Corrective Action Plans

FINDING 2022-006 Contact Person Responsible for Corrective Action: Schauna Relue Contact Phone Number: 260-665-2854 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: Effective Immediately; Completion will occur when the next report is requested.

Condition: For the annual report covering January 1, 2021 through December 31, 2021, a number of the HEERF section (a)(1) and (a)(3) amounts reported as institutional portion spending were incorrect based on supporting documentation provided by the University. In addition, for the fourth quarter 2021 (quarter ending December 31, 2021) and the first quarter 2022 (quarter ending March 31, 2022) institutional portion reports, the University reported the full amount of section (a)(1) student portion of HEERF awarded to the University on the section (a)(3) line, when the amount on the section (a)(3) line should have been the total Fund for the Improvement of Postsecondary Education (FIPSE) funding awarded to the University. Also, for the quarterly student portion reports, the University reported the incorrect number of students who were eligible to receive a CRRSAA emergency financial aid grant during the fall of 2021. Corrective Action: We have updated our procedure for preparing and reviewing the required reports, and we have established a team from the finance department to discuss issues that arise. The team will handle the identified discrepancies through their resolution. The team will meet at least monthly, and as requested by the Senior Accountant of Grants or the Director of Finance and Accounting (DFA). The team is receiving training on procedures, guidelines, and terminology to ensure accuracy on completed reports to ensure compliance. The updated procedure is that the Senior Accountant of Grants will prepare the quarterly and annual reports based on data provided in the accounting system and from the Office of Financial Aid and assure that the reported data ties to the University?s records. The completed reports will be reviewed by the Director of Finance and Accounting. When needed, the finance team will meet to handle apparent discrepancies. Approved reports will be returned by the DFA to the Senior Accountant who will then post the reports for public viewing and submit a copy to the funder. Person Responsible For Corrective Action: Cedric Lewis, Director of Finance & Accounting Anticipated Completion Date: June 30, 2023

Higher Education Stabilization Fund Reporting Planned Corrective Action: We uploaded the quarterly report for the use of the ARP student portion on the institution?s website late in August 2022. Now that both the student portion and the institution portion are required to be reported on one quarterly report provided by the Department, we will make sure the report is filed on time and concurrently post it on the institution?s website. Person Responsible for Corrective Action Plan: Diane Ahn, VP for Finance and CFO Anticipated Date of Completion: Completed

FINDING 2022-002 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Micah Williams Contact Phone Number: 765-832-2426 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Finance and Facilities and Payroll Personnel Director will work together to confirm the information to be submitted in regards to the ESSER/GEER Funds. Both will sign off on the information. The information will then be reviewed by the Director of Curriculum and Superintendent to ensure that the reporting is accurate. Additionally, one of those individuals will sign off on the reporting. Anticipated Completion Date: Implemented Immediately

2022-004: Higher Education Emergency Relief Funds ? Assistance Listing No. 84.425F, 84.425M Recommendation: We recommend the University review its policies and procedures for the filing of the HEERF to ensure that there is sufficient time in the process to meet the due date in accordance with the stated criteria. The evidence of submission should include the original supporting documentation for the information published. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has scheduled data gathering and reconciling processes to ensure timely 2023 filing. Name(s) of the contact person(s) responsible for corrective action: Michael Moos Planned completion date for corrective action plan: 06/30/2023

Finding No. 2022-002 Corrective Action Plan University Response: The University concurs with the finding concerning quarterly reporting of HEERF funds. Corrective Action: Rockhurst will conduct an additional review of the released guidance and reporting requirements to ensure compliance of any published, missing or future reports. In accordance with HEERF guidance, any reports with expenses that were incorrectly reported will be revised and publicly published, if applicable. Responsible Official: Kris Pace, Controller Anticipated Completion Date: June 30, 2023

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.

FINDING 2022-004 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Hunt Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: LaPorte Community School Corporation will review the Education Stabilization Fund schedule of disbursements more closely prior to submission. Anticipated Completion Date: May 15, 2023

Corrective Action Purchased orders will be prepared with the correct accounting code to reflect expenditures in the right budget line items. Person(s) Responsible Shontell McQueen, Finance Coordinator; Leslie Baynes,Chief Finance Office; Bima Baje, School Business Administrator Planned Completion Date As of July 2022, corrective action has been implemented.

