before the liquidation date. As a redundancy measure, the Budget Manager reviews AP contract activity associated with federal fund sources via the Provider Utilization Report to monitor the liquidation rate in correlation with the liquidation date to ensure all expenditures are captured within the period of performance. Post-liquidation date journal activity is mainly aligned with transactional code cleanup, not necessarily new expense posting outside the period of performance. As such, it doesn’t include or constitute changes to previously submitted federal reporting. To mitigate transactional errors, the Budget Manager, in coordination with the Grants Manager, thoroughly reviews the coding of procurement requests that utilize federal funds for the appropriateness of use and accuracy. This includes deactivating federal fund sources in the statewide accounting system to prevent transactions posting outside of the period of performance. These additional internal controls related to the period of performance were implemented in July 2023. The Office of Internal Audit will perform a review of the updated processes to ensure they are effective in correcting the above findings no later than March 31, 2024.

In February 2024, DCH and a third party executed a contract amendment which incorporates the required provisions per section 7.1.3 of the NCCI Technical Guidance Manual.

DCH has implemented the programming changes in Georgia Medicaid Management Information System (GAMMIS) to recoup capitation payments dating back to April 1, 2023 for members who were deemed retroactively eligible for Medicare. For any current Managed Care Organization (MCO) member that gets retroactive Medicare coverage, that member’s MCO capitation payments are recouped back to the day before the effective date of the Medicare benefit or back to 4/1/23 whichever is later. A monthly report entitled MGD-4218-M captures the recoupment activity.

The Department acknowledges that some of the capitation rates in Georgia Medicaid Management Information System (GAMMIS) were inaccurate. The Department has completed the review of all capitation rates in GAMMIS from July 1, 2021. The Department will implement the following procedures to ensure capitation rates are accurate: (1) correct all inaccurate capitation rates in GAMMIS, (2) test rates in GAMMIS for accuracy prior to production and (3) re-process Per Member Per Month (PMPM) payments to correct inaccurate payments.

DCH revised it contracts with its CMOs to include the following language: 8.6.2 The Contractor shall submit to DCH audited financial reports specific to this Contract on an annual basis. The audit must be conducted in accordance with generally accepted accounting principles and generally accepted auditing standards. The above language was added to the DCH contract in June 2022.

The Corrective Action Plan is as follows. The Georgia Department of Human Services (DHS) is redesigning its Contract Development and Procurement processes. With the new design, the accountability for Federal Funding Accountability and Transparency Act (FFATA) reporting will be with a new Office of Procurement Services (OPS). The OPS resources dedicated to FFATA will be trained on all reporting requirements by DHS. The expected implementation of the new processes by December 2024.

DHS has established a process for ensuring all Open Market Purchases above $24,999.99 are directed to a competitive solicitation per the State of Georgia Procurement Manual. The new DHS Office of Procurement Services is accountable for monitoring all Open Market Purchases and the DHS competitive solicitation process.

Verbal direction was given initially in a meeting with the Contract Liaisons (construction auditors) and to the District Construction Managers to remind them that the Certified Payroll Review Form must be used. This will also be discussed at the District Construction Managers meeting in April and a memo is being distributed to the District Construction Managers and Contract Liaisons reminding everyone of the process. Contract Liaisons who audit the projects for contract compliance have been informed to make sure the Certified Payroll Review Form is being used. The use of the form and proper procedure for checking payrolls will be verified each time the project is audited. The Contract Liaisons have also been informed to let each of the construction managers know to use the form. Payroll review will also be incorporated into the Contract Liaison’s annual training so that the construction staff will be reminded of the process and to also inform and educate new employees of the process. The procedures to be followed are outlined in the Construction Manual. (excerpt below) The Construction Manager shall complete the Certified Payroll Review Form for ALL payrolls reviewed. The Form shall be complete with any observed issues documented in as much detail as possible and shall be signed and dated by the Construction Manager. The Construction Manager should compare the wage rates listed on the payrolls to the applicable wage rates listed in the Contract based on the job title of the Contractors/Subcontractors employee. The Construction Manager should place comments or check marks by each employee on the Contractor’s/Subcontractor’s payrolls as they are reviewed, and wages compared. Once a set of payrolls has been reviewed, the Construction Manager will print their name and current date in the top right-hand corner of the payroll and initial.

