Corrective Action Plans

Finding 1200538 (2025-034)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring

Finding Number: 2025-034 Finding: The Department of Children, Youth, and Families improperly charged $9,980 to the Child Care and Development Fund. Program: 93.575 – Child Care and Development Block Grant 93.575 – COVID-19 Child Care and Development Block Grant 93.596 – Child Care Mandatory and Matc...

Finding Number: 2025-034 Finding: The Department of Children, Youth, and Families improperly charged $9,980 to the Child Care and Development Fund. Program: 93.575 – Child Care and Development Block Grant 93.575 – COVID-19 Child Care and Development Block Grant 93.596 – Child Care Mandatory and Matching Funds of the Child Care and Development Fund Compliance Requirement: Eligibility Questioned Costs: $9,980 Status: Corrective action complete Corrective Action: The Department concurs that federal funds were incorrectly used for one client who should have been paid with state funds. As stated in the finding, all clients sampled for audit testing met the eligibility requirements for the Working Connections Child Care program, meaning they were deemed eligible for subsidy payment. However, one client that was determined to be eligible for state funding was paid with federal funds. This was the result of a system coding error in the Payment Allocation Model (PAM) process that led to the wrong source of funds being used for the client. In November 2025, the Department corrected the PAM coding to prevent further occurrences of this specific error. In February 2026, the Department: • Processed an accounting adjustment returning the federal funds that were paid by error to the Child Care and Development Fund grant. • Implemented a monthly quality assurance review process in collaboration with the Department of Social and Health Services where a sample of PAM allocations will be reviewed for accuracy. Prior Findings: None Completion Date: February 2026 Agency Contact: Stefanie Niemela External Audit Liaison (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 395688

Finding 1191960 (2025-026)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

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

Finding Number: 2025-026 Finding: The Department of Social and Health Services did not have adequate internal controls to ensure only eligible clients received cash benefits under the Refugee and Entrant Assistance program and improperly charged $4,440 to the program. Program: 93.566 – Refugee and E...

Finding Number: 2025-026 Finding: The Department of Social and Health Services did not have adequate internal controls to ensure only eligible clients received cash benefits under the Refugee and Entrant Assistance program and improperly charged $4,440 to the program. Program: 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs Compliance Requirement: Eligibility Questioned Costs: $4,440 Status: Corrective action in progress Corrective Action: The Department concurs with the finding. As of October 2025, the Department requested the ESA Management Analytics and Performance Statistics (EMAPS) team to generate a report detailing all eligibility determinations made in the six weekly periods that were found to be lacking managerial review. As of November 2025, the Department submitted a formal EMAPS work request to develop a Refugee Cash Assistance (RCA) flagged eligibility caseload report. In addition to metrics already reviewed, this report includes a metric to flag cases where the “U.S. entry date” field has been modified. As of January 2026, the Department: • Developed, documented, and implemented a comprehensive process for managerial reviews of flagged eligibility caseload reports, including a backup process in the absence of the primary reviewer. • Developed and implemented a formal oversight process to monitor the completion and documentation of managerial reviews of all flagged eligibility caseload reports. This process will include a recurring check or log to ensure 100% compliance. • Revised the existing RCA desk aid to provide additional training and guidance to eligibility staff, clarifying the appropriate determination of the RCA eligibility period. The desk aid will specifically include instructions that staff are not to change the original date entered in the “U.S. entry date” field when a client leaves and reenters the country. As of March 2026, the Department reviewed the EMAPS reports to identify and correct any eligibility determination errors. By April 2026, the Department will develop and implement a tracking method to ensure all appropriate eligibility staff are trained on the revised RCA desk aid to ensure alignment with policy and procedures. If the grantor contacts the Department regarding the questioned costs identified in this finding, the Department will consult with the grantor to determine whether repayment is required. Prior Findings: None Completion Date: Estimated April 2026 Agency Contact: Richard Meyer External Audit Compliance Manager Richard.Meyer@dshs.wa.gov

View Audit 395688

Finding 1191853 (2025-012)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Eligibility Special Tests & Provisions

Finding Number: 2025-012 Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it profiled all claimants under the Unemployment Insurance program to identify people likely to need reemployment services and ensure repor...

