Corrective Action Plans

Inaccurate HEERF Annual Reporting Planned Corrective Action: The financial aid office (FA) will make correction to Year 2 HEERF Annual Reporting when the report opens in early 2023. The FA office will work closely with the business office and the IRE Department to get the reports needed to answer the questions correctly for the Year 2 corrections and well as Year 3 reporting. Person Responsible for Corrective Action Plan: Jennifer McCormack Anticipated Date of Completion: July 2023

Higher Education Stabilization Fund Reporting Planned Corrective Action: I have worked with our IT department, specifically the individual that works closely with Financial Aid reports and data, to ensure I have received accurate data in order to correct this report. The IT person who initially provided me with the information for the report is no longer in that department. Additionally, I am working with our former CFO who still works for Eastern on Special Projects to submit the Year 3 report. We are sharing our data with our new CFO and our Director of Accounting and Finance to help close the information gap. Person Responsible for Corrective Action Plan: Andrea L Ruth, Director of Financial Aid Anticipated Date of Completion: 3/24/2023

FINDING 2022-001 REPORTING SIGNIFICANT DEFICIENCY Federal Program: Education Stabilization Fund Assistance Listing Number: 84.4250 The school did not report activity related to the use of Elementary and Secondary Emergency Relief Fund in line with actual activity. The school did not have controls in place to ensure accurate reporting. The school will ensure that the ESSER data collection report reflects actual expenditures for the next period. Will use the grant tracking system to ensure dollar amounts are accurate on the report. Responsible Individual: Don Stewart, Director of Finance

Corrective Action Plan Audit Finding Reference: 2022-001 Planned Corrective Action: In response to audit finding 2022-001, the University has established a system of controls. When the prior- year finding was identified, the responsible reporting officials for the institutional and student portions of HEERF funding combined report information into a single web posting request prior to the deadline each quarter. This single request provided another check for the posting official to confirm the quarterly report is comprehensive. Date of Remediation: September 2021 Contact Person Responsible: Christina Pikla

