Corrective Action Plans

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.

FINDING 2022-013 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 district will develop a system for reviewing the Real Time report to ensure accuracy. In addition, the district will maintain a copy of the participating nonpublic school?s summary data related to enrollment and poverty status. Anticipated Completion Date: North Lawrence Community Schools will implement this procedure by June 2023.

FINDING 2022-010 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 will develop a plan for tracking employee pay and timecard alignment. The district will ensure that these documents are available to auditors. All expenditures will have a cover sheet with identifying information, will be attached to the proper invoice(s), signed by 2 parties, and hard copies will be kept on file for audit purposes in folders attached to each grant. Anticipated Completion Date: North Lawrence Community Schools will implement this procedure by June 2023.

FINDING 2022-007 Contact Person Responsible for Corrective Action: Melissa Hinds, Director of Special Education Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to cash management for the Special Education Cluster (IDEA), the District?s Treasurer and Special Education Director will review all cash balances quarterly to verify compliance with the grant agreement. As of July 2022, internal controls were put into place to ensure supporting documentation was attached to all reimbursements. Anticipated Completion Date: March 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Robyn Muder, Director of Business Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Supporting documentation for all transfers out of the Food Service account are kept in a labeled folder. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure in 2022.

FINDING 2022-003 Contact Person Responsible for Corrective Action: Robyn Muder, Director of Business Contact Phone Number: 812-279-3521 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: Internal controls were updated in 2022. All supporting documentation is attached to vouchers for more efficient and effective business practices. The financial software was updated in January of 2023 to keep fringe benefit information retained. North Lawrence Community Schools has implemented a new procedure to pay mileage as a vendor payment instead of reimbursement through payroll to keep it separate from employees? gross earnings. North Lawrence Community Schools has implemented new practice to send all salary employees contracts which must be signed and kept in their personnel files. North Lawrence Community Schools has implemented new practices to prevent employees from being off of the board approved hourly pay schedule. North Lawrence Community Schools no longer utilizes paper timesheets. We now use an electronic time clock system. North Lawrence Community Schools is updating direct deposit information for all employees. Anticipated Completion Date: North Lawrence Community Schools implemented this procedure in 2023.

Identifying Number: 2022-02 Finding: HEERF Activities Allowed or Unallowed While testing activities allowed or unallowed in the audit of 2020-2021 award year, we noted that there was a lack of a written plan to provide objective criteria for the distribution of funds until April 2022. Corrective Actions Taken or Planned: School now has a documented plan on file for disbursing HEERF funds. Contact Person: Lynn LeMoine Dean of Students ? Nick Anderson Director of Financial Aid Anticipated Completion Date: 4/11/2022

FINDING 2022-008 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: Vendor claims with supporting documentation will be retained by the business office. Requests for reimbursements including supporting documentation, including financial and programmatic records, will be retained to verify allowable activities or costs. Anticipated Completion Date: May 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

FINDING 2022-003 Contact Person Responsible for Corrective Action: Christopher Dixon, Director of Nutrition Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will document the review/oversight of disbursements from program funds prior to payment. Claims will be prepared and reviewed by Christopher Dixon, Director of Nutrition, or designee, and submitted to the Accounts Payable Specialist for payment. Claims will be initialed or signed demonstrating approval of disbursements. Accounts Payable Specialist enters claims into the financial software and pays claims after approval by the Chief Financial Officer and School Board. Documentation for claims will be kept in the business office. GCS will obtain prior written approval from IDOE and approval documents will be maintained by the Director of Nutrition. Assistant Superintendent, Dr. Barry Younhans, retired from GCS in July 2022. This corrected the finding. To ensure compliance, the payroll distribution report is reviewed and signed by the Treasurer and applicable program administrators prior to the completion of payroll by the payroll specialist. The report is reviewed to verify that employees are paid out of the correct accounting line. This process was implemented in December 2022. Anticipated Completion Date: April 2023 INDIANA STATE