Finding Number: 2025-012 Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it profiled all claimants under the Unemployment Insurance program to identify people likely to need reemployment services and ensure reports are reviewed before submission to the federal government. Program: 17.225 – Unemployment Insurance Compliance Requirement: Special Tests and Provisions – UI Reemployment Programs: Worker Profiling and Reemployment Services (WPRS) and Reemployment Services and Eligibility Assessments Questioned Costs: $0 Status: Corrective action in progress Corrective Action: In response to the finding and recommendations, the Department has taken the following actions: • In December 2025, reviewed the design of the Unemployment Tax and Benefits (UTAB) calculation and risk profile score and performed testing on its accuracy. • In January 2026: o Implemented additional internal controls to ensure claimants are profiled and prioritized for reemployment services based on their risk of exhausting unemployment benefits, in accordance with federal requirements. o Provided additional guidance to staff to ensure quarterly Employment and Training Administration (ETA) reports are completed accurately and submitted timely in accordance with ETA procedures. o Implemented a process to improve oversight in the reporting procedures to include adequate review and approval before submission to the grantor, and the proper retention of filed reports. The Department continues work to fully staff the unit and is working with the federal grantor and state partners regarding training and guidance on new accounting and reporting system changes. The Department partially concurs with the recommendation to reconcile the UTAB and Reemployment Appointment Scheduler (RAS) interface. There is currently a process in place to notify the RAS team if a record fails at the time of data transmission between UTAB and RAS. The Department is working on prioritizing resources to review the processes to verify that the complete UTAB exit file was successfully received by RAS. This work is anticipated to be completed in June 2026. Prior Findings: The conditions noted in this finding were previously reported in findings 2024-009 and 2023-010. Completion Date: Estimated June 2026 Agency Contact: Joshua Summers External Audit Manager (360) 529-6718 Joshua.Summers@esd.wa.gov

View Audit 395688

Finding 1191852 (2025-011)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Questioned Costs Allowable Costs / Cost Principles

Finding Number: 2025-011 Finding: The Employment Security Department did not have adequate internal controls over the 2208A reporting requirements for the Unemployment Insurance program. Program: 17.225 – Unemployment Insurance Compliance Requirement: Reporting Questioned Costs: $0 Status: Correctiv...

Finding Number: 2025-011 Finding: The Employment Security Department did not have adequate internal controls over the 2208A reporting requirements for the Unemployment Insurance program. Program: 17.225 – Unemployment Insurance Compliance Requirement: Reporting Questioned Costs: $0 Status: Corrective action complete Corrective Action: The Department notified our federal grantor when we became aware of the issue and submitted corrected reports for the periods in question. To improve internal controls, the Department: • Updated internal processes for reviewing reports and retaining all supporting documentation. • Implemented a new process to run a cumulative report to provide additional backup and to detect variances throughout the fiscal year. Prior Findings: None Completion Date: December 2025 Agency Contact: Joshua Summers External Audit Manager (360) 529-6718 Joshua.Summers@esd.wa.gov

View Audit 395688

Finding 1191848 (2025-008)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Allowable Costs / Cost Principles School Nutrition Programs Questioned Costs

Finding Number: 2025-008 Finding: The Department of Social and Health Services did not have adequate internal controls to ensure payments were allowable and made only to eligible beneficiaries for the Summer Electronic Benefits Transfer Program for Children. Program: 10.646 – Summer Electronic Benef...

Finding Number: 2025-008 Finding: The Department of Social and Health Services did not have adequate internal controls to ensure payments were allowable and made only to eligible beneficiaries for the Summer Electronic Benefits Transfer Program for Children. Program: 10.646 – Summer Electronic Benefits Transfer Program for Children Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Eligibility Questioned Costs: $55,454 Status: Corrective action in progress Corrective Action: The Department concurs with the finding. The improper payments identified by the auditors resulted from the challenges of a new program in its first year of implementation. Errors occurred when users from the Department and the Office of Superintendent of Public Instruction migrated data onto new templates and inadvertently included ineligible students and inaccurate dates of birth. The Department agrees that thorough data validation prior to issuance of benefits would have better identified systemic issues related to age and enrollment. Upon discovery, the Department promptly removed ineligible issuances to limit the state’s liability. The Department does not process overpayments on spent benefits based on 7 CFR 292.27(c)(2): “To the maximum extent practicable, Summer EBT agencies should limit claims against households to situations where there is evidence that the household knowingly obtained benefits through fraudulent activities.” In addition, the approved state plan with the federal grantor included a provision that the Department will not process overpayments for improper benefits unless there is evidence of fraud. By April 2026, the Department’s Community Services Division (CSD) will: • Implement a review process to verify age of applicants and address questionable data before submission to the contractor. • Amend the contract with the contractor to include specific reporting requirements for duplicate issuances and identification of ineligible participants. By July 2026, the Department’s CSD will: • Implement a mandatory data reconciliation process in which the contractor must provide full participant datasets, including dates of birth and eligibility status, to the CSD for review and approval prior to benefit issuance. • Request the contractor to complete an enhancement to its eligibility determination system to automatically flag participants under age one or over age 22 for further review. • Request the Electronic Benefits Transfer vendor to create a standard monthly report to show expenditures and expired benefits by client. If the grantor contacts the Department regarding the questioned costs identified in this finding, the Department will consult with the grantor to determine whether repayment is required. Prior Findings: None Completion Date: Estimated July 2026 Agency Contact: Richard Meyer External Audit Compliance Manager Richard.Meyer@dshs.wa.gov

View Audit 395688

Finding 1191816 (2025-001)

Material Weakness 2025

Lincoln University

MO

Student Financial Aid Questioned Costs Eligibility

The Office of Student Financial Services acknowledges the finding and will implement corrective actions to ensure full compliance regarding Year-Round Pell Grant eligibility. To address the issue, enhanced processes and internal controls will be established to ensure all eligible students are accura...