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Georgia Department of Labor did not maintain adequate controls over the identification, recording, and reporting of benefit overpayments associated with the Unemployment Insurance programs. GDOL Response: GDOL now freezes the overpayment data at the end of every month so we can conduct periodic reconciliation of the overpayment records. This will allow discrepancies to be identified faster and resolved before the deadline to submit the report for the specified period. GDOL consults with USDOL’s national 227 reporting specialists on an ongoing basis to work towards a reconciliation of previously submitted reports. Federal regulations require an actual person to review and establish fraudulent overpayments. Due to the volume of claims and the number of cross matches to be performed on all state and federal pandemic programs, it requires multiple GDOL staffing levels to manually review all cross matches, requiring increased levels of state and federal funding. The crossmatch process is conducted using software which runs a systematic check against weeks in a quarter for which benefits are paid and wages are reported during the same quarter. Although the program may detect weeks paid and wages reported, this alone is not indicative of an overpayment. Therefore, the process involves verification correspondence being sent to both the claimant and the employer, as applicable, to verify the status of employment, the wages earned as well as the weeks in which an individual worked and earned the wages. Based on responses, an assessment is made to determine if an overpayment exists and subsequent actions are taken accordingly. We are prohibited from assuming a match is an overpayment. It is not an overpayment until we have completed a full investigation and provided due process to all parties. GDOL developed an aggressive plan to complete all crossmatches. We are running cross matches on all the state and federal programs. The Department has a significant number of pending and potential overpayment investigations that may result in either a non-fraud or fraud determination. We are utilizing non-overpayment staff to assist with overpayment investigations. Additionally, we are utilizing temporary agency staff to perform some clerical duties; however, federal regulations prohibit non-merit staff from adjudicating and releasing overpayment decisions. We are slated to run our last accelerated crossmatch in March 2024 and will resume our regular crossmatch schedule in June 2024. Additionally, GDOL has procured a vendor to build and implement a modernized unemployment insurance (UI) system slated to be launched in 2026. We will continue to utilize available resources to investigate and establish overpayments in the legacy system as quickly as possible and will continue to do so within the program parameters in the new system. Summary: The current unemployment system is obsolete and cannot be remediated at this time Therefore, we acknowledge that this finding will persist until a system-wide resolution is implemented in the new modernized UI system. GDOL greatly appreciates the feedback and recommendations and will consider this information in our endeavors to modernize our UI system and business processes.

