Corrective Action Plans

Finding Number: 2025-002 Finding Title: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Program: 14.218 Community Development Block Grants/Entitlement Grants 14.218 COVID-19 – Community Development Block Grants/Entitlement Grants Name of Contact Person Responsible for Corrective Action: Matthew Bower, George Hardgrove Corrective Action Planned: The City concurs with this finding. City has hired additional resources to perform review of subrecipient transactions. On a monthly basis, the new position will review system generated reports to timely capture reportable subrecipient transactions. Additionally, the City has an ongoing quarterly meeting with all grant managers. Training will be provided to grant managers to ensure proper identification of subrecipient contracts and proper entry into the SAM.gov system. Anticipated Completion Date: December 31, 2026

Finding Number: 2025-003 Finding Title: Reporting – PR29 CDBG Cash on Hand Quarterly Report Program: 14.218 Community Development Block Grants/Entitlement Grants Name of Contact Person Responsible for Corrective Action: Matthew Bower, George Hardgrove Corrective Action Planned: The City acknowledges this finding. City has communicated directly with Housing and Urban Development for clarification on reporting requirements and intends on following the updated guidance they provided. Anticipated Completion Date: July 31, 2026

The Board of County Commissioners will ensure that the reports are accurate and reported in the proper period.

The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that the County receives to ensure that proper internal controls are implemented.

The Town agrees with this finding. We understand that while the total project budget was correct, $324, 641 for the Park St. Sewer Main, the project was accidentally listed as a current expense instead of a past expense. Corrective Action Plan: To fix this and make sure it does not happen again, the Town will take the following steps: Before sending any future reports to the federal government, the Finance Department will match the report numbers directly to the Town's official accounting records (the general ledger). A second person in the finance department will review and sign off on the report before it is submitted. We will save copies of the accounting records and the signed approval forms to show future auditors. Planned Implementation Date of Corrective Action: September 1, 2026 Person Responsible for Corrective Action: Town Accountant/ Finance Director

Finding 2025-003 Inadequate System of Internal Controls over Eligibility Determination Condition: The Organization uses a database to collect and store documentation related to eligibility determinations for program participants. While this tool was used consistently throughout the year, the audit identified a lack of documented review procedures to verify that eligibility criteria were appropriately assessed and that all required documentation was obtained and retained. There is no established process to review or confirm the completeness and accuracy of eligibility documentation within the database. A new system was implemented in December 2025 which improved the deficiencies identified for the remainder of the year. Corrective Actions Taken or Planned: In September 2025, the Organization began its transition to Pantry Soft, a new CRM to centralize client records, eligibility documentation and service dates. This went live in December 2025. We included mandatory eligibility fields and document upload requirements before service can begin. We developed SOPs to include a standardized eligibility checklist to be completed for all new and returning participants. Staff were trained on Pantry Soft usage, eligibility requirements and document retention stands. The Executive Team performed spot checks on these records but will begin documenting this procedure.

During the 2025 audit, the auditors discovered that a secondary review of eligibility determinations did not occur in a timely manner. The lack of internal control opened the possibility that an individual was incorrectly determined to be eligible to receive benefits and this error would not have been identified or corrected in a timely manner. Federal Regulations establish requirements for internal control over compliance with Federal program requirements. 2 CFR Section 200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. These requirements include the design, implementation, and operation of control activities to ensure compliance with applicable compliance requirements, including eligibility. As eligibility is a key compliance requirement identified in the OMB Compliance Supplement, the County is required to implement a review process and system of internal controls that allows management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, errors or noncompliance in eligibility determinations on a timely basis. The Department of Human Services (DHS) has implemented a monthly review process to audit a random sample of the IV-E cases. The review includes verification of timely and accurate determinations, client information, supporting documentation, and system entries, with results documented and approved by the reviewer. DHS Division leadership will monitor compliance to ensure the reviews are conducted each month. DHS believes this additional review procedure will provide the needed internal controls over IV-E determination.

None provided.