The Office of Student Financial Services acknowledges the finding and will implement corrective actions to ensure full compliance regarding Year-Round Pell Grant eligibility. To address the issue, enhanced processes and internal controls will be established to ensure all eligible students are accurately identified for Summer Pell Grant disbursements. The Office of Student Financial Services will implement enhanced procedures to ensure all eligible students are properly identified for Year-Round Pell Grant awards. Each term, a review report will be generated to identify summer enrollees who received Pell Grant funding during the fall and/or spring terms. Financial aid staff will assess eligibility prior to disbursement by verifying enrollment intensity, cost of attendance, and remaining annual Pell eligibility. Written procedures will be updated to require a Pell eligibility review before processing any summer disbursements. The Director of Financial Aid will review the report each term to monitor compliance with these procedures.

View Audit 395639

Finding 1191808 (2025-003)

Material Weakness 2025

Capstone Community Action, Inc.

VT

Eligibility Questioned Costs Subrecipient Monitoring

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-003 Compliance Finding - Eligibility Views of Responsible Officials Management a...

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-003 Compliance Finding - Eligibility Views of Responsible Officials Management acknowledges the eligibility determination error involving a two-unit dwelling and agrees that eligibility verification procedures were not sufficiently applied in accordance with DOE requirements for multiunit properties. The Organization takes this finding seriously and is committed to strengthening controls to prevent recurrence. The Organization is actively working with the pass-through entity to resolve the questioned costs of $4,048.39 and will repay any disallowed costs as required. Corrective Action Plan 1. Multi-Unit Eligibility Control Protocol A new Multi-Unit Eligibility Determination Checklist has been implemented requiring: • Individual income verification for each unit • Calculation worksheet demonstrating compliance with: o 66% rule, OR o 50% rule (where applicable), OR o HUD categorical eligibility per WPN 22-5 • Written supervisory approval prior to job authorization No multi-unit property may proceed to audit or production until eligibility documentation is approved. 2. Pre-Service Supervisory Approval Requirement • All multi-unit eligibility determinations must be reviewed and signed by: o Will Eberle (Weatherization Director) • Documentation must be verified before work order issuance. This adds a preventive control prior to expenditure of funds. 3. Executive Oversight Review • Will Eberle (Weatherization Director) will receive a monthly eligibility compliance report. • Any exceptions will trigger immediate review. • Quarterly summary reporting will be presented to senior leadership. 4. Targeted Eligibility Training • Staff will complete focused training on: o DOE WAP multi-family eligibility requirements o Income documentation standards o HUD categorical eligibility • Training will be conducted within 45 days and annually thereafter. • Attendance logs and materials will be maintained by Scott Hall. 5. File Audit & Continuous Monitoring • Will Eberle (Weatherization Director) will conduct monthly random sampling of: o 100% of multi-unit approvals for the next 6 months o Minimum 20% thereafter • Findings will be documented and tracked. 6. Resolution of Questioned Costs • The Organization is in communication with the pass-through entity regarding the $4,048.39 in questioned costs. • Repayment will occur promptly if required. • A repayment tracking file will be maintained by finance and reviewed by Chris Locarno. Implementation Timeline Summary Action, Responsible Party, Completion Target: Multi-unit checklist implemented, Scott Hall, Completed Supervisory sign-off requirement, Scott Hall, Immediate Staff eligibility training, Scott Hall, Within 45 days Executive reporting framework, Chris Locarno Completed Monthly sampling audits, Will Eberle, Ongoig Resolution of questioned costs WX Finance / Chris Locarno, Within 90 days Statement of Commitment The Organization is committed to restoring and maintaining full compliance with all federal and state Weatherization program requirements. Leadership, including, but not limited to: Will Eberle (Weatherization Director), Scott Hall (Weatherization Associate Director), and Chris Locarno (Business Manager), has implemented structural safeguards, enhanced supervisory review, and reinforced a culture of compliance and accountability to ensure that these deficiencies do not recur. Management believes the corrective actions outlined above address both the immediate deficiencies and the underlying control weaknesses identified in the audit. Responsible Person: Will Eberle Date of Completion: April 1, 2026

View Audit 395614

Finding 1191798 (2025-001)

Material Weakness 2025

Capstone Community Action, Inc.

