Corrective Action Plans

Finding 1181680 (2025-002)

Material Weakness 2025

WI

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Finding: #2025-002- Time and Effort Reporting Assistance Listing/Program Title: #84.027 A/IDEA Flow Through and #84.173A/Preschool Entitlement (Special Education Cluster) Federal Agency/Pass-Through Entity: U.S Department of Education/Wisconsin Department of lnstruction Award Numbers/Year: 2025-1333...

Finding: #2025-002- Time and Effort Reporting Assistance Listing/Program Title: #84.027 A/IDEA Flow Through and #84.173A/Preschool Entitlement (Special Education Cluster) Federal Agency/Pass-Through Entity: U.S Department of Education/Wisconsin Department of lnstruction Award Numbers/Year: 2025-133332-DPI-FLOW-341 and 2025-133332-DPI-PRESCH-347/2024-2025 Criteria: In accordance with the federal Uniform Guidance, charges to federal awards for salaries and benefits must be based on records that accurately reflect the work performed. Such records must be supported by time and effort documentation. Condition: During the auditors' testing of payroll charges, it was noted that the District did not maintain adequate time and effmi documentation to support the allocation of salaries and benefits to the Special Education Cluster. Specifically, one employee's time was coded to the Special Education Cluster at a fixed 10% allocation. Cause: The District did not have adequate internal controls to ensure required time and effort documentation was consistently obtained and maintained for all employees whose salaries and benefits were charged to the Special Education Cluster. Staff turnover and lack of training contributed to inconsistent application of federal requirements. Effect: Because required time and effort documentation was not properly maintained, salaries and benefits charged to the Special Education Cluster may not accurately reflect actual time spent working on the program. As a result, these costs are unallowable under the Uniform Guidance. Questioned Costs: The absence of proper documentation results in questioned costs of $7,037, representing the salary and benefit amounts charged to the program for the one employee without adequate support. Recommendation: The auditor recommends that the District strengthen internal controls over time and effort reporting to ensure all employees funded in whole or in part by federal programs complete required documentation in accordance with Uniform Guidance. Additionally, a monitoring process should be implemented to ensure time distribution report is are completed accurately and retained in accordance with record-keeping requirements. Response: Management concurs with the finding and will implement internal control improvements to ensure full compliance with federal time and effort documentation requirements.

View Audit 392933

Finding 1181652 (2025-001)

Material Weakness 2025

The Johns Hopkins University

MD

Allowable Costs / Cost Principles § 200.303 § 200.309 § 200.403

Corrective Action Plan: The University accepts this finding and has removed the questioned costs from the award. Management will reinforce and reiterate the internal controls process to the staff responsible for the review of the grant expenditures during the financial reporting process. Management ...

Corrective Action Plan: The University accepts this finding and has removed the questioned costs from the award. Management will reinforce and reiterate the internal controls process to the staff responsible for the review of the grant expenditures during the financial reporting process. Management will also communicate via our Financial Administrative Bulletin to the grants administration community our internal controls around 2 CFR 200. Management will conduct 2 CFR 200 training with the impacted departmental grant administration by March 5, 2026 Completion Date: March 31, 2026 Contact Person: Paul Gasior 443-997-8141

View Audit 392931

Finding 1181630 (2025-001)

Material Weakness 2025

Spero Family Services

IL

Allowable Costs / Cost Principles Reporting

Management will prepare the schedule of expenditures of federal awards as part of the year end closing process to determine our audit requirements under the Uniform Guidance and provide the schedule to the audit firm during the financial audit process.

View Audit 392910

Finding 1181434 (2025-003)

Material Weakness 2025

North Adams Community Schools

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Beth Quinn Contact Phone Number and Email Address: 260-728-3306 quinnb@nadams.k12.in.us Contact Person Responsible for Corrective Action: Abi West, Director of Special Ed...

