Corrective Action Plans

Finding 1176714 (2025-001)

Material Weakness 2025

IN

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

Findings Reported by Uniform Guidance – The following steps have been taken or will be taken to address Finding 2025-001: • Aspire Indiana Health continues to focus on reviews of the rental assistance calculation forms to make sure future issues are caught before submission • Aspire Indiana Health u...

Findings Reported by Uniform Guidance – The following steps have been taken or will be taken to address Finding 2025-001: • Aspire Indiana Health continues to focus on reviews of the rental assistance calculation forms to make sure future issues are caught before submission • Aspire Indiana Health upon discovery of the errors corrected within the system and plan to reverse out the dollars received in future drawdowns for this program

View Audit 390612

Finding 1176701 (2025-001)

Material Weakness 2025

Crescent Community Health Center

IA

Cash Management

Management acknowledges the cash management finding and the corrective action needed to ensure compliance with drawdown submissions, specifically the need to ensure that the timing of monthly drawdowns is supported by expenditures that have been incurred and paid prior to request for funds. To corre...

Management acknowledges the cash management finding and the corrective action needed to ensure compliance with drawdown submissions, specifically the need to ensure that the timing of monthly drawdowns is supported by expenditures that have been incurred and paid prior to request for funds. To correct this, we have created an updated schedule to ensure allocated expenditures have already been incurred and adjusted the timing of drawdown request submissions to occur during the first week of the following month to ensure all allocated expenses have been incurred and paid. All parties involved in the cash management process for the Base grant funding have been notified. These changes are in effect as of January 2026. Sherri Edwards, Director of Grants, will update timing of the preparation of drawdowns as noted. Brandon Cannon, Accounting Manager, will update the new monthly schedule to ensure that reimbursement status is maintained. Sam Lammers, CFO, will review the prepared monthly drawdown request to ensure updated procedures are properly applied.

View Audit 390586

Finding 1176676 (2025-003)

Material Weakness 2025

Community Mental Health Affilates, Inc.

CT

Cash Management Reporting Significant Deficiency § 200.516

Corrective Action Planned: Management will enhance internal control processes related to grants to include controls for proper lines of communication with granting agencies to ensure all required reporting requirements are identified and adhered to. Name(s) of Contact Person(s) Responsible for Corre...

Corrective Action Planned: Management will enhance internal control processes related to grants to include controls for proper lines of communication with granting agencies to ensure all required reporting requirements are identified and adhered to. Name(s) of Contact Person(s) Responsible for Corrective Action: Veronica Bochain, Director of Finance Anticipated Completion Date: For FY26 procedures have been put in place to maintain a schedule of reporting due dates that are reviewed monthly to ensure timely submissions.

View Audit 390542

Finding 1176675 (2025-002)

Material Weakness 2025

Community Mental Health Affilates, Inc.

CT

Cash Management Reporting Significant Deficiency § 200.516

orrective Action Planned: Management will enhance internal control processes related to grants to include controls for proper lines of communication with granting agencies to ensure all required reporting requirements are identified and adhered to. Name(s) of Contact Person(s) Responsible for Correc...

orrective Action Planned: Management will enhance internal control processes related to grants to include controls for proper lines of communication with granting agencies to ensure all required reporting requirements are identified and adhered to. Name(s) of Contact Person(s) Responsible for Corrective Action: Veronica Bochain, Director of Finance Anticipated Completion Date: For FY26 procedures have been put in place to maintain a schedule of reporting due dates that are reviewed monthly to ensure timely submissions.

View Audit 390542

Finding 1176625 (2025-008)

Material Weakness 2025

Oregon Association of Relief Nurseries

OR

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles § 200.305

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the sub...

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the subrecipient's behalf. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective October 1, 2025, all subrecipients were notified that payments would be made only to them, requiring them to directly pay their contractors and vendors. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: October 1, 2025

View Audit 390474

Finding 1176542 (2025-004)

Material Weakness 2025

State of West Virginia

WV

Cash Management Reporting Student Financial Aid § 200.303

2025-004 REPORTING – CASH MANAGEMENT IMPROVEMENT ACT WEST VIRGINIA STATE TREASURER’S OFFICE (WVSTO) Assistance Listing Numbers: 10.551/10.561/10.555/17.225/20.205/84.010/84.027/84.425/93.558/93.568/ 93.575/93.658/93.659/93.767/93.778/97.036 For the Annual Report filing deadline, December 31, 2025, W...