VT

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-001 Compliance Finding - Special Tests and Provisions Material Weakness in Inter...

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-001 Compliance Finding - Special Tests and Provisions Material Weakness in Internal Control Over Compliance Views of Responsible Officials Management acknowledges the deficiency identified in the Quality Control Inspection (QCI) process. While questioned costs were not identified, we recognize that the breakdown in controls represents a material weakness requiring immediate and sustained corrective action. Since the Office of Economic Opportunity (OEO) monitoring review, the Organization has undergone structural and cultural changes within the Weatherization Department. Leadership has taken decisive steps to reinforce compliance expectations, supervisory accountability, and documentation integrity. Corrective Action Plan 1. Immediate Structural Oversight Enhancement • Will Eberle (Weatherization Director) is designated as the primary responsible official for QCI program compliance. • Scott Hall (Weatherization Associate Director and Quality Control Lead) is responsible for direct oversight of all QCI staff and inspection standards. • Chris Locarno (Business Manager) will provide executive-level oversight and ensure crossdepartmental accountability and reporting to senior leadership and the Board. Effective immediately: • No weatherization unit may be reported or invoiced until: o QCI documentation is fully complete, o All required test results (blower door, combustion safety, final inspection) are included, o Client signature is present, o Secondary supervisory review is completed. 2. Secondary File Review Control A new Two-Tier Review Process has been implemented: Tier 1 - QCI Review (Performed by Certified BPI QCI) • Full compliance with Vermont Weatherization Program Standards • Documentation of all required final tests • Verification that QCI was not performed by supervising crew members or project participant Tier 2 - Supervisory File Review • Conducted by Scott Hall • Random sampling at minimum 25% of completed units monthly • Monthly summary report submitted to Will Eberle • Quarterly compliance summary reviewed with Chris Locarno No unit will be considered production-complete until Tier 2 review confirms documentation sufficiency. 3. Mandatory QCI Refresher Training • All QC I-certified staff will complete refresher training on: o DOE and HHS requirements o Vermont Weatherization Program Standards o Documentation standards o Independence requirements • Training will occur semi-annually at minimum. • Scott Hall will document attendance and maintain training logs. • Chris Locarno will verify annual compliance training completion as part of management review. Additionally, peer case reviews will be incorporated quarterly to reinforce quality standards. 4. Cultural and Performance Accountability • QCI compliance metrics will be incorporated into staff performance evaluations. • Repeated documentation failures will result in retraining or removal of QCI approval authority. • Monthly compliance meetings led by Scott Hall will include trend review and corrective tracking. 5. Monitoring & Reporting Timeline Action Two-tier review implemented, Will Eberle, Completed Refresher training session, Scott Hall, Within 60 Days Executive compliance review structure , Chris Locarno, Completed Quarterly internal audit sampling, Scott Hall / Will Eberle, Ongoing Responsible Person: Scott Hall Date of Completion: April 1, 2026

View Audit 395614

Finding 1191789 (2025-003)

Material Weakness 2025

Bloom Vernon Local School District

OH

Cash Management Eligibility Reporting

The District will add in another level of review to ensure that meals reported to DEW agree to the point-of-sale system CN-6 and CN-7 reports.

View Audit 395609

Finding 1191631 (2025-003)

Material Weakness 2025

Aleutian Pribilof Islands Association, Inc.

AK

Questioned Costs Eligibility Material Weakness

Finding 2025-003: Material Weakness in Internal Control over Compliance and Noncompliance – Eligibility Program: 64.055 Staff Sergeant Parker Gordon Fox Suicide Prevention Grant Program Planned Corrective Action: To address the identified material weakness and ensure future compliance with SSG Fox S...

Finding 2025-003: Material Weakness in Internal Control over Compliance and Noncompliance – Eligibility Program: 64.055 Staff Sergeant Parker Gordon Fox Suicide Prevention Grant Program Planned Corrective Action: To address the identified material weakness and ensure future compliance with SSG Fox SPGP eligibility and documentation requirements, the organization has implemented the following systemic enhancements: • Standardized Eligibility Controls: The organization has developed and deployed a mandatory Case File Compliance Checklist for all program participants. This control ensures that all federally mandated documentation—including signed program agreements, grievance procedures, religious protections, individualized service plans, and all five required baseline mental health screenings—is present and verified for every file. • Enhanced Management Oversight: To ensure the effectiveness of these controls, the Department Director has implemented a Monthly Quality Assurance (QA) Review. On a monthly basis, the Director will perform a formal audit of active case files to verify compliance. This review will be documented via a formal sign-off, providing a clear audit trail of supervisory oversight. • Records Retention & Security: Management oversight has been expanded to include specific verification of Data Integrity and Retention. Monthly reviews will ensure that all required documentation is maintained in accordance with 2 CFR § 200 standards—ensuring records are secure, unalterable, and readily accessible for future audits. • Continuous Professional Development: The organization has institutionalized a Mandatory Training Curriculum. All relevant staff will undergo initial onboarding and recurring periodic training focused on SSG Fox SPGP compliance standards, participant eligibility, and rigorous documentation procedures. • Personnel Realignment: The organization has undergone a restructuring of the program staff to ensure that all personnel are fully aligned with the agency's internal control environment and commitment to federal compliance. Anticipated completion date: April 30, 2026 Contact Information: Louise Chikigak, Chief Financial Officer, (907) 222-4250