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Department of Labor should improve internal controls over Employer Filed Unemployment Compensation claims. GDOL Response: GDOL submits the following information as an overview of the employer filed claims program and actions that have been taken and will continue to address the findings as well as incorporate additional safeguards and available technological system controls in the new system: The Employer Filed Partial Claims (EFC) program originated in the late 1960’s and was designed to allow employers with short-term, temporary periods of lack of work for their employees to retain their workforce when work resumes. This is a program that many large manufacturers in Georgia rely on when they have temporary plant shutdowns and have for decades. When GDOL has attempted in the past to limit this program, we have met strong resistance from Georgia’s manufacturers. This program optimizes our ability to process and pay mass numbers of claims more quickly, such as what occurred at the beginning of the pandemic. EFCs may be filed by an employer for any complete pay-period week during which an otherwise full-time employee works less than full-time, due to lack of work only, and earns an amount not exceeding his/her unemployment insurance weekly benefit amount. Such claims shall not be submitted or allowed for vacation days regardless of whether such vacation days were requested by the employee or established by the employer. Effective March 19, 2020, a temporary, Emergency Rule 300-2-4-05(1), containing Rule 300-2-4-.09(1) was signed which required employers to electronically submit EFCs on behalf of their employees whenever it is necessary to temporarily reduce work hours or there was no work available for a short period due to the pandemic. Employers were allowed to file such claims for full and part-time employees whose earnings had been reduced. In July 2020, the Rule was sunset and employers were no longer required to file EFCs. By electing to submit EFCs on behalf of the individuals, the employer is responsible for attesting by an affidavit to the employment status and weekly earnings of the individual for the EFC submitted. The affidavit certifies that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded for their employees. Individuals for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rules 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be actively seeking work. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual’s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI Customer Portal dashboard provides all the EFC correspondence sent to the individual as well as the status of the profile setup and identify verification. Before the implementation of the EFC profile requirement, GDOL utilized the Social Security Administration (SSA) crossmatch and Systematic Alien Verification for Entitlement (SAVE) verification processes to verify the identity of claimants where employers submit claims on their behalf. When we identify employer fraud schemes, we follow the guidance issued by the United States Department of Labor (USDOL) and collaborate with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Effective June 29, 2023, GDOL implemented additional Employer Filed Claims safeguards and security measures to reflect amended Georgia Employment Security Rule 300-2-4-.09. Employers must now meet the following conditions to submit Employer-Filed Partial Claims on behalf of their employees: • Employer accounts must have been registered with GDOL for more than 5 years. • Employers must be current on all quarterly tax and wage reports. • Employers must be current on all quarterly contribution taxes, assessments, penalties, and interest. • The week ending date on employer filed claims cannot be older than 30 days. The amended Georgia Employment Security Rule also clarifies that part-time employees are not eligible for Employer Filed Partial Claims. Summary: This finding will persist until a system-wide resolution is implemented in the new modernized UI system. GDOL will include a self-certification and dual certification process for employer filed claims in the new solution.

GDOL acknowledges this is a repeated finding from previous years, therefore the Department concurs with this finding and offers the following response preceded by the auditor’s findings: Auditor’s Findings: The Georgia Department of Labor did not have effective internal controls in place to ensure unemployment benefit payments were made correctly and only to eligible claimants. 1) Claimants did not self-certify for benefits in eighteen instances GDOL Response: Employer Filed Partial Claims (EFC) are submitted by employers on behalf of the claimant. The employer is responsible for attesting to the employment status and weekly earnings of the claimant for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Claimants for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rule 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. We recognize the state auditor's recommendations to add the self-certification. However, the current unemployment system is obsolete, having been put into production in 1982. This finding will persist until our new modernized unemployment insurance (UI) system is implemented in 2026. 2) Fraudulent employer-filed claims were filed for thirteen claimants GDOL Response: When we identify employer fraud schemes, we follow the guidance issued by the United States Department of Labor (USDOL) and collaborate with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Additionally, we have taken the following measures to safeguard the system against fictitious employers: • Effective December 6, 2021, the Employer Filed Partial Claims (EFC) process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual’s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI Customer Portal dashboard provides all the EFC correspondence sent to the individual as well as the status of the profile setup and identify verification. • Before the implementation of the EFC profile requirement, GDOL utilized the Social Security Administration (SSA) crossmatch and Systematic Alien Verification for Entitlement (SAVE) verification processes to verify the identity of claimants where employers submit claims on their behalf. • Effective June 29, 2023, GDOL implemented additional employer filed claims safeguards and security measures to reflect amended Georgia Employment Security Rule 300-2-4-.09. Employers must now meet the following conditions to submit Employer Filed Partial Claims on behalf of their employees: o Employer accounts must have been registered with GDOL for more than 5 years. o Employers must be current on all quarterly tax and wage reports. o Employers must be current on all quarterly contribution taxes, assessments, penalties, and interest. o The week ending date on employer filed claims cannot be older than 30 days. The amended Georgia Employment Security Rule also clarifies that part-time employees are not eligible for Employer Filed Partial Claims. BPC and Integrity merit staff continue to establish pseudo claims when fraud is confirmed to relieve victims of liability and the fraudster is unknown. Otherwise, the payments are moved to the fraudsters claim account, if identified. GDOL has procured a vendor to build and implement a modernized UI system. We are also pursuing data analytics tools to expedite the identification and detection of fraudulent activities. These tools will also be incorporated into the modernized solution. 3) Proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by five Pandemic Unemployment Assistance (PUA) claimants. One of these claimants was not eligible to claim benefits in Georgia. GDOL Response: The claimants who established PUA entitlement with a weekly benefit amount greater than the minimum or later determined to not be eligible were based on wages entered by the claimant and/or wages reported by the employer. The Coronavirus Aid, Relief, and Economic Security (CARES) Act only required proof of wages to be submitted. If claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. Claims established at a higher weekly benefit amount had to be reduced to the minimum amount if no proof was provided. To date, no proof has been provided by the claimants cited. The claims were reduced as appropriate. An overpayment has been established on all five claims identified for the difference in weekly benefit amount for weeks paid over the minimum amount under CARES and for the entire amount for weeks paid under Consolidated Appropriations Act (CAA)/American Rescue Plan Act (ARPA). GDOL’s current UI Information Technology (IT) system was developed in 1982 using mainframe “legacy’ technology. Due to the system’s age and other limitations, many automated processes and corrections cannot be fixed and/or easily implemented. As such, many processes must be handled manually by staff. This includes reviewing all the PUA proof documents submitted to determine the validity and eligibility for each PUA claim. Based on the volume of workload and staff limitations, GDOL has been unable to quickly complete this manual review to correct the finding. It is anticipated this manual review will continue throughout the FY24 audit review period. Summary: GDOL’s limited technology resources will hinder our ability to update our current system to satisfy the state audit’s recommendation. Therefore, we acknowledge that this finding will persist until a system-wide resolution is implemented in the new modernized UI system. The new solution will include a self-certification and dual certification process for employer filed claims and include controls over eligibility determinations for current and future UI programs. GDOL greatly appreciates the feedback and recommendations and will consider this information in our endeavors to modernize our UI system and business processes.