Guilford College (GC) Corrective Action Plan May 31, 2022 Audit 22-001 Limitations of the College?s Software to Provide a Trial Balance ? Material Weakness Auditor?s Findings and Recommendation Condition: During the planning of the audit and throughout the audit process, it was difficult for Management to obtain complete and accurate information in order to provide a trial balance that could be audited. Although the transactions for the year were present in the system, the reports to extract the data proved to be very challenging. Management was ultimately able to provide a working trial balance. Criteria: Adequate internal control over the financial reporting process. Cause: Turnover in staffing and issues with the College?s current software program. Effect: Delays in completing the audit due to multiple reports provided by Management. Recommendation: We recommend replacing the College?s current software and we understand that this decision has been made. The College is moving forward with a new software. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding. See Corrective Action Plan. Management?s Response Guilford College disagrees with the finding that this a material weakness. 1. During the pre-audit conferences on April 20th and June 7th the timetable for the delivery of the audit report was established. It was identified in the pre-audit meeting that the entire accounting team was new and had not been through the audit process at Guilford and required additional support and collaboration from the auditors. It was known that the access reports were non-functioning and a system generated report was to be delivered by ledger account via Banner or the Argos reporting tool. The auditors were provided early in the audit process (July 7th) from the system a working trial balance. The auditors struggled to translate the format change into their system, although the report provided the required information by ledger account. The Guilford accounting team had to take extra time to develop a report to map the data from the system that was basically an ordering and grouping format change to prior reports submitted. Also, the accounting team had to continue to ask for clarification on requests, work papers or examples of requested data which created frustration and delays. The majority of the audit list items, reports, and supporting documentation were provided electronically in July to facilitate and allow for a more efficient audit process to meet the established timeline. -48- John Wilkinson, MBA CFO / Vice President A&F Phone: 336-316-2422 Fax: 336-316-2956 jwilkinson@guilford.edu The audit team delayed auditing key items that data was provided to them electronically in July, delayed addressing the general ledger issue and were frustrated when it was addressed, late in the audit process and close to the delivery deadline. These issues should have been identified and resolved in July or at the front end of the audit process. This indicates a lack of planning and managing of the delivery schedule which is the basis for the material weakness comment. If the audit had been planned and supervised properly, this material weakness comment would not have been made. This is supported by a delivery of the audit report late Thursday evening before the required delivery date, Friday the next day. 2. A material weakness is present when there is a reasonable possibility that a material misstatement of the financial statements can occur and not be prevented or detected in a timely basis. The Guilford accounting staff understood the extraction of data was different this year and has successfully and accurately provided management and the board finance council with monthly financial data during the audit year. The auditors did not early in the audit process gain a full understanding of the new process of extracting data. The auditors waited until time pressure for audit delivery were significant before gaining an understanding of the new process. The auditor?s mismanagement of the audit process created the impression of a material weakness. The CFO and Controller have taken the following steps to remediate the findings: Complete list of all year-end journals, closing entries, calculations, reports and deliverables. Argos report Trial Balance As part of the Workday system conversion and implementation, the Chart of Accounts is being updated and streamlined to support financial reporting by fund, organization, ledger account, and program. This update to the backbone of the financial structure will provide accurate, timely and core financial reporting for the college and end users. Reporting Needs and Requirements are being identified and if canned system reports do not meet needs, then custom reports will be developed as part of the implementation deliverables. 22-002 Cash Accounts Not Reconciled ? Significant Deficiency Auditor?s Findings and Recommendation Condition: During our audit, we noted that several cash accounts had not been reconciled. Monthly bank account reconciliations are the primary internal control procedure relating to the College's cash accounts. During May 31, 2022, bank account reconciliations were prepared; however, the accounts were not completely reconciled. -49- John Wilkinson, MBA CFO / Vice President A&F Phone: 336-316-2422 Fax: 336-316-2956 jwilkinson@guilford.edu As May 31, 2022, there was an unreconciled amount of $177,466 in various cash accounts. Criteria: Adequate internal control over the financial reporting process. Cause: Turnover in staffing and issues with the College?s current software program. Effect: Although this amount may appear not to be material to the overall financial position of the College, it may obscure significant but offsetting items (such as bank errors or improperly recorded transactions) that would be a cause for investigation if the items were apparent. Unreconciled amounts should be investigated and not be allowed to carry over from month to month. Recommendation: We recommend replacing the College?s current software and we understand that this decision has been made and the College is moving forward with a new software and the cash accounts are being reconciled. View of Responsible Officials and Planned Corrective Action: GC Management?s Response: Guilford College disagrees with the finding that this is a significant deficiency. 1. The $177,466 bank accounts unreconciled amounts are immaterial to the financial statements. Any comment related to the bank account should be made as an observation to management (management letter) and should not be considered a significant deficiency. 2. A comment to the Board is unnecessary. This is a management issue and not a significant deficiency since the issue was known by the Controller?s office, but was considered a lower priority matter. A detailed list of the unreconciled items was completed and under investigation to reconcile, however due to limited staff, manual systems, and higher priorities they were noted as unreconciled. The cause explanation indicates this is clearly a workload matter given the limited accounting staff available and manual system processes. The moving forward and not finding the reconciling differences is a time management matter. Comment should be to management and indicate the accounting staff and improved manual processes should be addressed to manage the work necessary to prepare monthly bank reconciliations. The Controller has taken the following steps to remediate the findings: - Improve the monthly reconciliation policies and procedures to ensure reconciliations are completed accurately and timely. - Established a checklist of all bank accounts for reconciliation with an owner and established due dates. -50- John Wilkinson, MBA CFO / Vice President A&F Phone: 336-316-2422 Fax: 336-316-2956 jwilkinson@guilford.edu - Bank reconciliation workload is re-distributed among accounting team - A standard reconciliation form with preparer and a supervisory review and approval process. - Improved communications and procedures with Controller?s Office and Student Accounts on bank deposits, ACH, and cash transactions. - Update all incoming web receipts for gift processing from the operating account to the advancement account. To be completed by January 1, 2023. - The Sr. Accountant and the Workday Team are in the process to design a system to fully automate the cash receipt and reconciliation process in the ERP. Document the key controls in the automated system which will remediate the findings identified. Additionally, reoccurring reconciling items should be clearly identified to ensure system is designed to recognize them and minimize these types of items. - The Controller will update the cash management and reconciliations standards or policies and key controls that ensure policies are in place and effective based on new workflows and processes. Corrective Action Plan for Federal Funds 22-003 Higher Education Stabilization Fund (HEERF) Reporting Auditor?s Findings and Recommendation Condition: HEERF reporting was not always done accurately or timely. During the audit it was noted that College did not continue to update their website with the HEERF reporting requirements as listed in their grant agreements. The first and second quarterly reports for institutional funds (quarters ended September 30, 2021 and December 31, 2021) was not completed for HEERF II. Criteria: 2 CFR 200.329, 86 FR 26213 the College was required to post the Institutional Quarterly Report to their website within 10 days of the end of quarter in which the funds were spent. Cause: Turnover in staffing. There were multiple rounds of HEERF funding released, each with different requirements, which led to a gap in understanding of the requirements of the HEERF reporting. Effect: The College was not in compliance with the r

Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number: (219) 836-9111 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There has been turnover in the finance department and the past employees who would have been responsible for this are no longer here. There are already internal controls in place to ensure that the monthly sponsor claims submitted match the school?s meal count reports. The Treasurer will continue to ensure that everything is correctly entered before submission. Anticipated Completion Date: March 2023

The College will update the September 30, 2021 quarterly report currently posted on the website to include the estimated number of students eligible for HEERF funds. The College will post an additional report for the quarter ending June 30, 2021, indicating the receipt of funds and that no funds were distributed during the quarter.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Gerri Ford Contact Phone Number: 812-937-2400 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will prepare the annual reports and ensure the amounts agree to the accounting records. The annual reports prepared by the Corporation Treasurer will be provided to the Director of Learning who oversees the Elementary and Secondary School Emergency Relief (ESSER) grant to review and approve the amounts reported are accurate. After review and approval from the Director of Learning, the annual reports will be submitted by the Corporation Treasurer. Anticipated Completion Date: May 2023

Corrective Action Plan in Response to Single Audit Finding Year Ended December 31, 2022 Type of Finding: Internal Control - significant finding; Compliance ? significant finding Recommendation: The Organization should improve processes and procedures to ensure that quarterly reports required by the pass-through entity are completed and submitted on a timely basis. Reference Number: 2022-001 View of Responsible Officials: Management agrees with the finding and recommendation. Corrective Action Plan: Management will review reporting requirements on the contracts and develop a timetable to ensure that the reports are prepared and submitted to the funder in compliance with the deadlines in the contract. Contact Person: Brent Arakaki, Chief Financial Officer, Telephone number: (808)792-8585, Email: barakaki@higoodwill.org Anticipated Completion Date: August 31, 2023.

Finding 2022-005 Federal Agency Name: Department of Education Program Name: Education Stabilization Fund ALN 84.425 Finding Summary: During our testing, we noted the following issues over reporting: ? The financial data reported in the some of the quarterly reports posted for the institutional portion were not supported by the underlying trial balance activity. Responsible Individuals: Courtney Judah, Director of Institutional Effectiveness Corrective Action Plan: During internal audit of disbursements, the College identified several student disbursements that should have been recorded as emergency funds granted under the intuitional portion and not student portion. Journal entries were made to correct and change the award to the institutional portion, but failed to update the prior term report. To prevent future communication errors the team revisited the process and added a reviewing and updating of reports from prior periods. Management meet with the Grant Administrator and attended 2 webinars throughout the year to improve reporting process. Anticipated Completion Date: December 30, 2022

FINDING 2022-007 Contact Person Responsible for Corrective Action: Mary K. Kaczka, Assistant Director, Community Development Contact Phone Number: 574-322-4472 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Financial Reporting: Management has developed the following process to correct for the lack of evidence for review or approval for reports that are submitted: Staff responsible for preparing the report in IDIS and management responsible for review for accuracy and completeness will both sign appropriate documentation detail (PR 5 and PR 7, draw spread sheets, draw vouchers) supporting the Cash on Hand Report and the IDIS report. CDBG staff has consulted with HUD CPD staff for additional training on how to complete the PR 26 report. The training assisted staff in filing two (2) past due reports and resulted in changes to the reporting process utilized by staff. Performance Reporting: Management will address the performance reporting weaknesses by taking the following steps: The assistant director of community development will document the segregation of duties for the completion and submittal of the CAPER before submission to HUD. Documentation will consist of a clear and understandable workflow on City workpapers, and final submissions, evidenced by signature (ink or digital stamp), email string other generally acceptable audit trail. Additionally, as part of continuing education, CDBG staff participated in a workshop organized by our CDBG consultant this past June, 2023 to better understand the Section 3 reporting requirements. Special Reporting for Federal Funding Accountability and Transparency Act (FFATA): Management will address the weaknesses identified in Special Reporting for Federal Funding Accountability and Transparency (FFATA) by taking the following actions: Management will review and strengthen the current process in place for identification and timely submission of projects that qualify for FFATA reporting. Completed reports will show evidence of segregation of duty for completion, and review and approval. Anticipated Completion Date: August 31, 2023