View Audit 395488

Finding 1191584 (2025-001)

Material Weakness 2025

Clinica Msr. Oscar A. Romero

CA

Eligibility

Management is reviewing and strengthening the Sliding Fee Discount Program (SFDP) to ensure compliance with regulatory and internal requirements. Corrective actions focus on clarifying income verification and documentation standards, enhancing staff training, and implementing periodic monitoring to ...

Management is reviewing and strengthening the Sliding Fee Discount Program (SFDP) to ensure compliance with regulatory and internal requirements. Corrective actions focus on clarifying income verification and documentation standards, enhancing staff training, and implementing periodic monitoring to ensure consistent application of the sliding fee scale. As part of these efforts, Clinica Romero conducted a robust and targeted staff training through the CMOAR Clinical & Administrative Operations Training on February 21 and February 28, 2026. The training included 74 staff members and covered SFDP eligibility, income verification, documentation requirements, and proper application of discounts in alignment with HRSA Program Requirement. Expected outcomes include improved consistency in SFDP application across departments, increased staff understanding of compliance requirements, fewer incomplete or unsupported applications, and stronger documentation and audit readiness. Clinica will monitor closely and supervise the perfect execution of the sliding fee scale application, and it will set accountability standards for the application of the sliding fee scale.

View Audit 395451

Finding 1191554 (2025-008)

Material Weakness 2025

Leech Lake Tribal College

AZ

Questioned Costs Student Financial Aid Eligibility

Annual performance reports will be submitted on time as required by the funding agency. Management has developed a comprehensive listing of all reporting requirements and will utilize this information to ensure all reporting requirements are met.

View Audit 395432

Finding 1191552 (2025-007)

Material Weakness 2025

Leech Lake Tribal College

AZ

Questioned Costs Student Financial Aid Eligibility

Management will provide additional resources to the Financial Aid department to include training and assistance and will implement verification procedures to ensure that amounts awarded are accurate.

View Audit 395432

Finding 1191504 (2025-001)

Material Weakness 2025

Housing Authority of the City of Annapolis

MD

HUD Housing Programs Special Tests & Provisions Eligibility

Corrective Action Plan: The Authority acknowledges the finding. Corrective actions to address the deficiencies are underway and include: Updating internal policies and procedures related to Housing Choice Voucher (HCV) program compliance, including tenant eligibility, income verification, rent reaso...

Corrective Action Plan: The Authority acknowledges the finding. Corrective actions to address the deficiencies are underway and include: Updating internal policies and procedures related to Housing Choice Voucher (HCV) program compliance, including tenant eligibility, income verification, rent reasonableness, utility allowance calculations, and documentation requirements; Providing targeted staff training on HUD HCV program requirements, including proper file documentation, income calculation, and timely completion of annual and interim recertifications; Implementing a mandatory file checklist to ensure all required documentation is obtained, reviewed, and verified prior to finalizing tenant certifications and rent determinations; Establishing a formal quality control process in which supervisory staff perform periodic file reviews to ensure compliance with HUD requirements and internal policies; Conducting a comprehensive review and cleanup of all HCV tenant files to identify and correct missing or incomplete documentation, including income verification, inspections, and rent calculations; Maintaining an audit trail of all verification documentation to ensure proper retention and support for tenant eligibility and rent determinations; Implementing tracking tools and system reports to monitor recertification due dates, inspection schedules, and file completion status to ensure timely compliance; Continuing engagement with third-party service provider, Quadel, to assist with tenant file documentation compliance, backlog recertifications, and rent calculation accuracy; Hiring and/or assigning additional staff, including HCV program leadership and specialists, to strengthen oversight, ensure timely processing of recertifications, and maintain compliance with HUD requirements.

View Audit 395422

Finding 1191472 (2025-004)

Material Weakness 2025

Montcalm Community College

MI

Student Financial Aid Questioned Costs Eligibility

Cost of Attendance Calculation Inputs Auditor Description of Condition and Effect. During our testing of the College’s cost of attendance (COA) calculations, we identified inconsistencies between the COA component amounts recorded in the system and the amounts documented on the College’s COA calcula...