2025-004 REPORTING – CASH MANAGEMENT IMPROVEMENT ACT WEST VIRGINIA STATE TREASURER’S OFFICE (WVSTO) Assistance Listing Numbers: 10.551/10.561/10.555/17.225/20.205/84.010/84.027/84.425/93.558/93.568/ 93.575/93.658/93.659/93.767/93.778/97.036 For the Annual Report filing deadline, December 31, 2025, WVSTO staff experienced multiple extenuating circumstances including training of newer staff members, medical treatments, illness, and the sudden unexpected passing of a close family member. Realizing that these circumstances would interfere with the timely submission of the Annual Report, an extension was requested on December 30, 2025, with the Bureau of the Fiscal Service and was granted through Friday, January 9, 2026. Regrettably, the extenuating circumstances were not fully resolved by that date, and the report was ultimately submitted on January 14, 2026. The WVSTO remained focused on completing the Report but overlooked the need to request an additional extension. WVSTO staff subsequently met with Angela Smith, Director of the Bureau of the Fiscal Service and staff members Mary Bailey and Christopher Bush from the Revenue Collections Management Team. Director Smith confirmed there will be no penalties assessed due to the late filing. Additionally, WVSTO Banking Services staff will review the internal timeline of CMIA activities and procedures to ensure that future reporting is complete and submitted in a timely manner.

View Audit 390319

Finding 1176512 (2025-010)

Material Weakness 2025

State of West Virginia

WV

Matching / Level of Effort / Earmarking Student Financial Aid Cash Management § 200.303

2025-010 CASH MANAGEMENT GLENVILLE STATE UNIVERSITY (GSU), SOUTHERN WEST VIRGINIA COMMUNTY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 Glenville State University (GSU) Response: As of December 2024, the Glenville State University (GSU) Financial Aid Office, in conjunctio...

2025-010 CASH MANAGEMENT GLENVILLE STATE UNIVERSITY (GSU), SOUTHERN WEST VIRGINIA COMMUNTY AND TECHNICAL COLLEGE (SWVCTC) Assistance Listing Numbers: 84.063/84.268 Glenville State University (GSU) Response: As of December 2024, the Glenville State University (GSU) Financial Aid Office, in conjunction with the GSU Business and Finance Office, has implemented policies and procedures to perform, at a minimum, monthly Pell Grant and Direct Loan reconciliations, with the appropriate signoffs. The GSU Financial Aid Office reviews and reconciles all Pell Grant and Direct Loan disbursement records at least monthly by comparing Banner records to Common Origination and Disbursement (COD) records. If any do not match, the GSU Financial Aid Office notes this within their documentation and resolves these discrepancies in a timely manner. They are reconciled by the GSU Financial Aid Office, signed off by the reconciling staff member, as well as the Financial Aid Director. Further, the GSU Business and Finance Office Accountant and GSU Financial Controller review and sign-off the reconciled data. The final copy is kept within the GSU Financial Aid Office. 78 Southern West Virginia Community and Technical College (SWVCTC) Response: A Monthly Reconciliation Cover Sheet has been developed. The Financial Aid Counselor will complete the monthly and annual reconciliation for each fund (e.g., Pell Grant, Student Loans). The cover sheet will document the month reconciled, the fund being reconciled, the amount disbursed in Banner, the amount disbursed through COD, any discrepancies with explanations, and the preparer’s signature. The applicable SAS Reconciliation for each fund will be attached to the cover sheet. Upon completion, the reconciliation and cover sheet will be reviewed and approved by the Director of Student Financial Assistance.

View Audit 390319

Finding 1176393 (2025-004)

Material Weakness 2025

School District of Osceola

WI

Cash Management Reporting Significant Deficiency

Finding Reference Number: Finding 2025-004: Significant Deficiency in Internal Control and Compliance over Reporting – Medicaid Cluster Corrective Action: The District submitted corrected versions of the Quarterly Financial Summaries to SBS after audit fieldwork. The District plans for the Finance D...