Finding #2025-014 14.850 Public Housing Operating Fund Eligibility Views of Responsible Officials and Planned Corrective Action AMP 1 Response: We agree that it is essential for responsible personnel to enforce these monitoring controls effectively. Ensuring that staff obtain and properly document all necessary verification documentation before recertification is crucial for maintaining program integrity. In addition, supervisory personnel will perform periodic reviews to ensure that established procedures are consistently followed. Any deficiencies identified will be promptly corrected. AMP 1 Response to Noted Items • Item #1 - Criminal History/Sex Offender Registry Search We respectfully disagree with this finding. Documentation of the sex offender registry search was performed, verified, and included in the file. The documentation is attached to this response for your review. • Item #4 - EIV Report Timeliness We agree with the finding. The EIV report was processed six and four months late. We acknowledge this issue and will ensure the timely completion of this report. Staff will be reminded of the required timeframes for all certifications. • Item #8 - Declaration of Eligible Immigration Status We respectfully disagree with this finding. Documentation verifying the Head of Household's (HOH) eligible immigration status is included in the file. SAVE verification was conducted and documented at the time of admission to the program. The HOH is the only non-citizen in the household. The relevant documentation is attached for your review. • Item #11 - Independently Calculated Tenant Rent We respectfully disagree with this finding. After reviewing Form HUD-50058, we believe that the correct utility allowance for a 4-bedroom unit is ($498), and the corresponding tenant rent share is $43. These amounts differ from those mentioned in your summary. We have attached the source document for your review and confirmation. AMP 2 Response: We acknowledge the need to reinforce monitoring controls to ensure full compliance with eligibility and verification requirements. Effective immediately, staff will be required to obtain, review, and properly document all mandatory verification materials before completing any recertification of benefits. Recertifications will not be finalized unless the file contains complete and accurate documentation supporting the eligibility determination. In addition, Property Site Managers (PSMs) will conduct periodic quality control reviews to confirm that established procedures are consistently followed and that all required verification activities are fully documented. Any deficiencies identified during these reviews will be corrected promptly and addressed through additional training, procedural reinforcement, or other corrective measures, as appropriate. AMP 2 Responses to Noted Items • Item #5 – EIV Report Timeliness We agree with this finding. The EIV reports used to support income eligibility were processed six and four months late, respectively. We acknowledge this deficiency and will reinforce timeliness requirements with staff to ensure future compliance. Staff will be reminded that EIV reports must be obtained and reviewed within the required timeframe for all annual and interim reexaminations. • Item #7 – Verification of Assets We respectfully disagree with this finding. Documentation verifying household assets was obtained and is included in the file. The source documents supporting asset verification are attached to this response for your review. Based on the documentation on record, the verification requirements were met. • Item #9 – Eligible Immigration Status We also disagree with this finding. Verification of eligible immigration status was completed for the one non citizen Head of Household. The SAVE verification was performed, confirmed, and is attached to this response as supporting documentation. The file contains the required evidence demonstrating eligibility for assistance. • Item #12 – Rent Calculation and Form HUD 50058 We do not agree with this finding. A review of the Form HUD 50058 indicates that the correct utility allowance for a two bedroom unit ($319) was recorded, along with the correct tenant rent share of $239. These amounts differ from those listed in your summary. The source document is attached for your review and confirmation. AMP 3 Response: Management agrees with the need to reinforce monitoring controls among responsible personnel to ensure compliance with eligibility processing requirements for admissions and recertifications. Management will enforce requirements for staff to obtain, review, and properly document all required verification documentation prior to recertification. Furthermore, Property Site Managers (PSMs) will conduct periodic quality control reviews to ensure proper procedures are followed in compliance with HUD requirements. Any identified deficiencies will be promptly corrected and addressed accordingly. AMP 4 Response: We acknowledge the vital need to reinforce internal monitoring controls to ensure full compliance with all eligibility and verification requirements. Enforcing these controls effectively is essential for maintaining program integrity and ensuring the accuracy of benefit determinations. Property Site Managers (PSMs) will conduct regular, periodic quality control reviews to confirm that established procedures are being consistently followed across all files. Any deficiencies or errors identified during PSM reviews will be handled with immediate corrective action. AMP 4 Response to noted items: Sexual Registry Clearance Item #2 and #13. We agree with this finding. Sexual Registry clearance form was not completed by staff. Staff will make corrections to complete Sexual Registry clearance form. Moving forward all intake forms will be verified before finalizing certification. Enterprise Income Verification Item #13. We agree with this finding. Staff oversight on certifying EIV report. Staff will be reminded that all documents requiring PHA staff certification must be completed prior to finalization of certification. Verification of Assets Item #13. We agree with tis finding. Staff failed to obtain third-party bank statement, self-certification, or tenant declaration of asset. Calculated Tenant rent and Utility allowance Item #13. We disagree with this finding. Calculated tenant rent is correct based on income documentation submitted to PHA. Documentation for this finding submitted as attachment “Item 13” Verified Income Item #13. We disagree with this finding. Verified income was calculated and inputted in system. Documentation for this finding submitted as attachment “Item 13 Income”. Responsible Party: Asset Management Property Site Managers – Jeanna Blas, AMP 1 Acting, Gina Cura, AMP 2, Patrick Bamba, AMP 3, and Bernadette Tyquiengco, AMP 4 Anticipated Date of Completion: September 30, 2027