Cost of Attendance Calculation Inputs Auditor Description of Condition and Effect. During our testing of the College’s cost of attendance (COA) calculations, we identified inconsistencies between the COA component amounts recorded in the system and the amounts documented on the College’s COA calculation sheet. For instance, the College's tuition component was supposed to be based on credit intensity, but instead was being calculated using the student's enrollment status (e.g., full-time, half-time, etc.). Additionally, the College included direct loan fees in every students COA, even if they were not a direct loan receiving student. As a result, COA amounts used in awarding Title IV aid were being understated, preventing some students from potentially receiving additional aid they were entitled to. Auditor Recommendation. We recommend that the College establish and adhere to review procedures to ensure that all inputs used in the COA calculation are accurate, complete, and consistent with approved documentation. Corrective Action. Management is actively enhancing the College’s Cost of Attendance (COA) processes to ensure all inputs—particularly tuition, loan fees, and enrollment‑related components—accurately reflect approved documentation and federal requirements. The Financial Aid Office has reconfigured PowerFAIDS to calculate tuition based on credit intensity rather than enrollment status, and loan fees are now included only for students who actually borrow federal loans. An annual COA governance and approval process is now in place, requiring review and authorization by the Vice President of Finance and Administration before COA figures are built into the system. All COA entries in PowerFAIDS undergo an independent verification against the approved COA worksheet as part of a “build‑to‑proof” procedure. Spot checks are conducted at the start of each term to ensure accuracy across enrollment levels, and all mid‑year changes are documented using a formal change‑control log. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. March 31, 2026

View Audit 395393

Finding 1191462 (2025-002)

Material Weakness 2025

Montcalm Community College

MI

Eligibility Questioned Costs Student Financial Aid

Ineligible Student Received Title IV Funding Auditor Description of Condition and Effect. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed...

Ineligible Student Received Title IV Funding Auditor Description of Condition and Effect. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed both attempted courses. Despite the lack of demonstrated academic improvement following the appeal, the student was awarded Title IV funding in the Spring 2024–2025 semester based on the appeal granted during the 2022–2023 academic year. As a result of this condition, one student received Title IV funding that who was not eligible based on the criteria outlined in the College's satisfactory academic policy (SAP). Auditor Recommendation. We recommend the College implement a formal review process to verify that students who were previously dismissed and granted an appeal in a prior academic year have demonstrated the required academic improvement before receiving subsequent Title IV funding, or alternatively, obtain a new appeal determination. Corrective Action. Management acknowledges this finding and is implementing strengthened Satisfactory Academic Progress (SAP) review procedures to ensure students who previously appealed an academic dismissal are properly evaluated before receiving Title IV funding. The Financial Aid Office is now working closely with the Registrar to ensure both Title‑IV and non‑Title‑IV students undergo appropriate SAP monitoring. Information Technology is developing a report that identifies students by financial‑aid track status, allowing Financial Aid to review aid‑receiving students while the Registrar evaluates all others. Students who require SAP follow‑up are contacted by the appropriate office, and SAP appeal forms are reviewed under updated criteria to ensure students demonstrate academic improvement before additional aid is awarded. These steps ensure the College remains compliant with federal SAP requirements and prevents ineligible students from receiving Title IV funds. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026

View Audit 395393

Finding 1191337 (2025-004)

Material Weakness 2025

Langston University

OK

Questioned Costs Eligibility Significant Deficiency § 200.303

Student Financial Aid Cluster: TEACH Grant – Assistance Listing No. 84.379 Recommendation: We recommend the University review and update current procedures to ensure that students meet eligibility requirements prior to receiving the TEACH Grant. Explanation of disagreement with audit finding: There ...

Student Financial Aid Cluster: TEACH Grant – Assistance Listing No. 84.379 Recommendation: We recommend the University review and update current procedures to ensure that students meet eligibility requirements prior to receiving the TEACH Grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated procedures to ensure verification of student GPA prior to disbursement of TEACH Grant funding. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid and Ms. Courtney Youngblood, Assistant Director of Financial Aid Planned completion date for corrective action plan: September 2025

View Audit 395389

Finding 1191224 (2025-003)

Material Weakness 2025

University of Pikeville

KY

Student Financial Aid Eligibility

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.165(a). Condition: During our eligibility testing, 10 of 38 students who received Direct Loans were...

