Findings Citing § 200.303

2023-002 SPECIAL TEST – ENROLLMENT REPORTING Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work-Study Program 84.063 – Federal Pell Grant 84.268 – Federal Direct Loans Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matter Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS) (OMB No.1845-0035). Institutions are required to design and implement internal control structures to ensure compliance with requirements of assistance programs (2 CFR 200.303). Condition: During our testing, we on instance noted that the effective date of enrollment and enrollment status did not match between NSLDS and the Institutions records. Questioned costs: None Context: A statistically valid sample of 40 students was selected for testing of the institutional enrollment records for comparison to NSLDS records, as required by the Department of Education. One of the students selected for testing had an enrollment status change date improperly reported to NSLDS. Cause: The District inadvertently entered the improper data in the internal record keeping systems and transmitted this date to NSLDS. Effect: The improper documentation over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of student records to determine they are appropriately reflecting the proper status. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 SPECIAL TEST – ENROLLMENT REPORTING Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster ALN Numbers: 84.007 – Federal Supplemental Education Opportunity Grants 84.033 – Federal Work-Study Program 84.063 – Federal Pell Grant 84.268 – Federal Direct Loans Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matter Criteria or specific requirement: Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the National Student Loan Data System (NSLDS) (OMB No.1845-0035). Institutions are required to design and implement internal control structures to ensure compliance with requirements of assistance programs (2 CFR 200.303). Condition: During our testing, we on instance noted that the effective date of enrollment and enrollment status did not match between NSLDS and the Institutions records. Questioned costs: None Context: A statistically valid sample of 40 students was selected for testing of the institutional enrollment records for comparison to NSLDS records, as required by the Department of Education. One of the students selected for testing had an enrollment status change date improperly reported to NSLDS. Cause: The District inadvertently entered the improper data in the internal record keeping systems and transmitted this date to NSLDS. Effect: The improper documentation over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is not a repeat finding. Recommendation: We recommend the District design controls to ensure an adequate documentation of control and review of student records to determine they are appropriately reflecting the proper status. Views of responsible officials: There is no disagreement with the audit finding.

2023-001: Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Name: Student Finacial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number: P007A221715, P033A221715, Po63P221544, P268K231544 Award Period: July 1, 2022 - June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must address in its written information security program are at 16 CFR 314.4. Condition: Certain elements of the College’s information security program were not maintained in written form. Questioned costs: None Context: The College’s written information security program did not cover the following requirements as of the required deadline in June 2023: Conduct a periodic inventory of data, noting where it's collected, stored or transmitted. Encrypt customer information on the institution's system and when it's in transit; Implement multi-factor authentication for anyone accessing customer information on the institution's system; Maintain a log of authorized users' activity and keep an eye out for unauthorized access; and, Provides for the institution to regularly test or otherwise monitor effectiveness of the safeguards it has implemented (16 CFR 314.4(d)) Cause: The College engaged an external consultant to aid in the development of comprehensive written information security program, but the resulting written policies and procedures were not complete as of the June 2023 deadline. However the College had implemented the required actions under the requirements, and was actively managing information security within the intent of the requirements. The program was later written to codify College process. Effect: Information security management may not be optimized and responses delayed without the written plan. Repeat Finding: No Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Views of responsible officials: Management acknowledges that the policy components were not in a written comprehensive format, however the College was and continues to conduct those actions required in a written plan, and subsequent to the deadline has created the written documents to satisfy the requirements without compromise to any student information

2023-001: Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Name: Student Finacial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number: P007A221715, P033A221715, Po63P221544, P268K231544 Award Period: July 1, 2022 - June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must address in its written information security program are at 16 CFR 314.4. Condition: Certain elements of the College’s information security program were not maintained in written form. Questioned costs: None Context: The College’s written information security program did not cover the following requirements as of the required deadline in June 2023: Conduct a periodic inventory of data, noting where it's collected, stored or transmitted. Encrypt customer information on the institution's system and when it's in transit; Implement multi-factor authentication for anyone accessing customer information on the institution's system; Maintain a log of authorized users' activity and keep an eye out for unauthorized access; and, Provides for the institution to regularly test or otherwise monitor effectiveness of the safeguards it has implemented (16 CFR 314.4(d)) Cause: The College engaged an external consultant to aid in the development of comprehensive written information security program, but the resulting written policies and procedures were not complete as of the June 2023 deadline. However the College had implemented the required actions under the requirements, and was actively managing information security within the intent of the requirements. The program was later written to codify College process. Effect: Information security management may not be optimized and responses delayed without the written plan. Repeat Finding: No Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Views of responsible officials: Management acknowledges that the policy components were not in a written comprehensive format, however the College was and continues to conduct those actions required in a written plan, and subsequent to the deadline has created the written documents to satisfy the requirements without compromise to any student information