As noted by Georgia Department of Audits & Accounts (DOAA) in this finding, the corrective action, although implemented for the last quarter of F/Y 2023, was effective in dealing with this issue as no additional exceptions were identified in the tests performed by DOAA after the date of the corrective action being put into place. GDOL will continue to ensure that all current and future business practices follow the established policies and procedures of the Uniform Guidance, the U.S. Department of Labor, and the State of Georgia. When necessary, GDOL will modify its policies and procedures to ensure that expenditures reflect appropriate evidence of review and approval.

GDOL concurs with this finding: Regarding the pandemic Grants noted that were all under #UI34710-20-55-A-13: • The unemployment insurance (UI) Regular Grant typically provides the amount of available grant funds in advance based on 1.) and estimated number of claims to be processed in the current year (based on the average of two years prior activity) and 2.) the average processing times (based on the average of two years prior processing times). • In contrast, many of the pandemic grants are based on actual claims activity with monies being awarded “after the fact” with no consideration given to the aforementioned criteria as no prior- year basis exists. • GDOL experienced delays in some pandemic allocations due to delays in programing and the submission of the new reports for pandemic activities (Federal Pandemic Unemployment Compensation (FPUC), Pandemic Emergency Unemployment Compensation (PEUC) and Pandemic Unemployment Assistance (PUA)). All late reports have been submitted and we are reconciling grants as deemed appropriate. • With reimbursement based on pandemic claims activity, there was no clear mechanism for GDOL to be able to “forecast” the amount of time and effort needed to process the cyclical and unpredictable number of pandemic claims. As such, best efforts were made to estimate in this regard. • The 3073 FPUC grant is the only grant for which we have been reimbursed at 100%. However, due to the most recent implementation of stop/gain loss, we are no longer being reimbursed at the full amount. • Regarding the Employment Service/ Wagner-Peyser Funded Grants noted, the program period of performance was July 1, 2022 thru September 30, 2025. GDOL received instructions from USDOL on January 19, 2023 requesting a final ETA-9130 report be submitted by February 15th for grants that were being transferred to TCSG and offered technical assistance in completing the reports. The National office was designated to de-obligate the funds remaining and issue new grant numbers to obligate these funds at TCSG; however, several things occurred that caused the process to be delayed: o The required action was to check box 6 as yes (for the final 9130 reports) and 10g (Federal Share of Unliquidated Obligation) had to be zero although there were Unliquidated Obligations in the system. o Although the Wagner Peyer program was transferred to TCSG in January 2023, eligible costs continued. o The need for expenditure reconciliations was discussed with USDOL Regional Office and anticipated funds were drawn in lieu of billing TCSG. o Associated eligible costs were reconciled to the Wagner Peyser Ledger via manual journal entries in lieu of billing TCSG. o In addition, USDOL implemented a new GrantSolutions to replace its legacy grant processing system, E-Grants. USDOL replaced its legacy E-Grants Grantee Reporting System (GRS) by transitioning to PMS for grant recipients submission of the quarterly ETA-9130 financial reports on February 6,2023. o Although training was taken for this process, the overall reconciliation process was delayed, all reconciling items were resolved by the 9/30/23 reporting period.

