Corrective Action Plans

Finding 2022-042 Education Stabilization Fund, ALN 84.425 - During-the-Award Monitoring Procedures Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidance does not specify a timeframe for the review of FERs for the Education Stabilization Funds (ESF) and the ESF program is inherently more flexible than other federal programs in this regard. Although GANs originally required ESF subrecipients to submit a FER by August 29, 2022, MDE communicated to ESF subrecipients after the initial GANs that the August 29, 2022 due date was subject to change due to the continuously changing rules and requirements around this funding, including extension possibilities such as late liquidation. ESF FERs were due either within 60 days of full draw of the funds or within 60 days of the end of the award period, which could have been during the State?s fiscal year 2022 or well after September 30, 2022. For this reason, under Uniform Guidance, MDE had the authority to delay the review of FERs until closer to the end date of the award. In the case of late liquidation, the U.S. Department of Education provided notification that extended the award period as far as 14 months beyond the original end date of the award. For part b., MDE partially agrees with the finding. MDE acknowledges that subrecipient desk reviews were not finalized; however, the majority of the subrecipient monitoring was complete. The Uniform Guidance does not specify a timeframe for ESF subrecipient monitoring to occur and no requirement or expectation was made that monitoring would be finalized by MDE management by September 30, 2022. While the MDE contractor was not tracking completion against the date of September 30, 2022, documentation was and is still available, upon request from the OAG, to demonstrate the substantial ongoing monitoring activities, such as desk reviews and review of amendments, as of the end of the State?s fiscal year 2022. The Compliance Team was in regular contact with MDE throughout the monitoring process. The Compliance Team provided regular updates leading up to September 30, 2022 and shared comprehensive preliminary results with the department soon after September 30, 2022. Planned Corrective Action For part a., MDE will evaluate the process for reviewing FERs to determine the appropriate timeframe for FER review of these ESF funds in light of federal liquidation extensions. MDE and subrecipients were notified of a one-time, Coronavirus Aid, Relief, and Economic Security Act reopening drawdown opportunity during the spring of 2023, which again reopened the possibility for subrecipients to submit FERs. MDE will begin interim reviews of a sample of submitted FERs by September 30, 2023. For part b., MDE?s contractor provided MDE with the final results of its school year 2021 monitoring that was finalized during the summer of 2022 on January 5, 2023. MDE and its contractor have since followed up with subrecipients to recommend necessary or reasonable corrective action in March 2023. School year 2022 monitoring is ongoing and anticipated to be completed by September 30, 2023. Anticipated Completion Date September 30, 2023 Responsible Individual(s) Spencer Simmons, MDE

Finding 2022-012 MATT 2.0 Change Management Process Management Views MSHDA agrees with the finding. Corrective Action MSHDA completed the improvement of the existing change management process for the MSHDA Activity Tracking Tool (MATT) 2.0 in November of 2021, which includes requiring electronically documented approval before any production changes can be made. The remaining record that did not have documented support was a training issue that has already been addressed. Anticipated Completion Date Completed Responsible Individual(s) Mark Whitaker, MSHDA SaVille Hill, MSHDA

Finding 2022-011 MATT 2.0 Security Management and Access Controls Management Views The Michigan State Housing Development Authority (MSHDA) agrees with the finding. Planned Corrective Action For parts, a., b., and c., as of November 30, 2022, MSHDA implemented system security processes and procedures to review active generic and test accounts and to review and disable user accounts inactive for 60 days. In addition, MSHDA implemented a monitoring process that includes semiannual review of privileged accounts and annual review of all other accounts. For part d., MSHDA provided additional training to the user who did not properly approve and document a system access form. Anticipated Completion Date Completed Responsible Individual(s) Mark Whitaker, MSHDA SaVille Hill, MSHDA

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

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

Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: David Felix, Chief Financial Officer Anticipated Completion Date: May 18, 2023 Planned Corrective Action: When the City received notification of the award of CSLFRF funds, the CFO and City Attorney reviewed the law and, based on how it was written, felt that we could apply it to the Fire Department?s salary expenses as over 80% of their calls are for emergency medical services, they are the first responders to a 911 EMS call, and they usually transport the patients to the hospital. Neither in the initial law documentation, nor in the initial application, was there an option to select a $10M de minimus revenue loss option. If this was available, the City would have chosen that up front. We completed the interim report based on data created by inquiries run in our General Ledger on the date we submitted the report. We believed the data was saved on our system, but we can not find the electronic copy of it. As adjustments have been made to the data since then, we are unable to recreate a report that matches the data on the interim report. We can get within $800, but not the exact amount. Going forward, we will ensure the data is saved and put in a place that it is easier to retrieve.