Community Projects Funding / Congressionally Directed Funding – Assistance Listing No. 17.289. Recommendation: CLA recommends the Organization revise the indirect costs calculation process to review program-only costs, rather than entity-wide costs. Develop policies and procedures to incorporate appropriate internal controls over indirect cost calculations; ensure the performer of the internal control has the required knowledge & understanding of compliance requirements & accounting to catch errors during the review & approval process. There is no disagreement with this audit finding. Action taken in response to finding: In January 2026 we recevied an email from DOL outlining the correct way to allocate indirect costs. We made those adjustments to our indirect calculations and will adjust any previous overstated reimbursements. Name(s) of the contact person(s) responsible for corrective action: Tracey Hunter. Planned completion date for corrective action plan: May 2026

FINDING 2025-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Tom Warthen Contact Phone Number and Email Address: 317-831-1608 twarthen@mooresville.in.gov Views of Responsible Officials: The Town of Mooresville Management agrees that we failed to adopt adequate internal controls by not having a procurement policy in place regarding the use of federal funds and that by not doing so, we failed to recognize the need to obtain three quotes for small purchases. Description of Corrective Action Plan: The Town of Mooresville will adopt a procurement policy for the use of federal funds to ensure that all federal grants are handled appropriately, and all grant requirements are met to the best of our ability going forward. Anticipated Completion Date: To allow time for a policy to be written and adopted by Council and the potential need for outside assistance in creating said policy, the Town of Mooresville anticipates having this policy in place within 60 days of the exit conference.