We concur with this finding. Although the Wagner-Peyser Program transitioned to TCSG in December of 2022, related activities also continued at GDOL. Staff at the career centers continued to serve Georgia taxpayers in need of employment services rather than turning them away. As a result, staff continued to charge the Wagner-Peyser grant, and there were Wagner Peyser grant funds still remaining at GDOL. Journal vouchers were entered to allocate indirect costs to the Wagner-Peyser grant pursuant to GDOL's federally approved cost allocation plan. Journal vouchers were also used to correct other expenditures that should have been charged directly to Wagner Peyser. GDOL will ensure that all journal vouchers are properly supported by documentation, either attached directly to the journal voucher or the journal voucher will reference the supporting documentation which can be retrieved either electronically or manually.

The following corrective actions are being taken by Criminal Justice Coordinating Council (CJCC), effective for all federal reporting for the performance and financial period ending March 31, 2024: Federal Financial Report (FFR) Processes are updated as follows: • Federal Financial Report responsibilities are distributed on a per grant basis to the members of the CJCC Budget Team. • Because the US DOJ Just Grants system does not allow for review or secondary viewers in the financial reporting items the FFRs are to be printed digitally by the completing analysts/director. • FFR’s will be reviewed with written certification of review by a budget team member that was not responsible for primary submission of the report for each grant. • Any corrections will be made within the period of correction for the report to prevent a misstated report from becoming a permanent record. Prepared Federal Funding Accountability and Transparency Act (FFATA) and Performance Measures Tool (PMT) reports processes are updated as follows: • All PMTs and FFATA data will be routed for review through the Victims Assistance Division – Director of Operations for certification of completeness and accuracy.

Commodity Supplemental Food Program (CSFP) and The Emergency Food Assistance Program (TEFAP) have developed a tentative 2024 inventory schedule to ensure continued compliance with the annual USDA Food and Nutrition Services (FNS) requirements. The schedule was submitted to FNS as part of the state’s Management Evaluation (ME) findings response. The State received notification from FNS on January 26, 2024, noting the successful completion and close-out of the FFY 2022 Management Evaluation and its findings.

Commodity Supplemental Food Program (CSFP) and The Emergency Food Assistance Program (TEFAP) have developed a tentative 2024 agency review schedule to ensure continued compliance with the annual USDA Food and Nutrition Services (FNS) requirements. The schedule was submitted to FNS as part of the state’s FFY 2022 Management Evaluation (ME) findings response. The State received notification from FNS on January 26, 2024, noting the successful completion and close-out of the FFY 2022 Management Evaluation and its findings.

We will continuously monitor the compliance supplements for updates in order to meet all requirements. We have added additional staff to complete FFATA reporting to ensure the reports are submitted timely and accurately moving forward.

