Corrective Action Plans

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

FINDING 2022-017 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school corporation will develop a protocol for ensuring that all documentation and records regarding Federal Grants will be maintained for a period of three years. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in September 2022.

FINDING 2022-014 Contact Person Responsible for Corrective Action: Tricia Malone Hudson, District Curriculum Specialist Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: The school district has established a process for reviewing reimbursements and district expense records to ensure alignment. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure beginning in January 2023.

Views of Responsible Officials and Planned Corrective Action - Administration concurs with the findings. The College has corrected the website disclosure of number of students receiving Aid Grants under the program. The College will review and confirm accuracy of any future report submissions. Anticipated Completion Date: May 31, 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Kyle Zahn Contact Phone Number: 765-883-5576 ext. 5112 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As ESSER reports and reimbursements are completed the supporting documents will be kept with the reports. Prior to submission, reports completed and documentation compiled by the Director of Finance will be reviewed by the Director of Exceptional Learners and Testing and vice versa. Anticipated Completion Date: February 2023

FINDING 2022-001 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 Award No. and Year: Various Compliance Requirements: Reporting Management?s or Department?s Response: We concur. Views of Responsible Officials and Corrective Action: The City reported expenditures for the entire award amount based on the guidance available at the time of the initial reporting period for the award. This resulted in over reporting expenditures for the audit period since only half of the award was remitted to the City during the period under audit. The City has put measures in place to ensure only expenditures for the amount received in a particular period are reported. Name of Responsible Person: Kofi Antobam, Director of Administrative Services Implementation Date: June 30, 2022

Corrective Action Plan - Finding 2022-002 We agree with the finding and observations, which are consistent with Finding 2021-002, and specifically note the following coorective actions that were implemented subsequent to June 30, 2022: - The Chief of Staff will contact the DOE to determine if past reports not filed should be submitted at this time and if reports filed with incorrect amounts should be corrected. - The Associate VP for Finance & Controller will review HEERF repoting requirements to ensure any future reporting required is submitted on a timely basis. - The Associated VP for Finance & Controller will review any future reporting for HEERF funds before submission to ensure they reconcile to the College's accounting records. Responsible Official - Gillian King, Chief of Staff Anticipated Completion Date: Completed

REPORTING West Virginia Division of Rehabilitation Services (WVDRS) Assistance Listing Number 84.126 WVDRS will review current RSA-17 approval procedures by April 2023 and make appropriate modifications as necessary to ensure all evidence of report approval is maintained within our records.

Finding 2022-006: Reporting Federal Agency Name: Department of Health and Human Services CFDA #93.829 Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Finding Summary: Through testing of one programmatic report, the number of adults and children served during the reporting period included six individuals twice. As a result of a software change during the grant year, management combined the listing of adults and children served from two electronic health record systems and did not identify these six individuals were duplicates in the listings. Responsible Individuals: Project Directors (Missy Martini, Rebecca McCrackin) and CEO (Dan Ries) Corrective Action Plan: CEO will review reports prior to submission and will do random testing of numbers included in the report to ensure numbers reported have supporting documentation. Documentation used to complete the required reports will be retained by the Center. Anticipated Completion Date: This process was implemented beginning January 2023.

Finding 2022-004: Reporting Federal Agency Name: Department of Health and Human Services CFDA #93.087 Program Name: Enhance Safety of Children Affected by Substance Abuse Finding Summary: Through testing of one programmatic report, amounts reported did not agree to supporting documentation. Programmatic information included within the report were included in the wrong category for services provided to adults and children and amounts were included in two categories for services in which no adults or children were provided services. The preparer of the report improperly input the case sizes within the incorrect column within the report and entered incorrect information in two instances. The report included programmatic information in the wrong categories for services provided and services not provided to adults and children. Responsible Individuals: Project Directors (Christina Eggink-Postma, Sarah Heinrichs) and CEO (Dan Ries) Corrective Action Plan: CEO will review reports prior to submission and will do random testing of numbers included in the report to ensure numbers reported have supporting documentation. Documentation used to complete the required reports will be retained by the Center. Anticipated Completion Date: This process was implemented beginning January 2023.