Views of Responsible Officials and Planned Corrective Actions Each quarter, Indiana Afterschool Network will develop an estimated allocation of each employee?s personnel expense to each source of funding, including federal funds. The estimated allocation will be based on the employee?s work plan for the upcoming quarter. The estimated allocation will be retained in IAN?s electronic Dropbox files for a period as long as the funding sources? longest document retention requirement. Each pay period, IAN will review the estimated personnel expense allocation to determine whether each employee?s actual time was spent as estimated at the start of the quarter. IAN supervisors will conduct this review for each employee on their team. The supervisors will document the actual grant allocation for each employee on their team, and the documentation will include their approvals. The supervisors will provide these approvals to IAN?s CFO. The CFO will retain the approvals in IAN?s electronic Dropbox files for a period as long as the funding sources? longest document retention requirement. The CEO will be responsible for implementation of this correction. The CFO will oversee the process once implemented. Sincerely, Lakshmi Hasanadka Chief Executive Officer

Assistance Listings numbers and names 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Aid Portion 84.425F COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Institutional Portion 84.425L COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Minority Serving Institutions (MSIs) Award Number and Years P425E200055, April 20, 2020, through June 30, 2023 P425F201359, May 6, 2020, through June 30, 2023 P245L200182, June 2, 2020, through June 30, 2023 Federal Agency U.S. Department of Education Compliance Requirement Reporting Questioned costs Not applicable Contact Julie Dall?Aglio, Director for Grant Services Anticipated completion date June 30, 2023 1.The district will follow existing grant services procedures specifically for completing agency federal reporting,so it is accurate and on time. The district will also include a public disclosure notice regarding the timing ofpublic posting and note that the financial reporting is subject to change depending on when the financialbooks close each quarter. 2.To verify the accuracy of the information reported, the following will be performed: ?there will be a cross check using an independent financial analyst from grant services who willprepare the financial information for each grant. ?The grant services director will review the information and enter it into the quarterly reporting forthe 84.25F Institutional and 84.25L MSI reporting. ?The Financial Aid and Scholarships Department will verify 84.425 HEERF Student Aid information thatis compiled by Strategy, Analytics, and Research Department (STAR) and enter it into the samequarterly reporting document. ?The Financial Aid & Scholarships Department will submit the reporting back to Grant Services, andGrant Services will verify the financial information one more time to confirm it is accurate with thegeneral ledger.? The reporting will then be cleared for public posting and submitted through the Financial Aid and Scholarships Department who will contact Web Services for public posting. 3. This reporting process will be coordinated by the grant services director so the reporting can be completed within ten days after each quarter to meet the federal reporting requirements for these three grants. ? Any quarterly reporting will be updated as soon as it is identified there should be corrections. ? All information will be collected in an excel workbook with references to the source of information. ? This will serve as backup for the audit.

Corrective action plan: In December 2021, HHSC implemented the Texas Medicaid & Healthcare Partnership (TMHP) Provider Enrollment Management System (PEMS), an automated system that is the single tool for provider enrollment, re-enrollment, revalidation, and maintenance requests (maintaining and updating provider enrollment record information). HHSC is confident that as the LTC providers are enrolled and re-validated through PEMS, the errors for documentation will be corrected. The LTC process will mirror the sampled acute care providers which were found to be 100 percent compliant during this review, further supporting that the process is working. Implementation date(s): December 2021 Responsible persons: Deputy Associate Commissioner, Operations Management