2023-001: Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Name: Student Finacial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number: P007A221715, P033A221715, Po63P221544, P268K231544 Award Period: July 1, 2022 - June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must address in its written information security program are at 16 CFR 314.4. Condition: Certain elements of the College’s information security program were not maintained in written form. Questioned costs: None Context: The College’s written information security program did not cover the following requirements as of the required deadline in June 2023: Conduct a periodic inventory of data, noting where it's collected, stored or transmitted. Encrypt customer information on the institution's system and when it's in transit; Implement multi-factor authentication for anyone accessing customer information on the institution's system; Maintain a log of authorized users' activity and keep an eye out for unauthorized access; and, Provides for the institution to regularly test or otherwise monitor effectiveness of the safeguards it has implemented (16 CFR 314.4(d)) Cause: The College engaged an external consultant to aid in the development of comprehensive written information security program, but the resulting written policies and procedures were not complete as of the June 2023 deadline. However the College had implemented the required actions under the requirements, and was actively managing information security within the intent of the requirements. The program was later written to codify College process. Effect: Information security management may not be optimized and responses delayed without the written plan. Repeat Finding: No Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Views of responsible officials: Management acknowledges that the policy components were not in a written comprehensive format, however the College was and continues to conduct those actions required in a written plan, and subsequent to the deadline has created the written documents to satisfy the requirements without compromise to any student information

2023-001: Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Name: Student Finacial Aid Cluster Assistance Listing Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number: P007A221715, P033A221715, Po63P221544, P268K231544 Award Period: July 1, 2022 - June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must address in its written information security program are at 16 CFR 314.4. Condition: Certain elements of the College’s information security program were not maintained in written form. Questioned costs: None Context: The College’s written information security program did not cover the following requirements as of the required deadline in June 2023: Conduct a periodic inventory of data, noting where it's collected, stored or transmitted. Encrypt customer information on the institution's system and when it's in transit; Implement multi-factor authentication for anyone accessing customer information on the institution's system; Maintain a log of authorized users' activity and keep an eye out for unauthorized access; and, Provides for the institution to regularly test or otherwise monitor effectiveness of the safeguards it has implemented (16 CFR 314.4(d)) Cause: The College engaged an external consultant to aid in the development of comprehensive written information security program, but the resulting written policies and procedures were not complete as of the June 2023 deadline. However the College had implemented the required actions under the requirements, and was actively managing information security within the intent of the requirements. The program was later written to codify College process. Effect: Information security management may not be optimized and responses delayed without the written plan. Repeat Finding: No Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Views of responsible officials: Management acknowledges that the policy components were not in a written comprehensive format, however the College was and continues to conduct those actions required in a written plan, and subsequent to the deadline has created the written documents to satisfy the requirements without compromise to any student information

2023-002: Special Tests and Provisions - NSLDS Program - Level Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P221544, P268K231544 Award Period: July 1, 2022 - June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per the NSLDS Enrollment Reporting Guide, Published Program Length should be reported to NSLDS based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows: If the school has published, in it's catalog, on it's website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school published. If the school has not published a program length and the program is an associate or bachelor's degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. For all other programs for which the school has not published a program length, the program length is based on the school's determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Questioned costs: None Context: The condition occurred for 38 out of the 40 students tested Cause: The program length reported to NSLDS for associate degree programs is maintained in the College ERP system based on program length in months and was not converted to years as recommended in the NSLDS enrollment reporting guide. Effect: The NSLDS system calculated the program length at 2.678 years. Repeat Finding: No Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Views of responsible officials: There is no disagreement with the audit finding.

