Corrective Action Plans

Finding 1179746 (2025-048)

Material Weakness 2025

State of Nebraska

NE

Questioned Costs Eligibility Internal Control / Segregation of Duties

Program: AL 93.778 – Grants to States for Medicaid – Allowability & Eligibility Corrective Action Plan: The Agency has standard processes and procedures for processing renewals timely and updating budgets to reflect changes that have occurred within a household; however, worker errors resulted in th...

Program: AL 93.778 – Grants to States for Medicaid – Allowability & Eligibility Corrective Action Plan: The Agency has standard processes and procedures for processing renewals timely and updating budgets to reflect changes that have occurred within a household; however, worker errors resulted in these conditions. The Agency will ensure established standard processes are followed. Additionally, user guides and training materials will be reviewed and updated if deemed necessary for clarity. Individual staff who made the errors will be followed up with to ensure they understand the policies. Contact: Tiffanie Green Anticipated Completion Date: June 30, 2026

View Audit 392165

Finding 1179745 (2025-047)

Material Weakness 2025

State of Nebraska

NE

Questioned Costs Allowable Costs / Cost Principles Eligibility

Program: AL 93.778 – Grants to States for Medicaid – Allowability Corrective Action Plan: DHHS and Medicaid and Long-Term Care (MLTC) have been actively implementing procedures and controls to ensure that payments are allowable, adequately supported, and in accordance with State and Federal regulati...

Program: AL 93.778 – Grants to States for Medicaid – Allowability Corrective Action Plan: DHHS and Medicaid and Long-Term Care (MLTC) have been actively implementing procedures and controls to ensure that payments are allowable, adequately supported, and in accordance with State and Federal regulations. As noted in the early management letter, the findings and conditions are consistent with findings from prior year(s) audits. As a result, the department had already taken significant actions throughout State Fiscal Year 2025 to implement several procedures and controls which are expected to mitigate the majority of the conditions observed in the audit. Specifically, in late February 2025, MLTC implemented systematic controls to require that GPS/IVR visit verification and recipient signature is captured for visits to be submitted for claim payment. Additional changes included tightening down, or reducing, the radius of the geofence area for location verification. Additionally, in late June 2025, the department implemented additional, significant procedures and controls which include the requirement of all PAS and Home and Community Based caregivers and providers obtain and use their unique National Provider Identifier (NPI) on all visits and claims for visits to be submitted for claim payment, new systematic controls that do not allow for unreasonable billing of units/hours in a day on both a client and caregiver level, and new controls that parse the client authorizations into weekly segments which create limits for the number of hours/units per week that can be billed for services for a client, based on the authorized amounts in the client assessment. DHHS and MLTC will continue to monitor data and claims and identify and evaluate opportunities to implement additional controls and procedures that ensure payments for these services are allowable and in accordance with State and Federal regulations. In addition to the changes in MLTC, the following actions are being implemented by Child and Family Services (CFS). CFS will collaborate with the Nebraska State Patrol to develop an automated process to compare the addresses of foster parents with the Sex Offender Registry on a quarterly basis to ensure that no registered sex offenders reside at the same household address as a ward of the state. Additionally, Agency-Supported Foster Care contracts and Relative/Kinship Caregiver Agreements will be amended to include a requirement that caregivers report all criminal citations, charges, convictions, and any individuals who have moved into the home within five (5) business days to CFS. Finally, Foster Care Regulations require background checks for all individuals in the foster home who are 18 years of age and older. There are certain crimes that make a person ineligible to provide foster care, while other criminal convictions fall under the discretionary category. To ensure consistency, CFS has centralized the review and approval of discretionary convictions that are not subject to mandatory exclusion. Contact: Jeremy Brunssen, MLTC Kathleen Stolz, CFS Anticipated Completion Date: 6/30/2026 (ongoing)

View Audit 392165

Finding 1179725 (2025-038)

Material Weakness 2025

State of Nebraska

NE

Matching / Level of Effort / Earmarking Questioned Costs Eligibility

Program: AL 93.575 and 93.596 – CCDF Cluster – Allowability & Eligibility & Matching Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will ...

Program: AL 93.575 and 93.596 – CCDF Cluster – Allowability & Eligibility & Matching Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will be completed to identify enhancements to this area. The Agency will develop a new fraud prevention process for the Resource Development team to enhance controls over attendance, billing, and the auditing of provider claims, and to ensure compliance. A Provider Probation process will be implemented to address identified billing concerns. The Agency will evaluate current regulations and requirements surrounding provider rate increases related to the Step Up to Quality provider rate enhancements and develop a process to address concerns with exceeding private pay rates. Contact: Nicole Vint Anticipated Completion Date: September 30, 2026

View Audit 392165

Finding 1179724 (2025-040)

Material Weakness 2025

State of Nebraska

NE

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

Program: AL 93.575 – COVID-19 Child Care and Development Block Grant – Allowability Corrective Action Plan: In 2025, The Agency developed a subrecipient monitoring tool to ensure effective controls and processes are in place. The Agency will review all findings and take appropriate actions when warr...