FINDING 2023-003 Finding Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Summary of Finding: Certification that the contractor was not in compliance with the Davis-Bacon Act was not obtained 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: North Putnam will collect from the contractor they are in compliance with the Davis-Bacon Act. Anticipated Completion Date: Immediately, we are contacting contractor for documentation.

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund – Reporting Summary of Finding: ESSER III, Year 2 report contained material errors in the amounts reported 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: We will have one person complete the ESSER report and one person review the ESSER report for accuracy. Anticipated Completion Date: Immediately with the next ESSER report submission

Finding 2023-002 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Amy Phillips Contact Phone Number: (765) 662-2546 ext 8070 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Marion Community Schools will develop and implement a formal internal controls system to ensure compliance with all federal grant requirements. A detailed checklist of requirements listed in the grant agreement will be provided by the Grants Manager and reviewed for accuracy by the Grants Team consisting of the Assistant Superintendent for Curriculum and Instruction, the Grants Manager, the Chief Financial Officer, and the Chief Technology Officer. Compliance requirements will be monitored during weekly grant team review meetings for the duration of the grant agreement. All vendor contracts for construction will include clauses for the federal wage requirements and any additional requirements that may be required in the future. Construction companies will be required to provide us with weekly payroll report certifications. When the reports are received, they will be reviewed and approved by the Grants Manager and the Chief Financial Officer. Anticipated Completion Date: April 30, 2024

Finding 2023-001 – Title I Grants to Local Education Agencies – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Amy Phillips Contact Phone Number: (765) 662-2546 ext 8070 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Marion Community Schools will establish an internal control system that will require review of all timesheets and payroll registers by the Chief Financial Officer (CFO) or the Assistant Chief Financial Officer (Asst CFO). Timesheets/payroll registers will be reviewed for any new or updated wage amounts and provide a second sign off documenting that these were reviewed and approved. The payroll employee should bring these forward for initial review, however, the CFO/Asst CFO will still review registers as a double check and to prevent errors. Payroll changes should be kept together for easy reference, as well as with the payroll file for the period in which the change was made. Anticipated Completion Date: Immediately

Food Worker Relief Program – Assistance Listing No. 10.181 Recommendation: We recommend that the Organization strengthen its controls and processes to identify all procurement transactions, ensure the appropriate procurement policies and levels are followed and clearly documented, and to verify vendors are not suspended or debarred. These procedures will help ensure compliance with Compliance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has taken the follwing steps to ensure procurement policies are followed : 1) Management has begun the hiring process for additional staffing in the Procurement Department to help support all operations. 2) Management will review and update current policy to be in line with Federal Procurement policies. 3) Procurement department will provide training to all personnel authorized for purchases. Name(s) of the contact person(s) responsible for corrective action: Jesse Satterlee, Interim CFO, 778-730-1155 Nancy Lipman, SVP Compliance, 602-257-0700 Planned completion date for corrective action plan: 6/30/2024 – Ongoing action and Implementation

Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Luisa Ott Anticipated completion date: June 30, 2024 The District agrees with the finding. After reviewing the student in the finding, the District reprocessed the Return of Title IV calculation. The one student record was updated and resulted in an amount of $8 to be returned to the student by offsetting their current balance with the District. The District will fund the reimbursement with institutional funds. During the fiscal year ending June 30, 2023, the District has created supporting automated processes to identify potential Return to Title IV accounts. The District has started the implementation project of using the student information system to automatically calculate student Return to Title IV calculations. The District will continue to strengthen procedures surrounding Return to Title IV compliance requirements.

Dawes County Board of Commissioners will work closely with our new ARPA Funding Coordinator to ensure we do the background check for contractors receiving federal funds. Dawes County will also use our newly contracted firm to check on regulations for the program with SAM.gov and other resources provided by the federal government. Mark DeDiana with Core CPAs out of Hastings, Nebraska will be our new contact to ensure federal guidelines are achieved.