Finding Reference Number: Finding 2025-004: Significant Deficiency in Internal Control and Compliance over Reporting – Medicaid Cluster Corrective Action: The District submitted corrected versions of the Quarterly Financial Summaries to SBS after audit fieldwork. The District plans for the Finance Director to review Quarterly Financial Summaries and Annual Cost reports and document this review before submitting to SBS. The payroll coordinator will prepare the quarterly financial summaries and they will be reviewed by the Business Manager prior to submission to ensure accuracy. Responsible Person: Shannon Grindell, Sharon Weise Anticipated Completion Date: Ongoing

View Audit 390213

Finding 1176364 (2025-002)

Material Weakness 2025

Volunteers of America Colorado Branch

CO

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Condition: The Organization lacked adequate controls to ensure reviews were performed by a different individual than the one responsible for preparing monthly financial reporting, calculations of per-unit activity, and requests for reimbursement. Planned Corrective Action: 1. Standardization of Fina...

Condition: The Organization lacked adequate controls to ensure reviews were performed by a different individual than the one responsible for preparing monthly financial reporting, calculations of per-unit activity, and requests for reimbursement. Planned Corrective Action: 1. Standardization of Financial Reporting Workflow: A formal segregation of duties for all federal and pass-through reimbursement requests and financial reports has been implemented. Effective immediately, the individual responsible for accumulating cost data and calculating per-unit activity (preparer) is prohibited from being the reviewer. 2. Implementation of Approval Process: All reports must now be submitted by the preparer to the designated reviewer for approval via email prior to submission. An approval response from the reviewer is required prior to submission to the awarding agency. 3. Staff Training: All grants management and accounting personnel have been briefed on the requirements of 2 CFR 200.303, specifically regarding the necessity of documented internal controls to provide reasonable assurance of compliance. Contact person responsible for corrective action: Erin Nordmann (Controller) Chiyoko Yokota (Chief Financial Officer) Anticipated Completion Date: Fully Corrected

View Audit 390182

Finding 1176195 (2025-001)

Material Weakness 2025

Euclid City School District

OH

Cash Management Reporting Internal Control / Segregation of Duties

The District’s Director of Business Affairs conducts reviews of meal counts manually entered into the District’s point of sale system and the CRRS, and verifies the counts entered manually into the CRRS system. These review procedures are acknowledged by initials/signatures.

View Audit 390018

Finding 1175879 (2025-004)

Material Weakness 2025

Shenandoah Women's Center Inc. D/b/a Eastern Panhandle Empowerment Ctr

WV

Allowable Costs / Cost Principles Cash Management Reporting

During the period under review, the organization experienced turnover in the accounting position, which impacted continuity in grant reporting processes. In addition, VOCA grant funding administered through JCS (the grantor) transitioned from an advance payment method to a reimbursement-based paymen...

During the period under review, the organization experienced turnover in the accounting position, which impacted continuity in grant reporting processes. In addition, VOCA grant funding administered through JCS (the grantor) transitioned from an advance payment method to a reimbursement-based payment structure. This change significantly affected the timing and presentation of expenditures reported on monthly financial reports. Management would like to clarify that the revisions made to all 12 reports were not the result of unallowable or unsupported costs. As noted in the audit, there were no questioned costs. The grantor adjusted the reports primarily due to the shift in payment methodology and reconciliation of prior-year unexpended funds. In several instances, JCS modified invoice amounts after submission to align with its updated reimbursement process and internal grant tracking. These post-submission adjustments were administrative in nature and not attributable to improper expenditure classification or misuse of grant funds by the organization. We recognize, however, that stronger internal review controls could have reduced the need for grantor-initiated revisions. To address this matter and strengthen compliance EPEC, has instituted a double check procedure on invoices.

View Audit 389856

Finding 1175838 (2025-001)

Material Weakness 2025

Queens B'nai B'rith Housing Development Fund Company INC

NY

HUD Housing Programs Cash Management

Recommendation: The Housing Company should create and fund the Residual Receipts account. Comments on the Finding and Each Recommendation: Management concurs with the finding and auditor's recommendation to fund the reserve account. Action Taken: The Housing Company funded the reserve account on Sep...