Recommendation: We recommend that the University post and maintain the Student Aid Quarterly reports on the University?s website, as required. In addition, in order to prevent similar instances in the future, we recommend the University ensure interpretation of guidance is accurate through use of trainings, consultations and direct correspondence with the regulatory agency, when necessary, to ensure full understanding of reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university agrees. OSU reported the HEERF student aid portion quarterly on our reporting webpage. We initially interpreted the guidance to mean that at each quarter we should update the report the total student portion on the webpage to be cumulative and the previous quarter report was removed from the website. OUS will go back and report each quarter separately instead of as one aggregate total. We will post this data on the current reporting page by February 10, 2023. Name of the contact person responsible for corrective action: Keith Raab, Director of Financial Aid Planned completion date for corrective action plan: February 10, 2023

December 9, 2022 Aldrich CPAs + Advisors LLP 7676 Hazard Center Drive, Suite 1300 San Diego, CA 92108 RE: Corrective Action Plan Dear Aldrich, The following are responses to the finding identified in Union of Pan Asian Communities (UPAC) audit for the year ended June 30, 2022: 1) Finding 2022-001 a. Program Information: 93.778 Medicaid Cluster ? Medical Assistance Program, Pass-Through Awards #560005 and #555861 b. Criteria: In accordance with 2 CFR 200.329, non-Federal entities must submit performance reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report. c. Condition: During our audit, we identified two quarterly status reports that were submitted to the Contracting Officer?s Representative (COR) after the stated due date. Response: UPAC has put in place to email those staff who are responsible for submitting the performances reports to the Contracting Officer?s Representative a few days before the stated due date. Contact persons responsible for corrective action: 1) Annette Phan, Chief Financial Officer 2) Manuel Mercado, Staff Accountant Completion date: Additional internal control procedure noted above will be effective immediately. Sincerely, Margaret Iwanaga Penrose Chief Executive Officer Union of Pan Asian Communities

2022-002 Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Auditor Recommendation: We recommend management attend Federal award trainings and information to ensure the documented policies and procedures can be performed as described. This will ensure the Federal funds are reported accurately on the SEFA and that programs are reported under the correct assistance listing number. Corrective Action: The year ended August 31, 2022 was the first year in which the Center expended federal awards in excess of the limit that requires a Single Audit. Since receiving the EIDL loan, the Center maintained detailed tracking and documentation of all disbursements associated with the loan and understood such expenditures exceeded the $750,000 threshold for a Singe Audit during the fiscal year ended August 31, 2022. With the clarification of the specific rules surrounding the disclosure of EIDL loans on the SEFA, management will continue to review Federal Award guidance and requirements to ensure compliance with current and future federal awards. Name of Responsible Contacts: Larry Goodpaster, Director of Finance & Operations, and Kelly Martin, Accounting Manager Projected Implementation Date: May 1, 2023 and ongoing

Finding Number: 2022-001 Untimely and Inaccurate Reporting - Planned Corrective Action: Management met with assigned Department of Education grant representative via telephone and received instructions for submitting revised quarterly HEERF reports. The Controller will revise all applicable quarterly reports for review and approval by the Chief Financial Officer. Management will re-submit the reports to the Department and post on the College's website as required. Person Responsible for Corrective Action Plan: Quintress Hollis (Controller). Anticipated Date of Completion: April 30, 2023.

FINDING 2022-005: CAFETERIA NUTRITION CLUSTER REPORTING The Deputy Treasurer prints, verifies, initials the Employee Trial Balance Report (Payroll Report) every pay period. The Treasurer reviews these reports, but has not initialed them. Corrective Action Plan: The Treasurer will begin reviewing and initialing these reports for FY 2023. The Cafeteria Director will submit the child reimbursement form to Central Office for review and verification prior to submission for payment to the Indiana School Lunch Program for FY 2023.

FINDING 2022-008 Contact Person Responsible for Corrective Action: Dan Durrwachter Contact Phone Number: 765-473-3081 Views of Responsible Official: We agree with these findings. Description of Corrective Action Plan: The financial specialist will prepare a report the data for the reports and will be approved by the treasure to ensure accurate FTE is reported before submitting the reports. Anticipated Completion Date: : 6/01/2023

FINDING 2022-009 Contact Person Responsible for Corrective Action: Whitney Dixon, Treasurer Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Documentation to support reporting data will be prepared by the business office. Full-time equivalent positions will be reviewed by the Human Resources department to ensure that the FTE positions reported are accurate. This will be signed by the preparer, Human Resources, and the program administrator. All ledger expenditures will be included in any report requirement. The prepared report and supporting documentation will be reviewed and approved by Assistant Superintendent, Tracey Noe. Anticipated Completion Date: May 2023

The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance

County Judge/Executive?s Response: The fiscal court would like to point out that ARPA funds were properly distributed. During this time there was little guidance on how to manage the reporting. All reporting has been corrected.