Finding 2022-013 US Department of Department of Health and Human Services AL No. 21.023 Emergency Rental Assistance Program Significant Deficiency over Reporting Repeat Finding: No Auditee?s Corrective Action Plan: As part of an overall goal of the Mayor?s Office of Children and Family Success (MOCFS), this leadership is committed to ensuring that grant compliance to all Federal, State, and Local grants are prioritized as the agency is 85% grant funded. The agency is currently implementing internal grants management Standard Operating Process (SOP) that is in-line with the City?s Grants Management policy outlined in AM 413-60 and 413-6. These processes will minimize and ultimately eliminate audit finding as a result of inadequate SOP or lack thereof. Contact Person: Chief Financial Officer ? Unyime Ekpa Completion Date: April 25, 2023

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

FINDING 2022-004 Contact Person Responsible for Corrective Action: Barbara Fought Contact Phone Number: 260-260-3191 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: West Noble School Corporation will work with the Northeast Indiana Special Education Cooperative to implement the procedures detailed below. The Northeast Indiana Special Education Cooperative (NEISEC) Treasurer will reach out to member schools during the writing process of the IDEA 611 and 619 grants in order for each member school to submit their plans for their allocation of proportionate share money. NEISEC will provide the allocation amounts to each cooperative school. These submissions will include a proportionate share budget and include proportionate share staff names and any necessary information for the budget categories. The NEISEC Treasurer will then compile the proportionate share information and include on the grant submission. The LEA Treasurer will be given a copy of the grant application and budget upon approval of the grant. Any NEISEC employee being paid out of proportionate share grant funds for salary and benefits will be paid from the fiscal agent?s financial software. The LEA Treasurer will keep a spreadsheet of employee proportionate share expenses and this spreadsheet will be updated monthly based on time and effort logs that are submitted by all cooperative schools to the LEA and NEISEC. Any employee utilizing proportionate share funds that is not an employee of NEISEC, but rather a direct employee of a member school, will be paid directly by that member school. Time and effort logs will still be submitted to the LEA and NEISEC Treasurers for these employees in order to generate a direct reimbursement from the grant fund to the member school. For any expenses for a category outside of salary and benefits, a member school will need to submit an invoice and proof of purchase for equipment, supplies, etc. to NEISEC and the LEA in order to be directly reimbursed for those proportionate share expenses. If the request was not in the initial grant budget, the member school must submit all relevant information to NEISEC in order for a grant modification to be completed. Per IDOE the grant modification must be approved first prior to purchasing the items. Time and effort logs as well as invoice and proof of payment must be sent to the LEA Treasurer and NEISEC in order to complete the grant reimbursement requests. INDIANA STATE BOARD OF ACCOUNTS 29 TELEPHONE (260) 894-3191 - 5050 N US HIGHWAY 33 - LIGONIER, IN 46767-9606 - FAX (260) 894-3260 - 1-800-488-3191 - WNSC@WESTNOBLE.K12.IN.US At the end of the grant period, any school with remaining proportionate share money will be required to complete a waiver. As of this date (2/10/2023) DeKalb County Eastern CSD and NEISEC are still in communication with SBOA and IDOE to review the proportionate share plan and ensure all necessary requirements will be satisfied. Anticipated Completion Date: Changes discussed above will be implemented for the remainder of the FY23 grant period starting 07/01/2023.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Barbara Fought Contact Phone Number: 260-260-3191 Views of Responsible Official: We concur with the finding. Finding 2022-003 was corrected in January 2023. The Food Service Director and Maintenance Department met to discuss how federal purchases are to be made when repairs to kitchen are needed. Maintenance will secure at 3 quotes and share those quotes with the Food Service Director. The Food Service Director will send the selected quote back to Maintenance for ordering. Since implemented in January, repairs for the kitchens have been very smooth and seamless. Anticipated Completion Date: March 31, 2023

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

2022-001 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: We recommend that the School Corporation enhance its procedures and internal controls to ensure that it retains documentation of procurement suspension/debarment status verifications for its vendors and that this documentation is available for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our suspension and debarment procedures are being further developed requiring vendors to annually signoff stating that they are not suspended or debarred. If at any time during that year the vendor becomes suspended or debarred, it is the vendors responsibility to notify the school corporation of this change in status. Name(s) of the contact person(s) responsible for corrective action: Louise S. Smith and Jennifer Niese Planned completion date for corrective action plan: Procedures developed by June 30, 2023 and vendors will start signing required documentation as of July 1, 2023.