AUDITOR FINDING: 2025-001 Eligibility. We noted the following issues in the 25 cases tested: 1. One instance in which client income was incorrectly entered and as such, was ineligible for benefits as they were over the income limits for all of 2025. 2. Three instances in which, although case notes indicated general contact with the participant, the County did not retain sufficient documentation that a required meeting specifically addressed or confirmed engagement in an eligible work activity or was completed within required timeframe. Recommendation: We recommend that the County continue to strengthen internal controls related to eligibility determinations. This includes issuing training alerts related to the differences of subsidized and unsubsidized employment income and the impacts to eligibility. Additionally, we recommend continued periodic quality assurance reviews of TANF case files to ensure ongoing compliance with federal and state eligibility requirements and identification of employees with performance issues. Finally, we recommend the County develop monitoring reports to identify those clients who have not had a workforce contact in the required timeframe. CLIENT PLANNED ACTION: Jefferson County agrees with the findings and has taken or will take the following steps to address the errors. The findings were caused by workers on both the eligibility and workforce teams so varying measures will be implemented based on the finding and responsible team. Jefferson County will continue and implement the following actions to address and prevent future findings. • Eligibility Team Actions o Jefferson County will issue a training alert to all eligibility staff by June 20, 2026, detailing the difference between subsidized and unsubsidized employment, correct data entry, and the impact of each on TANF eligibility. o To monitor compliance, the County will continue completing Internal Quality Assurance reviews utilizing the state mandated list to assess the case and payment accuracy. • Workforce Development Team Actions o Performance concerns related to inconsistent client contact and incomplete documentation were identified during regular performance reviews in January 2026 and have been successfully addressed via the county Employee Relations coaching and disciplinary framework. •To monitor compliance, the County will continue completing Internal Quality Assurance reviews utilizing the state mandated list. In addition, Colorado Works Supervisors review at least one case per worker each month. Beginning in June 2026, the number will be increased to a minimum of 10 cases per month if a performance concern is identified. o Tableau reports have been created or enhanced to monitor compliance. • Individual case worker accuracy reports for all IQA and Supervisor reviews were released in March 2026. Progress reviews have been incorporated into monthly supervision meetings with staff. • Enhancement to report titled, Cases Needing Action, which tracks data entry of client contact and Individual Plan development in CBMS was completed on June 1, 2026. Workers will now be notified if client contact exceeds 30 days. Workers and supervisors will review the report monthly and take proactive measures for client contact prior to exceeding rule requirement of 90 days. CLIENT RESPONSIBLE PARTY: CW Eligibility Team: Julia Zoukhri (Program Manager), Brandy Brogan (Program Manager), Karen Thomas (Program Manager) and Jennifer Martinez (Quality Assurance & Systems Administrator) CW Workforce Development Team: Tara Noble (Program Manager), Kathryn Boyd-Cordova (CW Supervisor), and Erin Encinias (CW Supervisor) COMPLETION DATE: July 2026

FINDING 2025-002 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Reporting Contact Person Responsible for Corrective Action: Gloria Alumbaugh Contact Phone Number and Email Address: 812-591-3500 and townofwestport@comcast.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Clerk Treasurer will ensure that a review process is in place when completing the RD442-2 (Statement of Budget, Income and Equity) and the RD442-3 (Balance Sheet) for the annual USDA reports. The Clerk Treasurer will complete the RD442-2 and RD442-3 forms with working papers and reports to support the information reported on the forms. Then the Deputy Clerk will review the working papers and reports to verify the same results reported on the forms, before signing off on approval of the form, ensuring two signatures are included on the official forms before submittal to USDA each year. Anticipated Completion Date: The next annual USDA reports will be completed by March 1, 2027. INDIANA STATE

Management agrees with the finding and acknowledges that documentation of timesheet and payroll reviews was not consistently retained during the audit period. Management notes that this finding relates primarily to the documentation and consistency of review controls rather than an indication that reviews were not performed. To address this finding, management has implemented a formal, documented review process for timesheets and payroll prior to disbursement. Timesheets will be reviewed and approved through a centralized system or documented workflow to ensure that evidence of supervisory review is retained. Payroll changes require CEO approval prior to or concurrent with processing and documentation retained. Each payroll is subject to independent review and confirmation. Cumulative payroll and allocation are further subject to independent quarterly review by the CEO with supporting documentation. These procedures will be incorporated into standard operating practices and monitored periodically to ensure consistent application and retention of audit evidence. Anticipated Implementation Date: Implemented and ongoing; formal policy incorporation expected by September 1, 2026. Contact Person Responsible for Corrective Action: Shahara Wright, Chief Operating Officer & General Counsel and Brook Abitz, Director of People and Operations