2023-002: Special Tests and Provisions - NSLDS Program - Level Reporting Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P221544, P268K231544 Award Period: July 1, 2022 - June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per the NSLDS Enrollment Reporting Guide, Published Program Length should be reported to NSLDS based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows: If the school has published, in it's catalog, on it's website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school published. If the school has not published a program length and the program is an associate or bachelor's degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. For all other programs for which the school has not published a program length, the program length is based on the school's determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Questioned costs: None Context: The condition occurred for 38 out of the 40 students tested Cause: The program length reported to NSLDS for associate degree programs is maintained in the College ERP system based on program length in months and was not converted to years as recommended in the NSLDS enrollment reporting guide. Effect: The NSLDS system calculated the program length at 2.678 years. Repeat Finding: No Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P222871, P268K23871 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance: 1. The Code of Federal Regulations, 34 CFR 685.309(b), states that:  Colleges must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The college is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that college must report accurately the enrollment status of all students regardless if they receive aid from the institution or not.  Colleges must have some arrangement to report student program enrollment effective date and status to NSLDS. 2. Per Section 4.4.8 of the NSLDS Enrollment Reporting Guide, the Program Begin Date is the date the student fist began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program. 3. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition: Incorrect enrollment status, effective date, and program begin date were reported to NSLDS. It was also noted that the change in status was not reported timely. Questioned costs: None Context: This condition occurred in our statistically valid sample as follows: 1. The Enrollment Status was incorrectly reported for 24 out of 40 students. 2. The Effective Date was incorrectly reported for 9 out of 40 students. 3. The begin date was incorrectly reported for 26 out of 40 students. 4. The status was not reported timely for 9 out of 40 students. Cause: 1. Montgomery College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely, however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses. No review was completed to ensure the upload was completed in NSLDS. 2. Inaccurate Student withdrawal effective dates were not identified timely due to delays in the review of student withdrawal status. 3. Inaccurate Student program begin dates were due to a programming issue with the file transmission software. Program start date was updating each semester to the latest semester start date. There was insufficient review to identify the problem and recommend a solution to resolve. Effect: Student enrollment status, effective date, and program begin date was not reported accurately to NSLDS. Repeat finding: No Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Education Federal Program Name: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P222871, P268K23871 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance: 1. The Code of Federal Regulations, 34 CFR 685.309(b), states that:  Colleges must have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. The college is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Also, the Code of Federal Regulations, 34 CFR 682.610, states that college must report accurately the enrollment status of all students regardless if they receive aid from the institution or not.  Colleges must have some arrangement to report student program enrollment effective date and status to NSLDS. 2. Per Section 4.4.8 of the NSLDS Enrollment Reporting Guide, the Program Begin Date is the date the student fist began attending the program being reported. Typically, this would be the first day of the term in which the student began enrollment in the program. 3. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition: Incorrect enrollment status, effective date, and program begin date were reported to NSLDS. It was also noted that the change in status was not reported timely. Questioned costs: None Context: This condition occurred in our statistically valid sample as follows: 1. The Enrollment Status was incorrectly reported for 24 out of 40 students. 2. The Effective Date was incorrectly reported for 9 out of 40 students. 3. The begin date was incorrectly reported for 26 out of 40 students. 4. The status was not reported timely for 9 out of 40 students. Cause: 1. Montgomery College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely, however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses. No review was completed to ensure the upload was completed in NSLDS. 2. Inaccurate Student withdrawal effective dates were not identified timely due to delays in the review of student withdrawal status. 3. Inaccurate Student program begin dates were due to a programming issue with the file transmission software. Program start date was updating each semester to the latest semester start date. There was insufficient review to identify the problem and recommend a solution to resolve. Effect: Student enrollment status, effective date, and program begin date was not reported accurately to NSLDS. Repeat finding: No Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Views of responsible officials: There is no disagreement with the audit finding.