Recommendation: The Housing Company should create and fund the Residual Receipts account. Comments on the Finding and Each Recommendation: Management concurs with the finding and auditor's recommendation to fund the reserve account. Action Taken: The Housing Company funded the reserve account on September 30, 2025.

View Audit 389804

Finding 1175829 (2025-003)

Material Weakness 2025

North Central Education Cooperative

ND

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.430

Contact Person Tonya Hunskor Planned Corrective Action The Cooperative will ensure proper subrecipient monitoring is implemented. Planned Completion Date June 30, 2026.

View Audit 389783

Finding 1175815 (2025-003)

Material Weakness 2025

Isd #482 - Little Falls

MN

Subrecipient Monitoring Cash Management Reporting

Finding 2025-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and re...

Finding 2025-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Greg Johnson, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date The planned completion date is June 30, 2026. 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.

View Audit 389746

Finding 1175772 (2025-004)

Material Weakness 2025

Albright College

PA

Cash Management Student Financial Aid Internal Control / Segregation of Duties

Name of Responsible Individual: Larry Bomback, Interim CFO ; Justin Roy, VP of Enrollment ; Irene Langran, VP of Academic Affairs Corrective Action: Management acknowledges the instance in which Title IV funds were held beyond the allowable timeframe under 34 CFR §668.166. Although the amount was wi...

Name of Responsible Individual: Larry Bomback, Interim CFO ; Justin Roy, VP of Enrollment ; Irene Langran, VP of Academic Affairs Corrective Action: Management acknowledges the instance in which Title IV funds were held beyond the allowable timeframe under 34 CFR §668.166. Although the amount was within allowable tolerance thresholds and no questioned costs were identified, the College recognizes the need to strengthen internal controls over cash management compliance. To address this finding, the College will: • Implement a formal Title IV drawdown and disbursement monitoring procedure requiring review no later than the third business day following receipt of funds • Establish a standardized reconciliation process between the Business Office, Financial Aid Office, and Registrar to ensure timely identification of: o Students who have withdrawn o Enrollment status changes o Required returns of Title IV (R2T4) calculations • Develop a documented weekly reconciliation of federal drawdowns to disbursements and student account activity • Assign clear responsibility for monitoring excess cash thresholds and ensuring timely return of funds to the U.S. Department of Education when required • Provide cross-functional training to reinforce compliance requirements under federal cash management regulations These measures are intended to ensure timely disbursement of Title IV funds, proper reconciliation of enrollment changes, and full compliance with federal cash management requirements. Anticipated Completion Date: May 31, 2026

View Audit 389689

Finding 1175769 (2025-005)

Material Weakness 2025

Big Springs Medical Association D/b/a Missouri Highlands Health Care

MO

Cash Management Internal Control / Segregation of Duties Program Income

2025-005: Funds available from program income were not disbursed before the Organization requested additional drawdowns. The Organization was not appropriately with tracking and utilizing program income. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief ...

2025-005: Funds available from program income were not disbursed before the Organization requested additional drawdowns. The Organization was not appropriately with tracking and utilizing program income. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: August 2025 Views of responsible officials and planned corrective actions: Issues identified during the audit were indicative of an overall lack of controls and processes due to the change in Finance department staff and loss of knowledge. As of August 2025, program income is no longer being generated by the grant. The new CFO and Finance staff have also implemented processes and controls to ensure proper tracking and utilization of program income related to grants. The CEO will provide ongoing oversight to ensure processes and controls are being adhered to by the Finance Department.

View Audit 389688

Finding 1175768 (2025-004)

Material Weakness 2025

Big Springs Medical Association D/b/a Missouri Highlands Health Care

MO

Cash Management

2025-004: On January 27, 2025, the Office of Management and Budget (OMB) ordered a pause to the disbursement of federal grants to take effect the following day. Due to uncertainty around how long the pause would last and the Organization’s anticipated cash flow needs, management advance drew on the ...