Management agrees with the finding and acknowledges that documentation supporting review, approval, and segregation of duties for certain nonpayroll transactions was not consistently maintained during the audit period. To address this finding, management has formalized procedures requiring documented approval of invoices and nonpayroll expenditures prior to payment. These procedures require a clear separation between the individual requesting or managing a transaction and the individual approving the invoice or payment. Management has also implemented standardized approval workflows to strengthen segregation of duties, enforce approval requirements, and maintain a complete audit trail. Management will incorporate these procedures into formal policies and standard operating procedures and will periodically monitor compliance to ensure controls are consistently applied across programs. Anticipated Implementation Date: Implemented and ongoing; formal policy incorporation expected by September 1, 2026 Contact Person Responsible for Corrective Action: Shahara Wright, Chief Operating Officer & General Counsel and Brook Abitz, Director of People and Operations

Finding No. 2025-006 – Internal control deficiencies over accounting for federal funds received from the United States Department of Homeland Security (DHS) Corrective Action Plan Single Audit 2025 Page 6 April 30, 2026 Condition During our procedures over the Authority’s funds received from FEMA we noticed the following: 1. Return of interest earned on FEMA-related funds totaling approximately $211,853 was not timely recorded in the general ledger and was subsequently recorded through a post-closing entry dated January 26, 2026. 2. Management initially misclassified approximately $6 million received under the Coronavirus State and Local Fiscal Recovery Funds as state funds rather than federal awards. As a result, the amount was originally excluded from the Schedule of Expenditures of Federal Awards (the Schedule). Views of Responsible Officials and Corrective Actions It should be noted that, although certain funds received were not properly identified as working capital advances, those funds were properly considered as received from FEMA through the COR-3 office of the Government of Puerto Rico. This situation basically arises because the federal funds coming from FEMA are being handled by outside consultants, without any coordination with the Federal Funds Management Office (FFMO). The Authority’s management will ensure that, in the future, the FFMO will coordinate with the assigned outside consultants all the efforts necessary for the proper handling, identification and classification of funds received from FEMA. Name(s) of the Contact Person(s) Responsible for Corrective Action Romel Pedraza Claudio. P.E. – Assistant Executive Director for Planning & Engineering Elena González – DEA Finance Miguel La Torre – Interim Finance Director Anticipated Completion Date During FY-2026-2027

FA 2025·001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Titte: Federal Award Number: Questioned Costs: Description: Procurement Suspension and Debarment Significant Deficiency Nonmaterial Noncompliance U.S Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program 10.582 - Fresh Fruit and Vegetable Program 255GA324N1199 (Year: 2025), 255GA324L1603 (Year: 2025) $6,267 A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: To address this deficiency and prevent recurrence, the District will implement the following corrective actions: 1. Immediate Reinforcement of Quote Requirements Effective immediately, all School Nutrition and applicable district staff will be required to obtain and document price or rate quotations from a minimum of two qualified sources for all. 2. Pre-Approval and Verification Controls A pre-payment review process will be enforced requiring verification that: o Required quotes are documented o Procurement method aligns with federal thresholds o Vendor selection is properly justified o Payments will not be approved without complete documentation. 3. Staff Training and Accountability Mandatory training will be conducted for all School Nutrition Managers and staff involved in procurement to reinforce: o Federal procurement requirements o Documentation expectations o Internal control procedures Estimated Completion Date: July 31, 2026 Contact Person: Matoshia Grant, School Nutrition Director Telephone: 478-986-1390 Email: Matoshia.grant@jones.k12.ga.us Signature:Tonya Merritt Title: Cheir Financial Officer

Reporting – Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization perform a final review of amounts entered within the UDS report, as compared to the supporting schedules, prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Update UDS procedure to pull detail reports on all numbers reported in the UDS. • Add to the UDS procedure a review of detail reports to tie them to UDS report • Add a sign off to UDS report as part of final review that detail reports were pulled and verified. Name of the contact person responsible for corrective action: Keith Flores, CFO Planned completion date for corrective action plan: July 2026

Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds FFALN # 21.027 Finding Summary: Eide Bailly LLP prepared our single audit for Federal Coronavirus State and Local Fiscal Recovery Funds where the Town is a subrecipient to Douglas County who is the recipient of the funds. Eide Bailly LLP identified that the Town did not have documented or consistently applied internal controls to ensure compliance with the County’s subrecipient guidance requiring the submission of formal special reports for ALN 21.027. Responsible Individuals: Mark Henderson, Assistant Director of Castle Rock Water Corrective Action Plan: Staff will complete quarterly reports including project progress and estimated project infrastructure costs. The reports will be reviewed by management prior to submission to the recipient of the Federal Funds (Douglas County). Anticipated Completion Date: Ongoing during the period that the Town is a subrecipient of these funds for the project.