FINDING 2022-003 Contact Person: Jo Ann Treon Phone Number (765)948-4632 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: Forms RD 442-2 & RD Form 442-3 will be completed in August 2023. Anticipated Completion Date: Immediately

FINDING 2020-002 Contact Person Responsible for Corrective Action: Shelly Harrison, Corporation Treasurer Contact Phone Number: 765-492-5102 Views of Responsible Official: We concur to the findings; however, while completing the ESSER Reports, some formatting errors of the provided spreadsheet created some questions by the North Vermillion officials prompting a clarification email to the DOE. Since the formatting errors were not addressed and all completed boxes on the North Vermillion ESSER Report spreadsheet turned green (indicating the correct amounts on the spreadsheet), the North Vermillion officials felt the ESSER report submitted was correct. Description of Corrective Action Plan: To correct the internal control issue, the Superintendent and Corporation Treasurer will work independently as well as collaboratively on the ESSER Reports. Prior to submitting any future report, the corporation officials will document their work by signing off and dating the report prior to submission to the DOE. To rectify the incorrect dollar amount on the Yearly ESSER Report Spreadsheet, the corporation treasurer and superintendent will work collaboratively to correct the amounts on either the ESSER I Year End Report and the ESSER II Year 2 and/or Year End Report. Anticipated Completion Date: Both the Internal Control and ESSER I corrective actions have been corrected, with the ESSER I Final Expenditure Report being completed and signed off on. The ESSER II corrective actions will be completed on the upcoming ESSER III Year End Report when that report is due.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Jennifer Barcus, Corporation Treasurer. Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Corporation Treasurer will begin reviewing all annual data reports completed by the Superintendent, prior to submission of the reports, to verify that all expenditures are reported in the correct reporting period. Anticipated Completion Date: Immediate review will begin of all annual data reports.

Finding 2022-001 (L - Reporting) US Department of Homeland Security, Federal Emergency Management Agency, Assistance Listing 97.036 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Name of contact person: Rob Tonkinson, Vice President, Corporate Finance Corrective action: The Vice President, Corporate Finance will review and approve all quarterly and other required reports prior to submission. Proposed completion date: November 30, 2023

FINDING 2022-001: Timelv Financial Close As noted in Finding 2022-001, the cause of the delay in closing was primarily a lack of staff and the inability to recruit sufficient knowledgeable staff. Since that time all vacant positions in the Finance Department have been filled. Planned Corrective Action: Landmark has analyzed its staffing level and determined that the current positions when fully staffed are sufficient to complete the financial closing in a timely manner. However, Landmark will continue to monitor its staffing and adjust as deemed necessary. FINDING 2022-002: Accurate Quarterly Reporting All HEERF quarterly reports were filed in a timely manner and in accordance with the guidance available at the time. As soon as Landmark became aware of the updated guidance, amendments were prepared. Planned Corrective Action: Landmark has amended and filed all HEERF reports as necessary to comply with current guidance.

2022-001 ? COVID-19 ? Education Stabilization Fund - Significant Deficiency in Reporting Recommendation: The School should assign an individual to monitor reporting requirements of HEERF awards to ensure the School is in compliance. Planned Action The School plans to review enhance processes related to HEERF reporting to ensure compliance with the requirement of Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Section314(e) of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and 2 CFR sections 200.328 and 200.329. Proposed Completion Date: The School will review processes to ensure we are in compliance by March 15, 2023.

Higher Education Stabilization Fund (HEERF) Reporting Planned Corrective Action: Corrected quarterly reports will be completed and the practice will be maintained for any future funding received. Person Responsible for Corrective Action Plan: Cindy L. Weaver, Interim CFO/Director of Finance Anticipated Date of Completion: July 25, 2023

Finding Number: 2022-004 Condition: The University did not file accurate and timely reports throughout the fiscal year. Planned Corrective Action: 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required. Contact person responsible for corrective action: Colleen Scarff, Assoc VP for Business and Finance and Lana Greaves, Senior Associate Director, Student Financial Services Anticipated Completion Date: 3/24/23