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Beth Quinn Contact Phone Number and Email Address: 260-728-3306 quinnb@nadams.k12.in.us Contact Person Responsible for Corrective Action: Abi West, Director of Special Education Contact Phone Number and Email Address: 260-824-5880 awest@awssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Cooperative maintains a tracking spreadsheet to monitor hours worked by staff providing services to non-public students. Staff member will record K-12 and preschool hours separately on their Time and Effort Log. The Cooperative will then document these hours, distinguishing between Part B funds and Preschool funds. For kindergarten-aged students, the Speech-Language Pathologist will collaborate with the Student Record Administrative Assistant to identify students eligible under Section 5a (619 funding). Specifically, these are kindergarten students who are not yet six years old as of December 1. Such students are funded through both the 611 and 619 grants. Time and effort for preschool students, including 5a students, will be prioritized to the 619 grant until its allocated funds are fully expended. Once the 619 funds are exhausted, effort will be shifted to the 611 grant accordingly. Proportionate share reports will be based on actual expenditures within the six-month period, as reflected in our tracking spreadsheet. This process will be corrected for FY 2023 (611 and 610) and FY 2024 (611 and 910) to ensure compliance and prevent recurrence of similar findings in the next audit cycle. Anticipated Completion Date: September 1, 2025

View Audit 392695

Finding 1181424 (2025-001)

Material Weakness 2025

Northeastern Wayne School Corporation

IN

Allowable Costs / Cost Principles School Nutrition Programs Matching / Level of Effort / Earmarking § 200.303 § 200.403

Information on the federal program : Subject: Child Nutrition Cluster (CNC) Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (Or Other Identifying Numbers): FY2...

Information on the federal program : Subject: Child Nutrition Cluster (CNC) Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (Or Other Identifying Numbers): FY23-FY24, FY24-FY25 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed and Unallowed, Allowable Costs Audit Findings: Material Weakness, Other Matters Condition : The School Corporation did not have adequate internal controls in place to ensure that the School Corporation complied with the allowable cost requirements. Context : During our testing of the School Corporation’s compliance with the allowable cost requirements for the Child Nutrition Cluster (CNC), we tested 40 vendor disbursement transactions and 40 payroll disbursement transactions and identified the following exceptions: 1. For one vendor disbursement, the School Corporation incorrectly recorded the disbursement for $820 to Fund 800 (School Lunch Fund) that should have been recorded to Fund 300 (Operations Fund), resulting in an unallowable cost being charged to the food service fund. 2. For one payroll disbursement, the School Corporation inaccurately entered the number of hours worked by a cafeteria employee for one pay period, resulting in an overpayment to the employee by $5,568. The employee notified the School Corporation of the overpayment and remitted the overpayment back to the School Corporation. These errors were attributable to deficiencies in the internal controls over the review and approval of vendor and payroll expenditures. Views of Responsible Official : We concur with the finding. Description of Corrective Action Plan : Management will enhance controls and review processes surrounding vendor and payroll expenditures charged to the Child Nutrition. The Food Service Director will be receiving periodic reports to review expenditures charged to the CNC to monitor charged costs. The payroll exceptions report is now checked by the Executive Assistant and Payroll. Responsible Party and Timeline for Completion : Immediately corrected

View Audit 392694

Finding 1181417 (2025-003)

Material Weakness 2025

Southwest School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Information on the federal program: Subject: COVID-19 - Education Stabilization Fund, Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Elementary and Secondary School Emergency Relief Fund (ESSER III) Assistance Listings Nu...

Information on the federal program: Subject: COVID-19 - Education Stabilization Fund, Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Elementary and Secondary School Emergency Relief Fund (ESSER III) Assistance Listings Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Audit Finding: Material Weakness, Internal Control Condition: The School Corporation did not have internal controls in place to ensure compliance with the activities allowed or unallowed and allowable cost/cost principles requirements. The School Corporation had not designed or implemented adequate policies or procedures to ensure that stipend and wage rates were properly reviewed and approved. Context: For the testing of activities allowed and unallowed costs-cost principles, 12 vendor disbursements and 40 payroll disbursements were selected for testing. The following deficiencies were noted related to controls over pay rate approvals: • For 10 of 10 stipends sampled, the School Corporation could not provide proper approval of the stipend amount. The total of amount of stipends sampled was $5,056. The total amount of stipends charged to the grant for the audit period was $57,558. • One employee was underpaid by $9, and the error was not caught during the review process. • For two of seven hourly employees sampled, the School Corporation provided a pay chart. However, approval of the rates was not available. • One teacher received twice their regular paycheck amount due to a contract pay off. The School Corporation could not provide approval or additional support related to the contract payoff amount of $1,528. Views of Responsible Officials: Management agrees with the finding and has prepared a corrective action plan. Description of Corrective Action Plan: Management will retain documentation and approval for stipend and hourly pay rates. Management will review all pay runs and ensure the accurate amount of pay is disbursed and retain documentation for any changes in pay amounts. Responsible Party and Timeline for Completion: The Treasurer will be responsible for implementing the corrective action plan, which will go into effect immediately.

View Audit 392681

Finding 1181394 (2025-001)

Material Weakness 2025

Portage Township Schools

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hour...

Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request.

View Audit 392640

Finding 1181376 (2025-001)

Material Weakness 2025

Mohave Valley Elementary School District No.16

AZ

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility

2025-001 Eligibility Over Title I Program: Title I - Grants to Local Educational Agencies Federal Assistance Listing Number: 84.010 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 25FT1TTI-511375-01A Questioned Costs: $-0- Type of Fin...

2025-001 Eligibility Over Title I Program: Title I - Grants to Local Educational Agencies Federal Assistance Listing Number: 84.010 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 25FT1TTI-511375-01A Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: E. Eligibility Condition/Context: During our testing of school eligibility and funding, we discovered the District did not maintain records that agreed to the low-income student counts as reported to the Arizona Department of Education to properly allocate Title I funding by poverty level. Corrective Action: The District will ensure in future periods that records are maintained to support lowincome students and the allocation of Title I funding as reported to the Arizona Department of Education. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Jenette King, Business Manager

View Audit 392621

Finding 1181371 (2025-001)

Material Weakness 2025

Recovery Services of Northwest Ohio

OH

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

Recovery Services of Northwest Ohio, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024-June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently w...

Recovery Services of Northwest Ohio, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 1, 2024-June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. 2025-001 Type of Finding: Significant deficiency identified: The organization is charging payroll costs to grants based on budgeted amounts rather than costs supported by time and effort documentation. Recommendation: Implementation of either a timekeeping system where timecards include documentation of time allocated to each grant or the implementation of a time study process with the lookback procedures to meet the time and effort documentation requirements in accordance with the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The organization will implement time and effort documentation/time study for federal awards and charge grant staff costs based on such documentation. Name(s) of the contact person(s) responsible for corrective action: Jean Groves, CFO, Recovery Services of Northwest Ohio, Inc. 419-782-9920. Planned completion date for corrective action plan: March 15, 2026.

View Audit 392613

Finding 1181354 (2025-001)

Material Weakness 2025

Cleveland County School District

AR

Allowable Costs / Cost Principles

The District, under new office management will review contracts against the board approved salary schedules before the employees are paid. Also, when an employ-ee separates from the District, earned pay will be recalculated and reviewed to deter-mine if there is a difference in pay.

View Audit 392585

Finding 1181342 (2025-001)

Material Weakness 2025

Women for a Healthy Environment

PA

Allowable Costs / Cost Principles Cash Management

CORRECTIVE ACTION PLAN June 30, 2025 Women for a Healthy Environment submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Herbein + Company, Foster Plaza 10, 680 Andersen Drive, Suite 205, Pittsburgh, PA 15220 Audit pe...

CORRECTIVE ACTION PLAN June 30, 2025 Women for a Healthy Environment submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Herbein + Company, Foster Plaza 10, 680 Andersen Drive, Suite 205, Pittsburgh, PA 15220 Audit period: Year ended June 30, 2025 Contact: Michelle Naccarati-Chapkis, Executive Director The finding from the June 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Section III - Federal Award Findings and Questioned Costs 2025-001 ALLOWABLE COSTS, CASH MANAGEMENT, AND REPORTING – SIGNIFICANT DEFICIENCY Federal Program U.S. Department of Housing and Urban Development - Healthy Homes Production Program - ALN 14.913 Criteria Under OMB guidance, Public Law (Pub. L) No. 116-117, Payments Integrity Information Act of 2019, and Executive Order 13520 on reducing improper payments, federal agencies are required to take actions to prevent improper payments, review federal awards for such payments, and as applicable, recover improper payments, including any duplicate payment. Condition While working to provide a population of invoices for audit testing, management identified five invoices that were submitted for reimbursement twice, resulting in an overdraw of federal money. Additionally, while performing audit procedures over cash management and reporting, we noted that there was no review and approval of reports submitted for reimbursement. The Organization is required to submit quarterly reports for reimbursement. Neither of the two reports selected for testing contained evidence regarding review or approval prior to submission. Cause Duplicate invoices were submitted due to a temporary process change at the Organization when there were federal governmental department changes occurring related to federal programs. The Organization’s process change resulted in multiple people submitting reimbursement for the same expenses. We also noted that the reports were prepared based on information provided by separate personnel, but there was no review or approval in place over reports once they are combined to check for accuracy prior to submission. Effect The Organization overdrew federal program money during the year due to duplicate invoice submission, resulting in unallowable costs being charged to the program and inaccurate financial reporting. Questioned Costs $16,303 Context With changes in the processes for grant funding, the Organization prioritized submission of invoices for reimbursement. During this prioritization, the Organization implemented a temporary process change, resulting in the duplication submission errors of five invoices and the overdraw of federal funds. The lack of appropriate review and approval allowed the duplicate submission to occur. Repeat Finding No Recommendation We recommend that Women for a Healthy Environment establish and follow a system of internal control related to the costs charged to Federal programs. The process should establish procedures and responsibilities for the documentation and review of costs incurred and charged to Federal awards. Review and approval of this documentation should be performed by a person other than the preparer prior to submission to the Federal agency. Management Response Women for a Healthy Environment has reviewed the recommendation noted above and has put additional internal controls in place related to the reimbursement drawdowns/costs charged to Federal programs. This includes ensuring that only one reimbursement is being completed each month, rather than one done at mid-month. The accounting team will continue to prepare those monthly reimbursement calculations, which will be reviewed by the Program Manager, Director of Operations, and Executive Director.

View Audit 392561

Finding 1180984 (2025-001)

Material Weakness 2025

Logan County Board of Education

WV

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

Trainings have been conducted during the current school year for principals, secretaries, and cooks at all schools on following correct meal patterns and point of service procedures. The current child nutrition director performs random audits and visits at all schools to make sure schools are follow...

Trainings have been conducted during the current school year for principals, secretaries, and cooks at all schools on following correct meal patterns and point of service procedures. The current child nutrition director performs random audits and visits at all schools to make sure schools are following these procedures consistently.

View Audit 392512

Finding 1180974 (2025-003)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Corrective action plan: The CAPPS Financials team uses Pathlock to monitor and log privileged user activities. Pathlock maintains documentation of approvals and business justifications. Documentation of recurring privileged access reviews will be maintained as appropriate across all dedicated CAPPS ...

Corrective action plan: The CAPPS Financials team uses Pathlock to monitor and log privileged user activities. Pathlock maintains documentation of approvals and business justifications. Documentation of recurring privileged access reviews will be maintained as appropriate across all dedicated CAPPS Financial modules. IAM team will establish a documented process through which it will coordinate with the CAPPS Financial team to perform quarterly reviews of accounts and audit logs to strengthen privileged access provisioning. The review process will include documented approval, business justification, and periodic revalidation for all elevated roles in CAPPS Financial. Pathlock software is being used to manage single sign-on for granting privileged access to allowed users. With this software, the IAM team can grant access to a user, who would then login as themselves and then switch to the appropriate privileged role. Once the user switches to a privileged role, the Pathlock software maintains the audit log of user activity. Implementation date: February 27, 2026 Responsible persons: Daniel Kellogg, Deputy Chier Information Officer (DCIO), Infrastructure Services Leatha Marr, DCIO & Chief Product Officer, System Applications

View Audit 392506

Finding 1180919 (2025-004)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Cash Management § 200.303

Corrective action plan: HHSC will run quarterly expenditure reports for this grant to monitor administrative earmarking thresholds. Implementation date: July 31, 2026 Responsible person: Roderick Swan, Associate Commissioner, Behavioral Health Services Operations

View Audit 392506

Finding 1180910 (2025-001)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303

Corrective action plan: ITS will: • Work with HR and Security to analyze and validate the size and scope of the late submission of access termination requests for separated employees. Communicate the analysis results and recommendations on or before May 1, 2026. • Work with the Information Security ...

Corrective action plan: ITS will: • Work with HR and Security to analyze and validate the size and scope of the late submission of access termination requests for separated employees. Communicate the analysis results and recommendations on or before May 1, 2026. • Work with the Information Security Office for continuation of periodic reconciliation of HR data and network accounts. Schedule for reconciliation to be established on or before May 1, 2026. • Work with Human Resources to establish a schedule of periodic reconciliation for HR data and case management application accounts. Schedule for reconciliation to be established on or before May 1, 2026. • Review existing business process for offboarding separated employees and provided recommendations to HR for training and communication for staff. Recommendations to be provided by May 1, 2026. • Determine what technology solution may be needed by August 31, 2026, with consideration of effectiveness of mitigation actions, as noted above. Implementation dates: See Corrective action plan Responsible person: Angie Lindemann, Deputy Chief Information Officer

View Audit 392506

Finding 1180876 (2025-002)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Corrective action plan: ITS Management will establish a formal, documented user access review program applicable to both privileged and non-privileged network users. Key actions include: 1. Policy Updates: Revise information technology access control policies and procedures to re-quire periodic (at ...

Corrective action plan: ITS Management will establish a formal, documented user access review program applicable to both privileged and non-privileged network users. Key actions include: 1. Policy Updates: Revise information technology access control policies and procedures to re-quire periodic (at least annual) reviews of all network user access. 2. Standardized Process and Documentation: Implement a consistent, documented review process and maintain records in a centralized repository to ensure accountability and auditability. 3. Monitoring and Oversight: Implement oversight procedures to track completion of access re-views and remediation of identified issues, with reporting to IT and information security leadership to support governance. Implementation dates: 1. Policy and procedure updates: Expected completion by April 30, 2026 2. Standardized process and repository implementation: Expected completion by May 31, 2026 3. First completed annual review under the revised process: Expected completion by June 30, 2026 Responsible persons: Tara Mitchell, Director of IT Operations Sean Peterson, Chief Information Officer

View Audit 392506

Finding 1180872 (2025-016)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Corrective action plan: • IT will coordinate with HR on strengthening the separation process, to include HR running separation reports quarterly and sending to IT to cross check. Will perform regular scheduled meetings to discuss the separation process/issues. • IT is testing automatic scripts that ...

Corrective action plan: • IT will coordinate with HR on strengthening the separation process, to include HR running separation reports quarterly and sending to IT to cross check. Will perform regular scheduled meetings to discuss the separation process/issues. • IT is testing automatic scripts that will aid in the process and will be implemented this year. • IT will document quarterly access reviews which are already done. • IT will work on enhancing automation and controls; Will utilize AI to assist. Implementation date: May 2026 Responsible person: Chris Bunton, CIO, Texas Department of Agriculture

View Audit 392506

Finding 1180821 (2025-002)

Material Weakness 2025

Stroudsburg Area School District

PA

Allowable Costs / Cost Principles Reporting § 200.510

Significant Deficiency 2025-002 (Internal Control Over Federal Award Reporting – ESSER III) Federal Program: Education Stabilization Fund - ARP-ESSER ALN: 84.425U Condition: Allowable ESSER III expenditures incurred during fiscal year 2023-24 were not identified or included on the Schedule of Expend...

Significant Deficiency 2025-002 (Internal Control Over Federal Award Reporting – ESSER III) Federal Program: Education Stabilization Fund - ARP-ESSER ALN: 84.425U Condition: Allowable ESSER III expenditures incurred during fiscal year 2023-24 were not identified or included on the Schedule of Expenditures of Federal Awards (SEFA) for that year. In addition, expenditures related to Federal Set-Aside awards were mistakenly included in the Final Expenditure Report for ESSER III, resulting from a misunderstanding of the structure of the federal awards. Recommendation: Strengthen internal controls Corrective Action: The District will provide targeted training to staff responsible for federal grant accounting to ensure a clear understanding of federal grant award structures, including the distinction between ESSER III and related Federal Set-Aside awards. This training will cover grant setup, expenditure coding, and reporting requirements. Person Responsible: Brenda VanBuskirk, Business Manager Proposed Completion Date: December 31, 2025

View Audit 392478

Finding 1180811 (2025-004)

Material Weakness 2025

Benton Community School Corporation

IN

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.309 § 200.461

Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal ...

Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Period of Performance compliance requirements. Context: During fiscal year 2023-24, the School Corporation was a member of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01 and 22619-047-ARP grant awards, two exceptions were identified in the sample of five transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the two identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. This issue was isolated to fiscal year 2024. No costs incurred outside of the period of performance were identified in fiscal year 2025. Views of Responsible Officials and Corrective Action Plan: Management disagrees with part of the finding. The term “obligate” can be interpreted in various ways within our context. While we have a purchase order that was completed by September 30, we do agree that we changed vendors after September 30 and paid the non-public school directly. We agree with the finding that direct payment to a non-public school is not allowable. The purchase order is an internal written commitment to acquire the items/supplies, but it is not a binding written agreement to acquire “property” when we are purchasing supplies until it is provided to the vendor. The purchase order is authorization and approval to purchase the items/supplies. Once the purchase order is provided to the vendor, it is committed and is the binding written agreement. The invoice is an order to pay the obligation. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Sarah Claton, Cooperative School Services director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the cooperative on an ongoing basis.

View Audit 392466

Finding 1180807 (2025-003)

Material Weakness 2025

Benton Community School Corporation

IN

Allowable Costs / Cost Principles § 200.303 § 200.403

Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers...

Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-ARP, 24611-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Activities Allowed or Unallowed and Allowable Costs compliance requirements. Context: During fiscal year 2023-2024, the School Corporation was a member of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For costs related to non-public schools, the practice of the Cooperative was to separate out the required amount for each member school from the Cooperative budget, and the member schools would work with the non-public schools to determine how to spend their proportionate share amount. Each member school would then request reimbursement from the Cooperative for non-public school expenditures incurred. This allowed both the Cooperative and member schools to maintain control of all Special Education funds, property, equipment and supplies. In the initial sample of 25 expenditures, there was no noncompliance identified. However, while performing a review of separate transactions for the Period of Performance compliance requirement, it was noted that non-public schools received direct reimbursements from the Cooperative for their proportionate share expenditures, which is not allowable under the grant award. The audit team reviewed the expenditure population in entirety and identified a total of 5 expenditures, totaling $17,857, that were made from Special Education funds directly to non-public schools by the cooperative during the audit period. The lack of controls and noncompliance was an isolated to the 22611-047-PN01, 22611-047-ARP, 22619-047-ARP and 24611-047-PN01 grant awards. This issue was isolated to fiscal year 2024. No direct payments to non-public schools were identified during fiscal year 2025. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding. During the required consultation meeting involving the Local Educational Agency (LEA), representatives from private schools, and the parents or legal guardians of nonpublic students with disabilities, the agenda will cover both allowable and un-allowed costs. The meeting agenda will clearly outline that all purchased items are the responsibility of the LEA, that gift cards are prohibited, and that all acquisitions must provide direct benefit to students with disabilities. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Sarah Claton, Cooperative School Services Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the cooperative on an ongoing basis.

View Audit 392466

Finding 1180790 (2025-002)

Material Weakness 2025

City of Croswell

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.305 § 200.318 § 200.400

The City will review the requirements for written policies and will adopt policies, as needed, or will revise its current policies as needed to comply with Uniform Guidance.

View Audit 392455

Finding 1180732 (2025-001)

Material Weakness 2025

Westminster College

MO

Allowable Costs / Cost Principles § 200.400 § 200.403 § 200.404 § 200.405 § 200.406

Westminster College Corrective Action Plan (CAP) Federal Program: Economic Adjustment Assistance Program, Assistance Listing Number 11.307 Finding 2025-001: Questioned Costs – Allowable Costs/Costs Principles (material weakness) Name of Contact Person: Gerald J. Ganz, Jr., Vice President, CFO Specif...