Re: Home Investment Partnerships Program (HOME), Federal Assistance Listing #14.239 County Department Department of Planning and Development (DPD) Finding 2025 001 Cause: Post Pandemic allocations to the County included several housing related fundings and initiatives, including Emergency Rental Assistance I & II (ERA I& II), Homeless Sheltering, Homeless and Transitional Sheltering Physical Site Acquisition and Development, HOME ARPA (HUD Allocation), and HOME, CDBG CV development delays that challenged the Housing teams provision of services and compliance requirement. While HUD had extended post-pandemic compliance moratoriums into fiscal year 2024, Housing team hiring, training and implementation of compliance activities were unable to activate fully in the subject fiscal year to meet compliance. Team initial compliance training was implemented in FY 2025. DPD hired three additional staffers for a total of five to support compliance investigations moving forward. Corrective Action Plan: Special Test on Housing Quality Standards 1. Compliance training activities will continue to be coordinated by the Bureau's Compliance Management Team to strengthen program oversight and compliance efforts. As part of this initiative, 100% of Housing Team staff and management will receive compliance training, be qualified to perform compliance-related functions, and be assigned appropriate compliance responsibilities. a. All Housing Team staff and management will complete compliance training through HUD-sponsored virtual training or HUD-approved in-person training by November 30, 2026. b. Five of eight staffers will have hands-on site qualifications demonstrated by task and verified by management by November 30, 2026. 2. Required compliance planning for HOME programs will be completed by September 30, 2026. a. Plan will be reviewed and approved by Deputy Director and submitted to the Director by September 30, 2026. b. Initial site inspection appointments will be completed by October 31, 2026 c. Initial site physical inspections will commence by November 30, 2026. 3. Deputy Director will ensure that compliance site investigations and on-site file review will be completed by May 31, 2027. a. All reporting for respective site investigations shall be filed by above date b. All required communication to developer/owner teams shall be completed, mail and confirmation receipt by above date. Subrecipient Monitoring The department classified costs as subrecipient expenditures but should have classified as developer costs. Developer costs are not subject to subrecipient monitoring requirements under the Uniform Guidance. Therefore, the corrective action will be to assign a unique account code to address the finding where subrecipient monitoring will no longer apply. Grants Finance Manager will work with the Bureau of Finance to assign a unique account code by July 31, 2026. Endorsed By: Susan M. Campbell, Director

2025-004 Auditor’s Recommendation: UCM should formalize and document internal control procedures over Federal award expenditures, including documented review and approval processes to ensure compliance with Uniform Guidance. Corrective Action: UCM will formalize and document internal control procedures over Federal award expenditures to ensure costs charged to Federal awards are allowable, allocable, reasonable, properly approved, and adequately supported in accordance with Uniform Guidance. Written procedures will be developed for expenditure review and approval, including documentation of business purpose, budget availability, cost eligibility under the award terms, proper account coding, funding source, supporting documentation, and evidence of approval. UCM will also strengthen controls over direct assistance to client expenditures by requiring documentation of client eligibility, assistance type, amount approved, funding source, program approval, finance review, and evidence of payment. Direct assistance expenditures will be reviewed to ensure they are allowable under the Federal award, consistent with program requirements, properly coded, and adequately supported before payment or reimbursement is processed. UCM will also implement a Federal award expenditure checklist or similar review tool to document review before expenditures are paid, posted, or reported. The checklist will include review of allowability, allocability, reasonableness, budget availability, funding source, supporting documentation, approval, and compliance with applicable Federal award requirements. For direct assistance to clients, the checklist will also confirm client eligibility, approved assistance type, required case documentation, and evidence of payment. Staff responsible for Federal award expenditures, direct client assistance, grant accounting, accounts payable, and program budget management will receive training on the updated procedures and Uniform Guidance requirements. Supporting documentation and evidence of review and approval will be retained with the expenditure records. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Anticipated Completion Date: December 31, 2026