Recommendation: The College should review the reporting requirements and implement procedures to ensure that all required reports are issued / posted in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A review of the Department of Education?s reporting requirements for the HEERF Student funding has been completed, by all parties involved. The missing reports are finalized and posted to the College?s internet. The Financial Aid and Financial Services-Grants departments will monitor communication from the Dept of Ed, sharing information received by each, thereby ensuring future reporting requirements are fulfilled. Name(s) of the contact person(s) responsible for corrective action: Christian Zimmerman Planned completion date for corrective action plan: April 20, 2022

FINDING 2022-008 Contact Person Responsible for Corrective Action: Danica Houze, Chief Financial Officer Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Documentation will be kept to ensure evidence of preparation, review, and approval of the Grant Reporting. Two individuals will sign off on all future reports and documentation will be kept on file. Anticipated Completion Date: 2/13/2023

FINDING 2022-002 Program: COVID-19: Coronavirus State and Local Fiscal Recovery Funds CFDA No.: 21.027 Federal Grantor: United States Department of the Treasury Passed-through: N/A Compliance Requirements: Reporting Auditor Recommendation: We recommend the City enhance internal controls to ensure Interim and Project and Expenditure Reports are prepared in accordance with program requirements. Views of Responsible Officials and Corrective Action: We concur with the recommendation and will enhance internal controls to ensure that the Interim and Project and Expenditure Reports are prepared in accordance with program requirements. During this reporting period, there was no clear direction from the State on how to submit prior period corrections, so to achieve this action, City staff submitted a zero ?current expenditure? and then included the prior period adjustment in the cumulative total. Since the audit found that this was the wrong process and a deficiency in reporting, the City will reach out to the State for assistance in reporting prior period corrections. The City will ensure a thorough review prior to submitting to ensure the report is accurate. The City also encountered reporting difficulties for the quarter ending 6/30/2022 with entering vendor information. City staff contacted the State to request assistance, however the State was overwhelmed with requests from agencies state-wide and was not able to respond to the City?s request in a timely manner. The State was aware of the issues and had allowed Cities to submit their report late. The City has not had any issue subsequent to the 6/30/2022 report and has been submitting its report timely. Name of Responsible Person: Kim Sao, Finance Director Implementation Date: 6/30/2023

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Monica Kegerreis, Assistant Superintendent Contact Phone Number: 574-831-2188 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The ESSER reports requested by IDOE will follow the same procedures of all FER reports. The ?data collection? for the ESSER grants was not identified as a financial report, and thus did not follow these processes. Now that we know this is a financial report, the steps below will be followed. The grant was initially not set up correctly and expenses were expended to and then transferred to the correct accounts once the grants were set up correctly. These changes were in flux when the report was requested, so what was reported at the time of the report is no longer what is reflected in grants? ledgers. The corrective action will require that the program director gathers the initial data, the data will be reviewed by the administrative assistant to the grants? director, and then reviewed by the Treasurer. All three employees will sign/initial a printed copy of the report before it is submitted. Data regarding students served by programs and staff reports will be reviewed by the program director and the data specialist and signed off on by both parties to ensure accuracy. Anticipated Completion Date: March 24, 2023

Finding 2022-01: COVID1-19 Education Stabilization Fund, Higher Education Emergency Relief Funds ? Reporting Program: COVID-19 Education Stabilization Fund Federal Agency: U.S. Department of Education Pass Through Entity: Not Applicable Assistance Listing Number: 84.425E, 84.425F Federal Award Number: P425E200445 Federal Award Year: June 30, 2022 Condition: The College did not post the required quarterly reports for the Student Portion. Additionally, during the audit, it was noted that the College was unable to provide a copy of the annual report and supporting documentation for the year ended December 31, 2021. Corrective Action Plan Management agrees with the finding, and is committed to strengthening its procedures to avoid similar issues in the future. Quarterly reports for the Student Portion have now been posted on the College website. Turnover in finance department staff resulted in difficulty locating copies of reports submitted by former staff. New staff will be trained on the Department?s HEERF requirements to ensure accurate and timely future reporting.

Finding Number: 2022-002 Planned Corrective Action: The Business office has endeavored to keep pace with the shifting and changing guidance that is promulgated by the Department of Education. This has been a challenge. The Chief Financial Officer continues to monitor any guidance updates and make the appropriate changes to the reports to ensure their accuracy. There was only one report posted that contained one typographical error, but it is the University?s responsibility to ensure the accuracy of the reports and these reports will be monitored more closely going forward. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin