Corrective Action Plans

Finding 1208557 (2025-079)

Material Weakness 2025

State of Alaska

AK

Subrecipient Monitoring Cash Management Significant Deficiency § 200.303 § 200.305

Finding: 2025-079 - The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned Costs: None Assistance Listing Number: 10.237, 15.423, 47.050, 47.074, 47.078 Assistance Listing Title: From Learning to Leading: Cultivating the Next Generation of Diverse ...

Finding: 2025-079 - The University did not make payments to subrecipients within 30 days after receipt of invoices. Questioned Costs: None Assistance Listing Number: 10.237, 15.423, 47.050, 47.074, 47.078 Assistance Listing Title: From Learning to Leading: Cultivating the Next Generation of Diverse Food and Agriculture Professionals Research and Development Cluster (RDC) Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): There is no disagreement with the audit finding. Corrective Action (corrective action planned): UAF Office of Finance & Accounting has established procedures to communicate with the departments to ensure outstanding invoices are resolved promptly. Additionally, guidance has been developed and distributed to Principal Investigator to ensure proper delegation of authority when they are unable to sign off on invoices. Completion Date (list anticipated completion date~: Completed Agency Contact (name of person responsible for corrective action): Amanda Wall, Associate Vice Chancellor (AVC), UAF Financial Services, 907-474-7552

View Audit 399484

Finding 1208500 (2025-076)

Material Weakness 2025

State of Alaska

AK

Subrecipient Monitoring Cash Management Material Weakness § 200.303

Finding: 2025-076 - The Alaska Industrial Development and Export Authority’s (AIDEA) controls were not designed to detect noncompliance in program income reported in AIDEA’s annual report. During our testing of reports, we noted that the annual report tested did not report interest earned on deposit...

Finding: 2025-076 - The Alaska Industrial Development and Export Authority’s (AIDEA) controls were not designed to detect noncompliance in program income reported in AIDEA’s annual report. During our testing of reports, we noted that the annual report tested did not report interest earned on deposit accounts. The amount of interest income not included on the annual report totaled 167,023, which represents the cumulative interest income earned for the program from deposits since inception Questioned Costs: None Assistance Listing Number: 11.307 Assistance Listing Title: Economic Development Cluster COVID- 19 Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): Agree Corrective Action (corrective action planned): DCCED manages this program on behalf of AIDEA. DCCED will incorporate a new internal control procedure requiring that each year’s final EDA-209 report be reviewed and approved by AIDEA’s Controller or Chief Financial Officer prior to submission and includes backup that supports each number. This review step will ensure the completeness and accuracy of all future filings. Completion Date (list anticipated completion date): 06/30/2026 (or the date of when the next EAD-209 report is due) Agency Contact (name of person responsible for corrective action): jkornmuller@aidea.orq, aleavitt@aidea.orq, andy.macaulay@alaska.qov

View Audit 399484

Finding 1208495 (2025-047)

Material Weakness 2025

State of Alaska

AK

Allowable Costs / Cost Principles Eligibility Special Tests & Provisions § 200.1 § 200.303

Finding: 2025-047 - The amount of FY 25 SNAP benefits reported to United States Department of Agriculture as issued by the State’s Electronic Benefits Transfer (EBT) contractor, Fidelity National Information Services (FIS), was 1,235,577 more than the amount of authorized benefits reported in data f...

Finding: 2025-047 - The amount of FY 25 SNAP benefits reported to United States Department of Agriculture as issued by the State’s Electronic Benefits Transfer (EBT) contractor, Fidelity National Information Services (FIS), was 1,235,577 more than the amount of authorized benefits reported in data from the Division of Public Assistance’s Eligibility Information System (EIS). Furthermore, FIS could not provide a reliable audit trail of issuances. Questioned Costs: AL 10.551: 1,235,577 Assistance Listing Number: 10.551, 10.561 Assistance Listing Title: Supplemental Nutrition Assistance Program (SNAP) Cluster Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department agrees with the finding but does not concur with the questioned costs. The Division of Public Assistance completes reconciliations between FIS daily transaction records and EBT Account Management Agent (AMA) data to ensure issuance accuracy. Corrective Action (corrective action planned): A workgroup identified the root causes of the discrepancies. A revised reporting process is being implemented to ensure all EBT payments are accurately captured, improving completeness and accuracy Daily reconciliations are now in place to support ongoing accuracy and reduce reliance on ad hoc reporting. As a result, the report previously developed for this audit by the EBT contractor, FIS, is not expected to be needed moving forward. Completion Date (list anticipated completion date): The department anticipates the finding will be resolved in FY2026. Agency Contact (name of person responsible for corrective action): Pam Halloran, Assistant Commissioner

View Audit 399484

Finding 1208489 (2025-007)

Material Weakness 2025

Milwaukee Public Schools

WI

Cash Management Significant Deficiency Internal Control / Segregation of Duties § 200.303

Medicaid Cluster – Assistance Listing No. 93.778 Recommendation: The District should design and implement controls to ensure required authorization to bill Medicare (Form M-5) is obtained prior to initial billing. We also recommend the District design and implement controls to ensure a copy of this ...

Medicaid Cluster – Assistance Listing No. 93.778 Recommendation: The District should design and implement controls to ensure required authorization to bill Medicare (Form M-5) is obtained prior to initial billing. We also recommend the District design and implement controls to ensure a copy of this form is retained in accordance with Federal and State requirements and is available for future required reviews. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will strengthen internal controls to ensure all required authorizations are obtained and properly maintained prior to billing. MPS will accomplish this through the execution of the following: • Implementing a pre-billing verification process to confirm a completed Form M-5 is on file before any initial Medicaid billing occurs, • Establishing a standardized documentation procedure to ensure all Forms M-5 are securely retained and readily accessible for review, • Creating a centralized tracking system to monitor the status of required authorizations for all eligible students, • Conducting periodic internal reviews to ensure compliance with authorization and documentation requirements, • Providing training to relevant staff on Medicaid billing requirements and record retention expectations. Name(s) of the contact person(s) responsible for corrective action: Budget Director, Accounting Director (Deputy CFO), Financial Reporting Manager Planned completion date for corrective action plan: Implementation of the new process is currently underway and will be remediated in the coming months of FY26 and into FY27.

View Audit 399474

Finding 1208476 (2025-005)

Material Weakness 2025

Milwaukee Public Schools

WI

Allowable Costs / Cost Principles Cash Management Eligibility § 200.303 § 200.430

Special Education Cluster (IDEA programs) – Assistance Listing No. 84.027, 84.170 Recommendation: The District should implement controls that allow for the identification and proper classification of vendor payments to applicable grant period. Explanation of disagreement with audit finding: There is...

Special Education Cluster (IDEA programs) – Assistance Listing No. 84.027, 84.170 Recommendation: The District should implement controls that allow for the identification and proper classification of vendor payments to applicable grant period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will strengthen internal controls to ensure that vendor payments are appropriately aligned with the correct grant reporting period. MPS will implement a standardized review process to validate that vendor invoices and related purchase orders are coded to the correct grant period, establish clear procedures for identifying the period of performance for goods and services, enhance coordination between program and finance staff to validate the timing and allowability of expenditures, conduct periodic monitoring of vendor payments to ensure compliance with grant period requirements, and provide training to relevant staff relating to grant period compliance and expenditure classification. Name(s) of the contact person(s) responsible for corrective action: Senior Director of Specialized Services, Accounting Director (Deputy CFO), Financial Reporting Manager Planned completion date for corrective action plan: 6/30/2026

View Audit 399474

Finding 1208468 (2025-001)

Material Weakness 2025

S.d.s.i. Housing Corporation, Inc.

KS

HUD Housing Programs Cash Management Eligibility

Management will contact HUD and negotiate a payment plan to return the ineligible funds of $135,824 withdrawn from the reserve for replacements.

View Audit 399458

Finding 1208464 (2025-003)

Material Weakness 2025

Manor Apartments, Inc.

MD

HUD Housing Programs Cash Management

a. Comments on the Finding and Each Recommendation During the year ended December 31, 2024, management did not submit Form HUD-9250, "Fund Authorization" to HUD upon termination of the PRAC. As a result, management did not remit excess residual receipts of $418 as of April 30, 2025, to HUD. b. Actio...

a. Comments on the Finding and Each Recommendation During the year ended December 31, 2024, management did not submit Form HUD-9250, "Fund Authorization" to HUD upon termination of the PRAC. As a result, management did not remit excess residual receipts of $418 as of April 30, 2025, to HUD. b. Action(s) Taken or Planned on the Finding The 2025 Manor renewal was submitted to HUD before the excess income was in the account. A 9250 for $584.59 has been submitted to HUD for approval of returning in excess residual receipts.

View Audit 399440

Finding 1208430 (2025-003)

Material Weakness 2025

Anderson Place Apartments, Inc.

IN

Cash Management

Recommendation: The design of the current controls should be reviewed to ensure all tenant security deposits are properly tracked. Management should make transfers to the security deposit account to cover all deposits currently on hand. Action Taken: Management agrees with the finding and will imple...

Recommendation: The design of the current controls should be reviewed to ensure all tenant security deposits are properly tracked. Management should make transfers to the security deposit account to cover all deposits currently on hand. Action Taken: Management agrees with the finding and will implement procedures to ensure proper tracking of security deposits and will make the necessary transfer to fund the security deposit account.

View Audit 399384

Finding 1208428 (2025-004)

Material Weakness 2025

Cain Center Apartments, Inc. Dba Brown-MacKinnon Apartments

KY

Cash Management

Recommendation: The design of the current controls should be reviewed to ensure all tenant security deposits are properly tracked. Management should make transfers to the security deposit account to cover all deposits currently on hand. Action Taken: The management of Cain Center Apartments, Inc. db...

Recommendation: The design of the current controls should be reviewed to ensure all tenant security deposits are properly tracked. Management should make transfers to the security deposit account to cover all deposits currently on hand. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-Mackinnon Apartments accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all move out adjustments processed utilize the proper vacancy date. The overpayment of subsidy will be repaid to HUD through adjustments to monthly billing.

View Audit 399383

Finding 1208425 (2025-003)

Material Weakness 2025

Thompson-Woodlief Apartments, Inc.

KY

Cash Management

Recommendation: The design of the current controls should be reviewed to ensure all tenant security deposits are properly tracked. Management should make transfers to the security deposit account to cover all deposits currently on hand. Action Taken: The management of Thompson-Woodlief Apartments, I...

Recommendation: The design of the current controls should be reviewed to ensure all tenant security deposits are properly tracked. Management should make transfers to the security deposit account to cover all deposits currently on hand. Action Taken: The management of Thompson-Woodlief Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure proper tracking of security deposits and will make the necessary transfer to fund the security deposit account.

View Audit 399382

Finding 1208422 (2025-005)

Material Weakness 2025

Jude's Place Apartments, Inc.

KY

Cash Management

Recommendation: The design of the current controls should be reviewed to ensure all tenant security deposits are properly tracked. Management should make transfers to the security deposit account to cover all deposits currently on hand. Action Taken: The management of Jude’s Place Apartments, Inc. a...

Recommendation: The design of the current controls should be reviewed to ensure all tenant security deposits are properly tracked. Management should make transfers to the security deposit account to cover all deposits currently on hand. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure proper tracking of security deposits and will make the necessary transfer to fund the security deposit account.

View Audit 399381

Finding 1208415 (2025-004)

Material Weakness 2025

Adams-Bodine Apartments, Inc.

KY

Cash Management

Recommendation: The design of the current controls should be reviewed to ensure all tenant security deposits are properly tracked. Management should make transfers to the security deposit account to cover all deposits currently on hand. Action Taken: The management of Adams-Bodine Apartments, Inc. a...

Recommendation: The design of the current controls should be reviewed to ensure all tenant security deposits are properly tracked. Management should make transfers to the security deposit account to cover all deposits currently on hand. Action Taken: The management of Adams-Bodine Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure proper tracking of security deposits and will make the necessary transfer to fund the security deposit account.

View Audit 399378

Finding 1208403 (2025-002)

Material Weakness 2025

Mountainview Daycare Nutrition Program

WA

Cash Management

In response to the Operational Weakness found during the recent audit, MDNP has put into effect the following training and processes. A new process has been implemented, and has been part of staff training and is retained in the center Policy/Processes file on the server. Personnel are informed of t...

In response to the Operational Weakness found during the recent audit, MDNP has put into effect the following training and processes. A new process has been implemented, and has been part of staff training and is retained in the center Policy/Processes file on the server. Personnel are informed of the roles and responsibilities related to the accuracy of EIEA approval during staff training and on a one to one basis as needed.

View Audit 399371

Finding 1208268 (2025-001)

Material Weakness 2025

Good Shepherd Homes, Inc.

MN

HUD Housing Programs Cash Management Significant Deficiency

United States Department of Housing and Urban Development Good Shepherd Homes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: January 01, 2025 - December 31, 2025 The findings from the schedule of findings and questioned costs are d...

United States Department of Housing and Urban Development Good Shepherd Homes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: January 01, 2025 - December 31, 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. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS United States Department of Housing and Urban Development SIGNIFICANT DEFICIENCY 2025-001 Section 223(f) Mortgage Insurance for the Refinance of Existing Multifamily Housing Projects Federal Assistance Listing #14.155 Recommendation: We recommend that management deposit the remaining $770 to the residual receipts account as soon as possible. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management deposited the $770 into the residual receipts account on March 12, 2026. Management will ensure moving forward that if the Project has surplus cash, the correct amount will be deposited into the residual receipts account. Name(s) of the contact person(s) responsible for corrective action: Krista Martini, Chief Financial Officer Planned completion date for corrective action plan: March 12, 2026 If the United States Department of Housing and Urban Development has questions regarding this plan, please call Krista Martini at 320-259-3490.

View Audit 399272

Finding 1208267 (2025-009)

Material Weakness 2025

Polytechnic University of Puerto Rico, Inc.

PR

Cash Management § 200.302 § 200.305

The University will strengthen its cash management procedures to ensure that federal funds requests (drawdowns) are limited to immediate cash needs and that funds are disbursed within required timeframes. Enhancements will be made to the existing reconciliation process to ensure it provides sufficie...

The University will strengthen its cash management procedures to ensure that federal funds requests (drawdowns) are limited to immediate cash needs and that funds are disbursed within required timeframes. Enhancements will be made to the existing reconciliation process to ensure it provides sufficient detail to accurately link drawdowns to the corresponding disbursements and payroll charges, supported by adequate documentation. Additionally, Pre‑ and post‑disbursement reviews will be implemented to verify timing, accuracy, allowability, and prevent duplicate requests. Policies and procedures will be reinforced, and internal controls strengthened through segregation of duties, supervisory review, and documented approval processes. All records will be centrally maintained, and staff will receive targeted training to ensure consistent compliance. Furthermore, the University will also implement ongoing monitoring and periodic internal reviews to promote sustained compliance and address repeat findings. All corrective actions will be implemented within 30–60 days.

View Audit 399265

Finding 1208258 (2025-002)

Material Weakness 2025

Polytechnic University of Puerto Rico, Inc.

PR

Cash Management Student Financial Aid § 200.303

The University will implement a monthly reconciliation process linking each fund request (G5 drawdown) to underlying Title IV disbursements using Ellucian Banner reports including the Disbursement Report, supported by a standardized reconciliation. Policies and new procedures for cash management, re...

The University will implement a monthly reconciliation process linking each fund request (G5 drawdown) to underlying Title IV disbursements using Ellucian Banner reports including the Disbursement Report, supported by a standardized reconciliation. Policies and new procedures for cash management, reconciliation, and record retention will be design and formalized. Additionally, all documentation will be centrally maintained, the staff will be trained in the new process, and the University will pursue Banner reporting enhancements to improve transaction-level tracking.

View Audit 399265

Finding 1208212 (2025-001)

Material Weakness 2025

New Brittany Housing Foundation

CA

Cash Management HUD Housing Programs

The delay in the deposit was an oversight. The deposit has been made. Management will review the surplus cash calculation and ensure any required deposits are made within 90 days of year end.

View Audit 399143

Finding 1208198 (2025-001)

Material Weakness 2025

Texarkana Arkansas School District

AR

Cash Management Subrecipient Monitoring § 200.305

The District has implemented an internal control process that requires the review and approval of detailed expenditure reports and G5 drawdown amounts prior to submission. The review process includes the Director of the Magnet Program, Finance Coordinator, Executive Director of School Leadership, an...

The District has implemented an internal control process that requires the review and approval of detailed expenditure reports and G5 drawdown amounts prior to submission. The review process includes the Director of the Magnet Program, Finance Coordinator, Executive Director of School Leadership, and the Business Manager to ensure accuracy, compliance, and proper authorization before completion.

View Audit 399080

Finding 1208170 (2025-006)

Material Weakness 2025

Stillwater County

MT

Subrecipient Monitoring Special Tests & Provisions Cash Management

FINDING 2025-006: FEMA Grants Response: The county finance office has implemented a project number for each grant received and follows other projects according to this numbering schedule. At the time of the initial FEMA grant operations there was not a Finance Officer in place, and all expenditure w...

FINDING 2025-006: FEMA Grants Response: The county finance office has implemented a project number for each grant received and follows other projects according to this numbering schedule. At the time of the initial FEMA grant operations there was not a Finance Officer in place, and all expenditure went into one Fund without description as to what expenditure they were covering. The FEMA grants for events in 2022 and 2023 are near close out with FEMA and the State, all revenue from these grants has been redeemed.

View Audit 399021

Finding 1208143 (2025-001)

Material Weakness 2025

Case Western Reserve University

OH

Cash Management § 200.302

The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302 (b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properl...

The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302 (b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properly supported and authorized prior to submission. During the audit period, at least one drawdown was approved, one day retroactively, after submission but prior to receipt of funds. This occurred prior to the remediation period. No exceptions were identified in the remediation period, and the finding is considered remediated. The instance arose during a leadership transition with the Office of Research Administration. Since that time, the entire drawdown process, review and approval has been clarified under new leadership, and additional oversight has been implemented to ensure approvals are documented prior to submission. As part of the drawdown process review, the University developed a standardized drawdown template, which streamlines how the Federal award expense information is gathered, compared to approve budgeted amounts and reviewed for approval. The template documents the preparer, the approver and the dates of both for the respective drawdown. The Office of Research Administration received training on the use of the template in January and February 2026 and implementation is planned for February 2026. Primary responsibility for implementing the correction action plan for this finding rests with Angela Tagliaferri, Assistant Vice President of Post-Award Services and Financial Compliance, 216-368-6269.

View Audit 399018

Finding 1207156 (2025-001)

Material Weakness 2025

Evergreen Park Elementary School District 124

IL

Cash Management Reporting

The District and Business Manager will implement controls to properly report expenses to ISBE on a timely basis.

View Audit 399009

Finding 1207122 (2025-006)

Material Weakness 2025

Livingston School District No. 4 & 1

MT

Subrecipient Monitoring Student Financial Aid Cash Management

FINDING 2025-006: Program Income Response: This repeat finding is related to the Districts LINKS afterschool program supported by 21st Century funding. The Office of Public Instruction (OPI) performed monitoring of Livingston schools 21st Century program in August of 2024 and determined the District...

FINDING 2025-006: Program Income Response: This repeat finding is related to the Districts LINKS afterschool program supported by 21st Century funding. The Office of Public Instruction (OPI) performed monitoring of Livingston schools 21st Century program in August of 2024 and determined the District was not in compliance with changes to federal regulations made in 2018. The District has made all recommended changes from OPI and is now in compliance with federal regulations.

View Audit 398964

Finding 1207114 (2025-004)

Material Weakness 2025

Dolton School District 149

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.303

Condition: On May 15, 2025, ISBE communicated to the District that ARP ESSER recipients had until May 24, 2025 to liquidate obligations and that the District needed to submit its expenditure report to ISBE by May 21, 2025 for ISBE to process and submit to the U.S. Department of Education by the new ...