All federal Project and Expenditure reports were filed timely and all actual expenditures were also reported correctly according to the report overview page. This finding deals with the body of the report which incorrectly listed the Justice Center Project twice, with the obligation amount of $880,00 listed for the project. This duplicated project has been removed from future reports. The finding noted for $175,741, once again has all the correct totals in project overview report, which should be the summation of the report. We have been rehiring staff with American Rescue Plan funds since 2021, and this has been an ongoing project. Once again, the report overview page lists the correct expenditures, however the body of the report has the project listed twice. This duplicated project has been removed from future reports. The reporting software gives a total of expenditures before you hit submit on each report, this total has always displayed the correct cumulative expenditure total. If projects were entered twice, the total expenditures should of been over by these dollar amounts, and they were not.

The finance office will ensure proper education and administration of HEERF grant requirements. Cross training and education will occur with the College?s administration and business office to ensure regulatory standards and requirements are met. Future grant requirements will be noted on planning calendars, discussed at monthly meetings, and reviewed for assignment and compliance. Cross coverage will be planned with the financial aid office and senior accountant as needed for reporting deadlines.

No yellow book findings noted in the current year. Single Audit Finding 2022-001 Federal Agency Name: Department of Education Federal Financial Assistance Listing: 84.425E, 84.425F Program Name: COVID-19: Higher Education Emergency Relief Student Aid Portion, COVID-19: Higher Education Emergency Relief Institutional Portion Reporting Significant Deficiency in Internal Controls over Compliance Finding Summary: During the testing over the reporting for the HEERF student and institutional funds, the reports that were required to be filed during the fiscal year were not filed by the required timeframe. Responsible Individuals: Director of Budgeting; HEERF Operations and Policy Analyst Corrective Action Plan: Management agrees with this finding. The University has resolved the delinquent status of the reporting for periods during fiscal year 2020-21 as of September 2021. In October 2021, the University hired a HEERF Operations and Policy Analyst (Analyst) to oversee the HEERF compliance requirements including reporting. Additionally, the Director of Budgeting is responsible to monitor the timely reporting of subsequent reports. Anticipated Completion Date: Completed in October 2021.

Finding 2022-002 Reporting ? The Executive Advocate (Tony Metz) will review newly signed con tracts for programmatic report requirements and enter the due dates into the tracking spreadsheet. ? Each staff member with responsi bility for completing reports will have access to the tracking spreadsheet document. ? The Executive Advocate will remind the team member responsible for completing the report two weeks before the due date. ? The assigned staff member will complete the report, submit the report, and mark the submission date in the tracking spreadsheet. ? The Execu tive Advocate will be responsible for monitoring th e submission of reports and alerting the Chief Executive Officer prior to any missed deadlin es. This process will be reviewed by the Finance Committee and approved by the Quanada Board of Trustees as part of our Fiscal Policy document.

Logan Acres maintained detailed separate financial records within the Finx Authority accounting system. Accurately accounting the revenue and expenditures in its operating fund. All grant receipts will be tracked through a separate Fund account established by the Auditor’s office. Logan Acres will request a new Fund account to be established by the Logan County Auditor’s office for each individual grant allocation it receives.

The College has implemented procedures in which the Manager, Business Operations will work with the Director of Financial Aid to ensure that all HEERF quarterly reports depict accurate data. The Dean, Student Affairs and Enrollment will verify the accuracy of these reports prior to submission.

Finding 2022-004: Internal Control over Compliance and Compliance with Reporting (Preparation of Schedule of Expenditures of Federal Awards) Finding: The SEFA as prepared by management did not originally include one federal grant with federal expenditures during the year and one grant for which the Assistance Listing Number (ALN) did not match the grant documents. Corrective Action: Compare all contract or award letters for accurate information reported on the SEFA prior to submission. Contact: Carmen Stevens, Finance Director Expected Completion Date: 11/30/2023 If you have any questions, please contact Carmen Stevens at 713-472-0753 or by email at cstevens@tbotw.org.