2025-004: On January 27, 2025, the Office of Management and Budget (OMB) ordered a pause to the disbursement of federal grants to take effect the following day. Due to uncertainty around how long the pause would last and the Organization’s anticipated cash flow needs, management advance drew on the Organization’s federal awards on January 28, 2025. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: May 2025 Views of responsible officials and planned corrective actions: This is a once in a lifetime occurrence based on uncertainty and the Organization’s cash position at the time. The Organization has reviewed the cash management policy to ensure it is compliant. Additionally, the Organization has taken steps to improve its cash position and do not view this as an ongoing issue.

View Audit 389688

Finding 1175753 (2025-001)

Material Weakness 2025

High Point University

NC

Cash Management Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Finding 2025-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely mann...

Finding 2025-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. University’s Response: The excess cash balance relates to prior award years and is not part of the currently audited period. The University has maintained these funds in a segregated federal funds account and safeguarded them from expenditure while performing reconciliation. The University is actively coordinating with the Department of Education to determine the appropriate process for returning the excess cash and will follow their guidance once received. The University has continued to ensure these funds are not comingled and has protected them from spending. Because of the discrepancies identified, each student’s loan history had to be reviewed and compared between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation have proven to be a tedious but necessary process to identify the funds never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: The University, working with an external financial aid consulting firm with experience in reconciling FFEL loan programs, has finished researching all related accounts against the National Student Loan Database System (NSLDS) records. The University continues to work with the Department of Education to determine how to return funds in instances where the last lender used is no longer available to process student loan funds, and lastly, book the appropriate entries for any funds determined to belong to the University that were not moved to the University operating accounts properly at the time of the transactions. Name of the responsible person: Brad Calloway, Senior Vice President for Business Affairs Anticipated completion date: Unknown

View Audit 389665

Finding 1175749 (2025-005)

Material Weakness 2025

University of the Incarnate Word

TX

Matching / Level of Effort / Earmarking Student Financial Aid Cash Management § 200.303

Finding 2025-005 – Cash Management Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: February 1, 2026 Condition: The University did not provide evidence that the School Account Statements (SAS) from ED were used to reconcile to the U...

Finding 2025-005 – Cash Management Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: February 1, 2026 Condition: The University did not provide evidence that the School Account Statements (SAS) from ED were used to reconcile to the University’s financial and business records on a monthly basis during the year ended May 31, 2025. Identification of repeat finding: N/A Resolution: We maintain that we did reconcile to the School Account Statements, as evidenced by the reports that have been run against the SAS statements through the Banner job RLRDLRC. However, we did not maintain the individual monthly evidence of the mismatches identified on those reports, and their resolution. We are maintaining this evidence going forward.

View Audit 389658

Finding 1175732 (2025-003)

Material Weakness 2025

Saint Mary's University of Minnesota

MN

Student Financial Aid Cash Management Significant Deficiency

Saint Mary’s University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-003 - Cash Management Condition G5 Drawdown requests were not documented as reviewed and approved by a responsible party separate from the preparer. For 2 of the 7 G5 draws tested, there was no d...

Saint Mary’s University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-003 - Cash Management Condition G5 Drawdown requests were not documented as reviewed and approved by a responsible party separate from the preparer. For 2 of the 7 G5 draws tested, there was no documentation of review or approval by someone other than the preparer. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: A form will be created to support each G5 draw or refund. Requestor will fill out the form, providing details of the transaction. The form will be reviewed and signed off by the Controller or EVP of Finance. The person performing the transaction in G5 will sign, attached all the appropriate back-up and file in a designated area for future reference. Name(s) of Contact Person(s) Responsible for Corrective Action: Karen Stellpflug, Controller and David Ansell, Assistant Vice President for Finance Anticipated Completion Date: March 31, 2026

View Audit 389644

Finding 1175718 (2025-001)

Material Weakness 2025

Montana Cancer Consortium

MT

Allowable Costs / Cost Principles Cash Management Matching / Level of Effort / Earmarking § 200.302 § 200.305 § 200.313 § 200.430

Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporti...

Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. Montana Cancer Consortium (MCC) has updated the Financial Process Procedure to include language related to receipt management, allowable and disallowed grant expenses, and timing of payment requests. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators

View Audit 389640

Finding 1175684 (2025-002)

Material Weakness 2025

Iberia Comprehensive Community Health Center

LA

Cash Management

Management has currently implemented procedures for grant funded expenditures to ensure that complete documentation supporting the funds requests are available and at the time of the drawdown of the grant funds.