Condition: On May 15, 2025, ISBE communicated to the District that ARP ESSER recipients had until May 24, 2025 to liquidate obligations and that the District needed to submit its expenditure report to ISBE by May 21, 2025 for ISBE to process and submit to the U.S. Department of Education by the new deadline. On May 21, 2025, the District submitted a claim for reimbursement of expenditures totaling $4,343,814. The expenditures comprising this claim by date incurred and liquidated were as follows: $1,668,710 incurred through May 21, 2025 and liquidated as of that date $31,692 incurred through May 21, 2025 but not liquidated as of that date $325,805 incurred from May 21, 2025 through June 30, 2025 and liquidated as of June 30, 2025 $531,321 incurred from May 21, 2025 through June 30, 2025 but not liquidated as of June 30, 2025 $1,786,286 incurred after June 30, 2025 At May 21, 2025 and June 30, 2025, expenditures totaling $2,675,104 and 2,349,299, respectively, out of the $4,343,814 claimed for reimbursement were not incurred, not liquidated or both and, therefore, did not qualify for reimbursement based on the Federal statutes, regulations and the terms and conditions of the Federal award in effect at those dates. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Responsible Person: Dr. Maureen M. White, Superintendent Anticipated Completion Date: June 30, 2026

View Audit 398922

Finding 1207110 (2025-005)

Material Weakness 2025

St. George Fire Protection District No. 2

LA

Allowable Costs / Cost Principles Cash Management Matching / Level of Effort / Earmarking § 200.303 § 200.305

2025-005 – Noncompliance and Deficiency in Internal Control over Cash Management Corrective Action: The District will implement a documented review and approval process for each Federal reimbursement request prior to submission, including verification of calculations, agreement to supporting documen...

2025-005 – Noncompliance and Deficiency in Internal Control over Cash Management Corrective Action: The District will implement a documented review and approval process for each Federal reimbursement request prior to submission, including verification of calculations, agreement to supporting documentation, and allowability within the reimbursement period. The reimbursement package, review documentation, and approval will be retained in accordance with the District’s records retention policy for each applicable grant award. Management will not submit reimbursement requests until the documented review is complete and any identified discrepancies are resolved. Responsible Officials: Fire Chief Gerard Tarleton Anticipated Completion Date: September 2026

View Audit 398900

Finding 1206882 (2025-002)

Material Weakness 2025

Southeastern Oklahoma State University

OK

Subrecipient Monitoring Cash Management Internal Control / Segregation of Duties § 200.305

Management acknowledges the finding related to cash management requirements and the timing of federal fund draws and disbursements. While the University maintains a robust, multi-layered review process, enhancements are necessary to ensure full alignment with federal requirements regarding the minim...

Management acknowledges the finding related to cash management requirements and the timing of federal fund draws and disbursements. While the University maintains a robust, multi-layered review process, enhancements are necessary to ensure full alignment with federal requirements regarding the minimization of time between the receipt and disbursement of funds. The University currently utilizes several internal controls, including: • A two-person pre-draw validation process to ensure draws align with liquidated expenses • Programmatic oversight through detailed fiscal year draw reports and reconciliation to G5 activity • Periodic fiscal year and program year reviews to identify and correct discrepancies These controls enabled the University to identify and correct the instances noted in the audit. However, management recognizes that refinements are needed to further align the timing of draws with actual cash disbursement activity. To address this, the University will implement the following corrective actions: 1. Refinement of Draw Timing – Draw requests will be more closely aligned with immediate cash needs and anticipated disbursement activity. 2. Enhanced Pre-Draw Reconciliation – In addition to existing controls, a real-time reconciliation of outstanding obligations and pending disbursements will be required prior to each draw to ensure alignment with cash needs. 3. Standardized Draw Calendar Adjustments – The University will evaluate and adjust its draw schedule, where necessary, to better align with actual disbursement cycles, including payroll and purchase card activity. 4. Formalized Monitoring and Documentation – Documentation will be maintained to support the relationship between drawdowns and disbursements, and periodic internal reviews will be conducted to ensure ongoing compliance. 5. Training and Communication – Additional guidance will be provided to program and fiscal staff regarding federal cash management requirements and expectations for timing of draws. Management believes these enhancements, in combination with existing internal controls, will ensure compliance with federal cash management requirements and prevent recurrence of this issue. Implementation Date: July 1, 2025 Responsible Party: James Altman (Director of Finance) in coordination with Darla Ellett (Trio Director) and Teriki Barnes (Trio Director)

View Audit 398877

Corrective Action Plans

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