The College acknowledges the finding and agrees that required notifications to students must be provided prior to the disbursement of Title IV funds. The condition resulted from the absence of formal procedures and controls to ensure timely notification and documented review. The College is in the process of implementing enhanced controls over student notification procedures. Formal policies and procedures will be established to ensure that notifications are generated and delivered prior to disbursement, including defined timing, content, and documentation requirements. The College will engage third-party consultants and implement system enhancements to improve the timing and sequencing of notifications and disbursements. In addition, the College will implement monitoring procedures, including tracking of notification and disbursement dates and documented supervisory review, to ensure compliance with timing requirements and timely identification and resolution of exceptions. Accounting, independent of the Office of Financial Aid, will perform a final review to verify that notifications are issued prior to disbursement and that established procedures are consistently followed. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that required notifications are provided timely and in accordance with federal requirements, and to prevent recurrence

The College acknowledges the finding and agrees that verification procedures must include documented evidence of completion and supervisory review. The condition resulted from the absence of formal procedures and lack of retained documentation evidencing completion and review of verification activities. The College is in the process of implementing enhanced controls over verification procedures. Formal policies and procedures will be established to define responsibilities, documentation requirements, and supervisory review expectations. Each verification file will require documented evidence of completion and review, including electronic sign-off or system-based approval. In addition, the College will implement quality control measures, including systematic validations and periodic supervisory reviews, with documentation retained to evidence the scope and results of such reviews. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that verification procedures are consistently applied, properly documented, and subject to appropriate review, and to prevent recurrence.

The College acknowledges the finding and agrees that Return of Title IV Funds (R2T4) calculations and related return activity must be accurately calculated, properly documented, and fully traceable. The condition resulted from the absence of formal procedures, lack of documented supervisory review, and insufficient documentation and reconciliation of student-level return activity. The College is in the process of implementing enhanced controls over the R2T4 process. A monthly structured workflow has been established whereby the Office of Financial Aid prepares and provides a detailed listing of students subject to R2T4 calculations, including institutional return amounts. Accounting independently reviews and verifies the calculated return amounts and processes the return through the federal system, with documented review and approval. The College has eliminated undocumented manual netting adjustments and requires that all R2T4 returns be recorded as distinct transactions supported by a standardized documentation package, including studentlevel calculations, withdrawal determination dates, and institutional return amounts. All activity is maintained in a centralized electronic repository to ensure a complete audit trail. In addition, the College is formalizing written procedures to define roles and responsibilities, establish documentation standards, and require documented supervisory review and approval. Periodic reconciliations will be performed to ensure that student-level return amounts agree to system activity and federal cash activity. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that R2T4 calculations and returns are accurate, properly documented, fully traceable, and compliant with federal requirements, and to prevent recurrence.

The College acknowledges the finding and agrees that reporting to the Common Origination and Disbursement (COD) system must be accurate, complete, and submitted within required timeframes. The condition resulted from the absence of formal procedures and controls to validate key data elements and monitor reporting timeliness. The College is in the process of implementing enhanced controls over COD reporting. The Office of Financial Aid will develop and formalize written procedures governing the reconciliation of awarding and disbursement activity with COD reporting, including defined responsibilities, documentation standards, and review requirements. The College will also engage third-party consultants to review current processes and assist with system enhancements. System configuration and process improvements will be implemented to support the automation of award and disbursement reporting through PeopleSoft. The Office of Financial Aid will implement quality control measures, including systematic validations and documented supervisory review, to ensure accuracy, consistency, and compliance in COD reporting. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that COD reporting is accurate, timely, and properly controlled, and to prevent recurrence.