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.165(a). Condition: During our eligibility testing, 10 of 38 students who received Direct Loans were not notified of their disbursements timely by the University. Cause: The University did not have controls in place to ensure students were being notified of Direct Loan disbursements in a timely manner (within 30 days before or 30 days after crediting the students' account). Effect: The provisions of 34 CFR 668.165(a) were not followed and thus a total of 10 students were not notified of Direct Loan disbursements in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University update their internal controls related to Direct Loan disbursements and send required communications prior to crediting the students' accounts. Corrective Actions Taken or Planned: We agree with this finding and recommendation. The financial aid office has automated the process to send disbursement notifications. Disbursement notifications are sent the day after loans are posted to a student’s account. Responsible Parties: Daniel Donner, Director of Financial Aid Completion Date: November 05, 2025

View Audit 395369

Finding 1191202 (2025-001)

Material Weakness 2025

Concordia University Chicago

IL

Questioned Costs Student Financial Aid Eligibility

2025-001 Pell Grant Under Award Recommendation: We recommend the University implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit ...

2025-001 Pell Grant Under Award Recommendation: We recommend the University implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The Office of Financial Aid will continue to run monthly or bi-monthly enrollment reports for Pell Grant recipients to ensure awards are accurately determined based on enrollment status. 2) Financial Aid Counselors will continue to review the daily and weekly Hour Change Reports for each payment period to ensure Pell Grant awards are adjusted appropriately in response to enrollment status changes. 3) The Director and Assistant Director of Financial Aid will continue providing Banner (student information system) training to staff to ensure Pell Grant amounts are updated accurately within the system. Name(s) of the contact person(s) responsible for corrective action: Vanesa Teran-Martinez, Jennifer Monroy Planned completion date for corrective action plan: June 30, 2026

View Audit 395330

Finding 1191131 (2025-001)

Material Weakness 2025

San Fernando Community Hospital D/b/a San Fernando Chc

CA

Special Tests & Provisions Eligibility

Corrective Action: Imperial Beach Community Clinic will immediately take steps to correct processes and workflows to meet future year Sliding Fee documentation requirements. In conjunction, the Revenue Cycle team including the CFO and Billing Manager will work with the Patient Services Manager to pu...

Corrective Action: Imperial Beach Community Clinic will immediately take steps to correct processes and workflows to meet future year Sliding Fee documentation requirements. In conjunction, the Revenue Cycle team including the CFO and Billing Manager will work with the Patient Services Manager to put together training for all Staff in Patient Services and Revenue Cycle on all issues identified. Training will encompass program requirements and proper identification and implementation of the sliding fee program. The team will also institute monthly Sliding Fee Chart Audits to assess staff knowledge, provide feeback and offer guidance to all staff.

View Audit 395309

Finding 1191103 (2025-016)

Material Weakness 2025

State of Connecticut Drinking Water Fund - State Revolving Fund

CT

Eligibility Questioned Costs Special Tests & Provisions

Recommendation: The Department of Social Services should provide the necessary resources and institute procedures to ensure that it uses all information from eligibility, income, and death matches to ensure that it correctly issues benefits to or on behalf of eligible clients. DSS should return fede...

Recommendation: The Department of Social Services should provide the necessary resources and institute procedures to ensure that it uses all information from eligibility, income, and death matches to ensure that it correctly issues benefits to or on behalf of eligible clients. DSS should return federal reimbursements for unallowable expenditures claimed under Medicaid and SNAP. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding. DSS staff is in the development phase of implementing new automated procedures to ensure timely and accurate action is taken to discontinue benefits of deceased clients when date of death information is received and matched to the Connecticut Department of Public Health’s State Vital Records Office. Action has been taken to correct the errors cited, including discontinuing the benefits of the individuals that were verified as deceased, and recouping the overpayments as appropriate. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Dan Giacomi, Program Division Director (860) 424-5080

View Audit 395257

Finding 1191098 (2025-011)

Material Weakness 2025

State of Connecticut Drinking Water Fund - State Revolving Fund

CT

Eligibility Questioned Costs Cash Management § 200.303

Recommendation: The Department of Social Services should strengthen internal controls to ensure that only eligible recipients receive Medicaid services in accordance with federal laws and the Medicaid State Plan. Corrective Action Plan as Reported by the Department of Social Services: The Department...

Recommendation: The Department of Social Services should strengthen internal controls to ensure that only eligible recipients receive Medicaid services in accordance with federal laws and the Medicaid State Plan. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding. The Department identified cases where overrides that were applied during the public health emergency were not removed. This resulted in individuals remaining enrolled inappropriately. Our Business Systems Division is implementing a tiered resolution approach, beginning with individuals enrolled in the Medicare Savings Program and HUSKY-C coverage. Please note: The Department will not be returning the questioned costs associated with this finding. According to federal regulations, recoveries based on eligibility errors can only be pursued when identified by programs operating under CMS’ Payment Error Rate Measurement program, per section 1903(u) of the Social Security Act and regulations at Title 42 CFR Part 431, Subpart Q. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Dan Giacomi, Program Division Director (860) 424-5080

View Audit 395257

Finding 1191085 (2025-025)

Material Weakness 2025

State of Connecticut Drinking Water Fund - State Revolving Fund

CT

Eligibility Internal Control / Segregation of Duties Questioned Costs § 200.303 § 200.403

Recommendation: The Department of Social Services should strengthen internal controls to ensure that only eligible recipients receive Money Follows the Person Rebalancing Demonstration services in accordance with federal laws, award terms and conditions, and the Money Follows the Person Operational ...