Funding Years(s): 7/1/2022 – 6/31/2023 Financial Assistance Listing Number: Coronavirus State and Local Fiscal Recovery Funds (CFDA 21.027) Contract Number: 21-417039 Pass-Through Agency: The State of Illinois, Department of Human Services Federal Agency: U.S. Department of the Treasury Type of Finding: Internal Control (Material Weakness) Repeat Finding: No Criteria: In accordance with Part 6 of the 2023 Compliance Supplement and as stipulated by the 2 CFR Section 200.303, recipients of Federal Awards are required to establish and maintain an internal control environment that complies with either the guidance in “Standards for Internal Control in the Federal Government” (the “Green Book”) issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” (revised in 2013), issued by the Committee of Sponsoring Organization of the Treadway Commission (“COSO”) for the federal funding streams it administers. Condition: We selected a non-statistical sample of nineteen (19) employee payroll expenses to test compliance for Activities Allowed and Unallowed and Allowable Costs for the grant and found that for the passthrough award received for Job Training & Economic Development (JTED), the Lighthouse did not maintain sufficient and timely documentation regarding the review and approval of time spent by personnel working on the program that was charged to the grant. Cause: Lighthouse has a process in place to review and ensure expenditures charged to the grant do not exceed budget. We were not able to obtain evidence that these payroll expenditures were reviewed by someone knowledgeable about the grant and its compliance requirements, such as the Assistant Director for Grants and Contracts. Effect: The lack of timely application of the review of the data on the hours worked used in the determination of payroll expense charged to the grant could result to the entity charging cost to the grant that have not yet been incurred. Questions Costs: None Recommendation: We recommend that management establish a control to timely review the actual time worked by each personnel assigned to the program prior to charges being submitted to the grantor for reimbursement. Views of Responsible Official: Management notes the details of this finding and will implement procedures to mitigate the outlined issues as described in our Corrective Action Plan.

Department of Education 2023-002 Pass-through Kentucky Department of Education; COVID-19 Education Stabilization Fund - Assistance Listing No. 84.425; Grant period - Year ended June 30, 2023 Criteria and Condition: 2 CFR 200.303 requires the non-federal entity to establish and maintain effective internal controls over compliance with Federal statues, regulations, and the terms and conditions of the Federal awarrd including proper tracking of grant expenditures or compliance. COVID-19 Education Stabilization Funds require disbursements to contain doucmentation of approval by the Program Director Cause: Disbursements using COVID-19 Education Stabilization Funds were not documented as approved by the Program Director Effect: Disbursements could be made using COVID-19 Stabilization Funds that are not in compliance with grant requirements. Questioned Costs: No questioned costs were incurred from this finding Context: A sample of 17 disbursements from a population of 124 disbursements was selected for audit procedures. On the 13th disbursement tested from the sample, we noted it lacked documenation of approval by the Program Director. The sample was not a statistically valid sample. Recommendation: The COVID-19 Education Stabilization Fund Program Director should document approval of all disbursements Views of Responsible Officials and Planned Corrective Actions: The District concurs with the finding, see corrective action plan

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -003 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View of Responsible Officials and Timing: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -004 Approval Of Expense Transactions – Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 – Child Nutrition Cluster And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View of Responsible officials and Timing: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.

2023 -004 Approval Of Expense Transactions – Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 – Child Nutrition Cluster And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View of Responsible officials and Timing: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.

2023 -004 Approval Of Expense Transactions – Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 – Child Nutrition Cluster And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View of Responsible officials and Timing: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.

2023 -004 Approval Of Expense Transactions – Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 – Child Nutrition Cluster And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View of Responsible officials and Timing: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.

2023 -004 Approval Of Expense Transactions – Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 – Child Nutrition Cluster And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View of Responsible officials and Timing: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.

2023 -004 Approval Of Expense Transactions – Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 – Child Nutrition Cluster And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View of Responsible officials and Timing: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.

2023 -004 Approval Of Expense Transactions – Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 – Child Nutrition Cluster And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View of Responsible officials and Timing: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.

2023 -004 Approval Of Expense Transactions – Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 – Child Nutrition Cluster And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View of Responsible officials and Timing: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.

2023 -004 Approval Of Expense Transactions – Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 – Child Nutrition Cluster And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View of Responsible officials and Timing: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.

2023 -004 Approval Of Expense Transactions – Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 10.555/10.553 – Child Nutrition Cluster And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all payroll transactions. View of Responsible officials and Timing: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.

2023 -005 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View Of Responsible Officials: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -005 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View Of Responsible Officials: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -005 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View Of Responsible Officials: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -005 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View Of Responsible Officials: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -005 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View Of Responsible Officials: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.

2023 -005 Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) – Significant Deficiency Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a written process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, the engagement team noted a review process of the SEFA had been implemented during 2023. However, there was no formal written review process. Cause: The entity does not have a written process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a written consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner. View Of Responsible Officials: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date.