The Organization has implemented a full review of the contracts at year end to make sure all expenses are assigned to a funder code in the accounting system. In additional, as a final control procedure, Accounting will run a final report for all contracts that have been identified as federal vs actual invoiced expenditures and further compared to what has been expensed per the financial statements and provide to the Chief Program Officer to compare and reconcile to the SEFA. 39

Finding 2022-001 Condition/Context The Center improperly calculated lost revenues as a result of improperly including contributions and improperly excluding contractual adjustments related to patient service revenues. This is not a statistically valid sample. Corrective Action Plan Corrective Action Planned: St. Joseph's Center will correct the lost revenues calculation in the Period 4 Submission due March 31, 2023. In order to ensure that St. Joseph's Center properly calculates lost revenues in the future, all lost revenue calculations and source documents will be prepared by the Accounting Manager and reviewed by the Chief Financial Officer. Name(s) of Contact Person(s) Responsible for Corrective Action: James Ceccoli, CFO Anticipated Completion Date: 3/31/2023

"Finding No. 2022-002: Internal Controls over Compliance ? Procurement, Suspension and Debarment Corrective Action Plan: The SDSTA will continue to work on improving controls surrounding the review of contracts to ensure they contain the proper provisions and strengthen document retention policies. Contact Person: Terry Miller, Chief Finance Officer, South Dakota Science and Technology Authority. Anticipated Completion Date: The SDSTA will implement additional controls on or before June 2023."

Finding 2022-002 Equipment and Real Property Management Significant Deficiency in Internal Control over Compliance and Compliance Federal Agency Name: Department of Education and Passed through State of South Dakota Department of Education Program Name: COVID-19 Education Stabilization Fund - Governor's Emergency Education Relief (GEER) Fund Federal Financial Assistance Listing #84.425C Finding Summary: In the sample of expenditures selected for testing, no support to substantiate a physical inventory of federal-funded equipment was performed within the last two years. In addition, Federal-funded equipment is not distinguished separately from non-federal-funded equipment within the Club's fixed asset listing. Responsible Individuals: Jody Hernandez, Chief Executive Officer; Darcie Bien, Chief Financial Officer Corrective Action Plan: A physical inventory of federally-funded equipment will be completed annually to assure that all federally funded equipment and real property is accounted for. All federally-funded assets are now identified on the fixed asset listing. Anticipated Completion Date: June 30, 2023

Compliance requirement ? Procurement, and suspension and debarment Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor findings on the deficiencies in a), b) and c), about requesting quotation because, In accordance with the procedures under 2 CFR ? 200.320, and the definitions under 2 CFR 200.1 and 48 CFR Part 2, subpart 2.101 to support response to an emergency; the seven (7) referenced procurement transactions were under the Micro-purchase threshold for a national emergency response and the purchase could be awarded without soliciting competition or quotations. 2. The institution concurs with the auditor finding. The institution will incorporate the verification of suspension and debarment under the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution. Actions Taken or Planned: The institution will incorporate the provisions of 2 CFR Section 200, 2 CFR Section 180.300 and other related regulations in the procurement policies of the institution.

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

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

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

Compliance requirement ? Cash Management Institutional Comments on Findings and Recommendations: 1. The institution does concur with the auditor finding. The institution is revising the accounts' payable structure to ensure future payments falls within the allowed elapsed time. Actions Taken or Planned: The institution is revising the accounts' payable structure to ensure future payments falls within the allowed elapsed time.

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

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

Compliance requirement ? Other ? Policies and Procedures requirements. Institutional Comments on Findings and Recommendations: 1 The institution agrees with the auditors on this finding in which the current University Catalog containing the updated general disclosures for enrolled or prospective students were not updated on time for the fiscal year. 2 The institution agrees with the auditors on this finding in which the Drug and Alcohol Abuse Prevention Program did not fully comply with the distribution requirement in writing for each student. It also agrees that the institution did not perform a recent biennial review of its Drug and Alcohol Abuse Prevention Program. Actions Taken or Planned: The institution has already updated, published, and distributed its Catalog to accurately represent the vision and goals, our academic offerings and administrative policies and procedures of our operation. As related to the institutions Drug and Alcohol Abuse Prevention Program, the same was also updated, revised, published, and distributed to all active students and staff. The updated Drug and Alcohol Abuse Prevention Program is also available for distribution for all prospective students and any potential employees through the Admissions and Human Resources offices respectively. The same would also be posted on the Web page of the institution. Evidence of both issues were submitted to the auditors.

Finding: 2022-002 Federal Program: Education Stabilization Fund (ALN 84.425F) Name(s) of the contact person(s) responsible for the corrective action: Jare Allocco Allen, Controller David Drews, Associate Controller Misty Clark, Director of Accounting View of Responsible Officials: The Controller?s Office will implement an additional internal control for this compliance requirement. In addition to Procurement?s verification and documentation, Accounting will also perform a verification of the written evidence of the suspension and debarment review.