Recommendation: The Department of Social Services should strengthen internal controls to ensure that only eligible recipients receive Money Follows the Person Rebalancing Demonstration services in accordance with federal laws, award terms and conditions, and the Money Follows the Person Operational Protocol. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees in part with this finding. Condition #1: DSS agrees that participation end dates were not updated timely due to cross-system manual entry limitations. Reconciliation procedures and supervisory oversight will be strengthened. Condition #2: DSS agrees that participation suspensions were not consistently reflected across systems due to timing delays. Monitoring and real-time reconciliation controls will be enhanced. Condition #3: DSS agrees approved costs exceeded institutional thresholds in limited cases. Variances were clinically justified, reviewed, and authorized. DSS will strengthen documentation and internal protocols to ensure clearer policy alignment. Condition #4: DSS agrees that the documentation was incomplete in one instance. Internal review standards will be reinforced to ensure comparative cost analyses are consistently documented. Please note, the Department will not be returning the questioned costs associated with this finding. According to federal regulations, recoveries based on eligibility errors can only be pursued when identified by programs operating under Centers for Medicare and Medicaid Services’ (CMS) Payment Error Rate Measurement program, per section 1903(u) of the Social Security Act and regulations at Title 42 CFR Part 431, Subpart Q. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Christine Weston, Program Division Director (860) 424-5012

View Audit 395257

Finding 1191067 (2025-029)

Material Weakness 2025

State of Connecticut Drinking Water Fund - State Revolving Fund

CT

Eligibility Questioned Costs Cash Management

Recommendation: The Department of Social Services should strengthen internal controls to ensure that each Children’s Health Insurance Program recipient is eligible for the program according to the state plan and federal regulations. Corrective Action Plan as Reported by the Department of Social Serv...

Recommendation: The Department of Social Services should strengthen internal controls to ensure that each Children’s Health Insurance Program recipient is eligible for the program according to the state plan and federal regulations. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with this finding. Condition #1: This was a processing error and was independently addressed. Condition #2: The findings were for cases that were granted prior to the implementation of the Department’s manual review process, which includes updating third-party information in the Health Insurance Exchange (HIX) system after verifying policy information. This process was officially started in May 2025. It is a post-enrollment function since it is permissible for clients to self-attest to having third-party liability (TPL) at the time of application. We expect to see a reduction in this type of error in future audits. There is an inevitable delay in DSS being notified of any discrepancies with TPL details due to the timing of that information being updated from carriers and then provided to DSS. With our new process, we can close these cases as soon as that information is available to us. Condition #3: There are multiple root causes related to this finding, including Premium Payment Module file transaction issues, reversing system functionality that was temporarily implemented during the COVID-19 Public Health Emergency which resulted in lingering enrollment issues, and staff processing errors. DSS regularly reviews age-out cases to take the necessary actions to close. Please note, the Department will not be returning the questioned costs associated with this finding. According to federal regulations, recoveries based on eligibility errors can only be pursued when identified by programs operating under Centers for Medicare and Medicaid Services’ (CMS) Payment Error Rate Measurement program, per section 1903(u) of the Social Security Act and regulations at Title 42 CFR Part 431, Subpart Q. Anticipated Completion Date: December 31, 2026 Department of Social Services Contact Person: Dan Giacomi, Program Division Director (860) 424-5080

View Audit 395257

Finding 1191058 (2025-022)

Material Weakness 2025

State of Connecticut Drinking Water Fund - State Revolving Fund

CT

Eligibility Questioned Costs Special Tests & Provisions

Recommendation: The Department of Social Services should strengthen internal controls over sanctions to ensure compliance with Temporary Assistance for Needy Families child support enforcement requirements. Corrective Action Plan as Reported by the Department of Social Services: The Department agree...

Recommendation: The Department of Social Services should strengthen internal controls over sanctions to ensure compliance with Temporary Assistance for Needy Families child support enforcement requirements. Corrective Action Plan as Reported by the Department of Social Services: The Department agrees with the finding. DSS Economic Security and Office of Child Support Services implemented a new child support non-cooperation referral process on November 25, 2025. It is task based, assures an accurate and complete universe of sanction notices for child support non-cooperation are provided, and assures staff process and document all required sanctions. Anticipated Completion Date: November 25, 2025 Department of Social Services Contact Person: Tricia Morelli, Program Administrative Manager (860) 424-5519

View Audit 395257

Corrective Action Plans

Filters