FINDING 2022-005 Finding: Internal controls were not in place/effective in relation to the Title I Annual Expenditure Reports filed during the audit period. Subsequently, the 20-21 Title I Annual Expenditure Report did not agree with School Corporation?s ledgers. $578,452 of expenditures were reported the Annual Expenditure Report and $677,514 from Fund 4121 on the ledgers. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: When required annual federal grant reports are completed for submission, they will be reviewed by the treasurer for accuracy. Both the treasurer and the grants coordinator will sign off on the reports. In order to address the issue related to earmarking and set-asides within Title I not be completed, Concord Community Schools created a Grants and Assessment Coordinator position in May 2022. A person was hired to fill this position starting on July 1, 2022. One of the essential functions of this position is maintaining current and accurate records related to federal and state grants. Starting in January 2023, in addition to the Grants and Assessment Coordinator, a member of the business department will be a second reviewer and sign the semi-annual certifications. Anticipated Completion Date: December 31, 2023

We will comply with the Auditor's recommendation,

United States Department of Health and Human Services Infinity Health respectfully submits the following corrective action plan for the year ended November 30, 2022. Audit period: December 1, 2021 ? November 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT None FINDINGS?FEDERAL AWARD PROGRAMS AUDITS United States Department of Health and Human Services 2022-001 Reporting ? Assistance Listing No. 93.224/93.527 Recommendation: We recommend that multiple members of management be involved in the preparation and review process of the UDS report, and that supporting documentation, which agrees to the amounts in the report, be saved in a manner which allows for easy access and recovery if needed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We believe the inability to provide sufficient supporting documentation for the 2021 UDS report to be an anomaly due to the extenuating circumstance of a flood that closed Infinity Health?s main administrative building during the preparation of the 2021 UDS report. The preparation of the 2022 UDS report was completed by the CEO, CFO, COO and Director of Quality and Efficiency. All supporting documentation has been reviewed and saved on a network drive that allows for easy access, recovery and back up retrieval if necessary. Name(s) of the contact person(s) responsible for corrective action: Samantha Cannon, CEO, and Michelle Leonard, CFO. Planned completion date for corrective action plan: 4/26/2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: George ann Ewald, Director of Finance & HR Contact Phone Number: (574) 277-4452 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Finance & HR will expand Fund 8700 to include adding line items for all allowable reimbursement costs associated with each firefighter position covered by the 2019 Staffing for Adequate Fire and Emergency Response (SAFER) federal grant. The Director of Finance & HR will ensure that all funds used to compensate each covered firefighter position will be paid entirely out of Fund 8700, only. This action will result in a negative value for Fund 8700 until which time the fund is reimbursed the allowable costs under the provisions of the federal grant. The Director of Finance & HR will generate a report for each reimbursement request, which will be limited to include only the payroll dates of the period for which the request is being submitted. The Fire Chief will review and confirm that all associated costs have been withdrawn from Fund 8700. The Fire Chief will then direct the Assistant Fire Chief to complete the reimbursement request via the FEMA GO website. Once the reimbursement request has been submitted, the Assistant Fire Chief will print the completed reimbursement request documents and obtain signatures from each of the following individuals: 1. Prepared By: (NAME), Director of Finance & HR 2. Reviewed & Approved By: (NAME), Fire Chief 3. Submitted By: (NAME), Assistant Fire Chief Anticipated Completion Date: ? Implementation: June 2023

FINDING 2022-004 Contact Person Responsible for Corrective Action Plan: Alva Sibbitt, Jr., Superintendent, Melissa Embry, Corporation Treasurer, Brehan Leinenbach, Grant Writer Contact Phone Number: 812-547-2637 Views of the Responsible Official: We concur with the findings. Description of the Corrective Action Plan: All reports will be done by the Corporation Treasurer and/or Grant Writer and checked over by the Superintendent. Anticipated Completion Date: February 2023

FINDING 2022-011 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure proper calculation and supporting documentation of equitable services as it relates to the GEER I application for participation of private school children. Documentation will be retained by the Federal Programs Administrator and reviewed by the Chief Financial Officer for accuracy and completeness. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE

FINDING 2022-009 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: Internal controls will be in place for ESSER funds so that Treasurer and Superintendent or Title I specialist will sign off on annual reports to ensure accuracy of ESSER dollars spent. Anticipated Completion Date: March 2023

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.

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.