View Audit 389534

Finding 1175646 (2025-003)

Material Weakness 2025

Durham Public Schools

NC

Subrecipient Monitoring Cash Management Material Weakness

Contact Person: Jeremy Teetor, Chief Financial Officer Corrective Action Plan: The finding resulted primarily from significant turnover within the Finance Department. Management has established procedures to ensure that all bank account and other required reconciliations are prepared on a timely bas...

Contact Person: Jeremy Teetor, Chief Financial Officer Corrective Action Plan: The finding resulted primarily from significant turnover within the Finance Department. Management has established procedures to ensure that all bank account and other required reconciliations are prepared on a timely basis going forward. The Finance department will also strive to keep key positions filled at all times and ensure that staff receives appropriate training regarding reconciliations. Proposed Completetion Date: Immediately

View Audit 389467

Finding 1175612 (2025-004)

Material Weakness 2025

Otero County

NM

Reporting Subrecipient Monitoring Cash Management § 200.303

Views of Responsible Officials Management concurs with the finding. The Operation Stonegarden grants are managed by Broken Arrow Services, LLC, who is contracted with Otero County for this purpose. For future audits, management will refer auditors directly to Broken Arrow Services, LLC for all docum...

Views of Responsible Officials Management concurs with the finding. The Operation Stonegarden grants are managed by Broken Arrow Services, LLC, who is contracted with Otero County for this purpose. For future audits, management will refer auditors directly to Broken Arrow Services, LLC for all documentation, (other than the SEFA and general ledger reports), as they maintain the most accurate and up-todate records for all reporting, purchases, and reimbursements. Broken Arrow Services, LLC has communicated to all sub-recipients the importance of submitting reports and invoices in a timely manner so that financial and performance reports can be completed and submitted to DHSEM by the required deadlines each quarter. All late submissions by sub-recipients will be tracked and follow-up efforts will be documented. The SEFA report did not include the expenditures for sub-recipients, and this was an honest oversight that will not be omitted in the future. The Finance Department will continue to prepare the SEFA and provide general ledger reports to the auditors. Finding Resolutions Timeline: Completed. December 18, 2025 Designation Of Employee Position Responsible For Meeting This Deadline: Finance Director

View Audit 389450

Finding 1175611 (2025-002)

Material Weakness 2025

Lehigh University

PA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the...

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the student was enrolled in the summer term and their summer Pell Grant was not processed until October. As a result, the Title IV credit balance was created well after the end of the summer payment period, outside of our typical refund monitoring cycle for that term. In the second instance, the credit balance was identified within the 14-day requirement. However, the student had not enrolled in direct deposit through the eBill system. Lehigh contacted the student to obtain payment instructions. When no banking information was provided to Lehigh, a paper check had to be issued, which extended the disbursement timeline beyond the 14-day period. While these situations were atypical, we recognize the importance of ensuring timely disbursement regardless of individual circumstances. To strengthen controls, we continue to prioritize Title IV credit balance refunds over refunds resulting from institutional aid or other funding sources to ensure compliance with federal timelines. Although we continue our institutional practice of holding refunds until after the 10th day of class to account for schedule adjustments and enrollment changes, we will begin generating and reviewing credit balance reports earlier in the cycle to allow sufficient processing time. We will implement automated reporting to identify credit balances that occur after the end of an academic period. These reports will be sent to a shared bursar office email account rather than an individual staff member. This will ensure visibility and actionability even during staff absences, turnover, or non-workdays. Responsibility for monitoring and processing Title IV credit balances will be formally documented. Multiple staff members will be trained in the procedures to ensure appropriate backup coverage during employee absences, leave, or staffing transitions. Management will periodically review refund timelines to confirm adherence to procedures and verify that credit balances are disbursed within regulatory timeframes. We believe these corrective actions address the audit recommendation and will ensure timely and consistent processing of Title IV credit balance disbursements regardless of staffing availability.Name of contact person: Jennifer Mertz is the Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: All of the control strengthening mechanisms and documentation will be complete by June 30, 2026.

View Audit 389449

Corrective Action Plans

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