The input error was corrected prior to end of the audit. The credit union's CDFI analyst was contacted by the Chief Strategic Officer and the analyst opened the data field for editing in the AMIS system. The Chief Strategic Officer made the correction in the AMIS system and submitted the corrected information. The Chief Strategic Officer has assigned CDFI reporting responsibiities to the Director of Strategy. Future submissions will be performed by the Director of Strategy and reviewed by the Chief Strategic Officer prior to submission. Executive Responsible - Brady Popp, Chief Strategy Officer Projected Completion Date - Completed prior to the close of the audit

Corrective Action Plan: PREMA will establish and document formal procedures for the preparation, review, reconciliation, and timely submission of SF-425 Federal Financial Reports for EMPG grants by implementing a report reconciliation checklist requiring agreement of reported data to PRIFAS and SEFA records, ensuring each report includes federal and recipient share, drawdown activity, and unliquidated obligations, designating an official responsible for report review and approval prior to submission with evidence of filing retained, and providing staff training on federal reporting requirements under 2 CFR 200.327–200.329 to improve accuracy, completeness, and compliance in federal financial reporting. Lead Person: Maritza Torres, Fiscal Area Director, and Contractors (Robles & Assoc.). Anticipated Completion Date: December 2025.

Management has contracted with a contract accountant who has already started audit preparation services for future audits. The 2022 has been started and will be completed shortly. The 2023 audit will be started shortly. The Native Village expects to be fully caught up by their fiscal year 2025 audit.

Management will ensure that all required grant reporting, both financial and/or narrative/programmatic will be prepared and submitted timely. The final reporting for the Treasury CARES ACT has been completed and submitted subsequent to year end.

2021-003: Internal control failures including two employee timesheets being unreviewed by agreed-upon personnel. Recommendation: We recommend management ensure all internal control procedures are being followed as outlined. Action Taken: Management agrees with this finding and has implemented a stricter system of internal control procedures to prevent further instances of recurrence. Name of Person Responsible for Corrective Action: Frances Tribble-Adams, Finance Manager. Anticipated Completion Date of Corrective Action: July 1, 2021.

2021-002: Auditee has improperly tracked grant awards and expenditures. Recommendation: We recommend the WDBEA maintains an effort to properly track and report federal awards and expenditures. Action Taken: Finance Manager, Frances-Tribble Adams, has taken appropriate action and has reconciled accounting records to ensure grant revenues and expenditures are adequately tracked in the future. Name of Person Responsible for Corrective Action: Frances Tribble-Adams, Finance Manager. Anticipated Completion Date of Corrective Action: July 1, 2021.

Finding 2021-007 Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Program Director Jacy Hyde, Executive Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Program Director Corrective Action Plan: • Clark Nuber has reviewed the current closing and reporting policies and procedures. Clark Nuber’s proposed updates and revisions will be reviewed and approved by CFSC Management and thereafter implemented by CFSC staff. • CFSC will be considering an automated AP and approval processes through Bill.com or another similar provider to determine whether a provider of this nature will assist in more timely expenditure recognition workflows. • CFSC will update its fiscal reporting policies and procedures to direct that all reports are reviewed by both the grant manager and finance manager to ensure all known expenses are included and that the Schedule of Expenditures of Federal Awards is properly prepared in accordance with the Uniform Guidance. • CFSC will be doing a full review of policies and procedures to ensure they are compliant with GAAP and Uniform Guidance requirements. • The Board of Directors has approved hiring three additional Financial Staff to improve capacity for reporting. Anticipated Completion Date: CFSC will establish and implement the enhanced policies and procedures by the end of Q2 of 2024. CFSC aims to fully onboard additional Finance Staff in Q2 of 2024.

Finding 2021-006 Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jessica Martinez, Program Director Joel Rusco, Chief Financial and Administrative Officer Jacy Hyde, Executive Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Program Director Corrective Action Plan: • CFSC retained Clark Nuber to review current reporting policy and procedures. Clark Nuber’s recommendations will be reviewed and approved by CFSC management and thereafter implemented by all CFSC staff. • CFSC will implement the updated policy, procedures, and tracking mechanisms to ensure all grant progress reports are submitted to managers prior to the due date for review, approval, and timely submission to the funding agency. • CFSC is conducting a full review of policies and procedures to ensure they are compliant with GAAP and Uniform guidance requirements. Anticipated Completion Date: CFSC will establish and implement the new policies and procedures by the end of Q2 2024.

U.S. Department of Health and Human Services 2021-003 Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: The auditors recommend that the Organization design, implement and monitor internal controls over reporting as well as maintain source documentation to support amounts reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will maintain evidence of timely submission of reports, review of reports and documentation to support amounts reported. Additionally, management will implement a formal documentation retention policy. Name of the contact person responsible for corrective action: Lyn Elliot, CEO Planned completion date for corrective action plan: 3/1/2024