Westminster College Corrective Action Plan (CAP) Federal Program: Economic Adjustment Assistance Program, Assistance Listing Number 11.307 Finding 2025-001: Questioned Costs – Allowable Costs/Costs Principles (material weakness) Name of Contact Person: Gerald J. Ganz, Jr., Vice President, CFO Specific Corrective Action: To prevent recurrence, the College is implementing the following measures: 1. Enhanced Funding Source Review Procedures: The College will develop and enforce a standardized review process requiring staff to verify and document the original funding source for any expenditure prior to charging it to a federal award. This process will include mandatory cross-checking between project accounting records, bond expenditures logs, and grant reimbursement requests. 2. Strengthened Internal Controls Over Capital Project Accounting: The College will implement additional controls within the accounting system to ensure expenditures tied to capital projects are flagged and reviews for potential dual funding before being charged to any federal program. 3. Training and Guidance for Staff: All personnel involved in grant management, accounting, and capital project administration will receive updated training on Cost Principles under 2 CFR 200.400-200.406, with emphasis on allocability, reasonableness, and the proper handling of applicable credits. 4. Ongoing Monitoring and Review: Quarterly internal compliance reviews will be conducted to confirm adherence to the new procedures, and corrective measures will be taken immediately if discrepancies are identified. The College is committed to ensuring full compliance with federal regulations and strengthening internal controls to safeguard all funding sources. We appreciate the opportunity to improve our processes and will implement the recommended procedures to ensure the integrity of future federal program expenditures. Anticipated Completion Date: June 30, 2026

View Audit 392416

Finding 1180710 (2025-002)

Material Weakness 2025

National University of Natural Medicine

OR

Student Financial Aid Subrecipient Monitoring Allowable Costs / Cost Principles § 200.516

Finding 2025-002 Reporting Department’s Response: Management agrees with this finding. Corrective Action: This issue arose during the onboarding of students admitted through a teach-out arrangement with a closing institution. Because these students entered under program structures that differed from...

Finding 2025-002 Reporting Department’s Response: Management agrees with this finding. Corrective Action: This issue arose during the onboarding of students admitted through a teach-out arrangement with a closing institution. Because these students entered under program structures that differed from NUNM’s standard enrollment models, some of the information initially received did not align with NUNM’s financial aid packaging assumptions. In two cases, cost of attendance calculations reflected full-time status when the program design required three-quarter-time treatment. While the situation was limited to a small number of students within a unique population, management recognizes that our internal coordination processes did not sufficiently account for the complexity of the teach-out transition. In particular, clearer confirmation of enrollment status and program structure should have occurred before aid was packaged and originated. Management is strengthening procedures for any future teach-out, transfer, or non-standard admissions cohorts to ensure accurate and compliant packaging from the outset. Going forward, NUNM will implement the following controls: • A standardized handoff process from Admissions to Financial Aid for special populations that documents program structure, term length, and expected enrollment level prior to packaging. • A secondary review requirement for initial aid awards for new program types or cohorts before loans are originated. • Regular cross-functional checkpoints between Admissions and Financial Aid during the setup of non-standard programs. Management views this experience as an opportunity to improve coordination and compliance during periods of institutional transition and is committed to maintaining strong controls over Title IV packaging and cost of attendance calculations. Contact: Jerry Bores Anticipated Completion Date: Immediately

View Audit 392354

Finding 1180708 (2025-002)

Material Weakness 2025

Easter Seals Serving Dc/md/va

MD

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.302 § 200.405 § 200.430

We have a multi-pronged action plan. We will clarify and review our accounting policies and procedures regarding payroll allocations with staff; We will create a more thorough documentation process of the basis for each allocation; We will review the assumptions used for allocations during the year ...

We have a multi-pronged action plan. We will clarify and review our accounting policies and procedures regarding payroll allocations with staff; We will create a more thorough documentation process of the basis for each allocation; We will review the assumptions used for allocations during the year and update them (as needed); We will include regular monitoring and review of payroll allocations.

View Audit 392353

Finding 1180704 (2025-002)

Material Weakness 2025

Wauseon Exempted Village School District

OH

Allowable Costs / Cost Principles Cash Management Matching / Level of Effort / Earmarking § 200.303

Management is aware and understands the importance of compliance with the federal requirements and will ensure the meal counts will be properly reported in the future.

View Audit 392349

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