Program: AL 93.575 – COVID-19 Child Care and Development Block Grant – Allowability Corrective Action Plan: In 2025, The Agency developed a subrecipient monitoring tool to ensure effective controls and processes are in place. The Agency will review all findings and take appropriate actions when warranted. Contact: Nicole Vint Anticipated Completion Date: June 30, 2026

View Audit 392165

Finding 1179711 (2025-031)

Material Weakness 2025

State of Nebraska

NE

Eligibility Questioned Costs Matching / Level of Effort / Earmarking

Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs – Allowability & Eligibility Corrective Action Plan: The Refugee Resettlement Program has requested eligibility system changes to prevent eligibility errors. In addition, the Refugee Resettlement Pro...

Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs – Allowability & Eligibility Corrective Action Plan: The Refugee Resettlement Program has requested eligibility system changes to prevent eligibility errors. In addition, the Refugee Resettlement Program performs monthly reviews of RMA enrollees and will coordinate case reviews with the RMA team to ensure comprehensive case review. Retraining of eligibility staff will occur as needed. Contact: Sara Bockelman Anticipated Completion Date: April 30, 2026

View Audit 392165

Finding 1179677 (2025-002)

Material Weakness 2025

Granville County, North Carolina

NC

Eligibility Internal Control / Segregation of Duties Questioned Costs

For the Year Ended June 30, 2025 Corrective Action Plan Finding 2025-002 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed completion date: Corrective actions for Finding 2025-005 also apply to State Award findings. Section IV - State Award Findings and Questioned Cost...

For the Year Ended June 30, 2025 Corrective Action Plan Finding 2025-002 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed completion date: Corrective actions for Finding 2025-005 also apply to State Award findings. Section IV - State Award Findings and Questioned Costs Taylor White and Michelle Ogle - Medicaid Supervisors Family and Children Leadership Training: On October 29, 2025, staff received training on self-employment income calculations, including guidance on interpreting tax forms. This training ensures caseworkers correctly document and budget income in the case files going forward. Adult Medicaid Leadership Training: On June 6, 2025, Adult Medicaid leadership conducted SSI Ex Parte training to reinforce policy requirements and timeliness standards for processing program changes. A follow-up SSI training was also held on July 15, 2025, to emphasize the importance of timeliness and policy compliance. Policy and Process Improvement Training: On December 18, 2025, Family and Children Leadership will conduct training on “Noncompliance with Program Requirements and Inadequate Requests,” focusing on online verification review procedures, appropriate notice requirements for undocumented aliens, and appropriate policy sections. This session will include time management training and the implementation of a timeliness checklist to improve case processing efficiency. Adult Medicaid Policy Training: By December 31, 2025, Adult Medicaid Leadership will conduct training covering appropriate policy sections including - Financial Resources verifications, income limit reduction rules, and Transfer of Assets verifications. Adult Medicaid caseworkers will also complete some online trainings and update the review documentation template to include the income limit reduction rules. These corrective actions are designed to strengthen staff knowledge of policy requirements, improve documentation accuracy, and ensure ongoing compliance with timeliness and program standards. All trainings and documentation updates will be completed by December 31, 2025. Section III - Federal Award Findings and Questioned Costs 159

View Audit 392096

Finding 1179621 (2025-002)

Material Weakness 2025

Sunshine Connections, Inc.

KS

Cash Management Eligibility Significant Deficiency

2025-002 – 10.558 – Child and Adult Care Food Program –Eligibility Condition Two providers received an improper amount for their meal reimbursement for the month tested. Recommendation Controls should be reviewed and updated to ensure that complete and accurate meal counts are submitted to the State...

2025-002 – 10.558 – Child and Adult Care Food Program –Eligibility Condition Two providers received an improper amount for their meal reimbursement for the month tested. Recommendation Controls should be reviewed and updated to ensure that complete and accurate meal counts are submitted to the State for reimbursement. Comments on the Finding Given Sunshine Connections, Inc.’s limited staffing structure, full segregation of duties within the meal claims process is not always possible. However, the organization has implemented practical internal controls to reduce the risk of errors and ensure accurate claims are submitted. All meal count and attendance records submitted are reviewed for completeness and accuracy before being entered into the claim system. Meal counts are checked against enrollment, attendance, and licensed capacity to ensure they are reasonable and allowable. Action Taken Whenever possible, someone other than the Director will prepare the monthly claim. The Director will then review the claim for accuracy and compare totals between the Excel spreadsheet and the Little Organizer program before submission to ensure the information is correct.

View Audit 392018

Finding 1179439 (2025-007)

Material Weakness 2025

Municipality of Naranjito

PR

Eligibility Significant Deficiency Internal Control / Segregation of Duties

COMMONWEALTH OF PUERTO RICO CORRECTIVE ACTION PLAN MUNICIPALITY OF NARANJITO FOR THE FISCAL YEAR ENDED JUNE 30, 2025 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit...

COMMONWEALTH OF PUERTO RICO CORRECTIVE ACTION PLAN MUNICIPALITY OF NARANJITO FOR THE FISCAL YEAR ENDED JUNE 30, 2025 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Orlando Ortíz Chevres - Mayor Contact Person: Mrs. Meyleen Hernández, Finance Director Phone: (787) 869 – 2200 Finding Reference Number: 2025-007 Federal Award: Child Care and Development Block Grant (ALN 93.575) Compliance Requirement: Eligibility (E) Type of Finding: Significant Deficiency (SD), Instance of Noncompliance (NC) Description of Finding: During our audit procedures, we evaluated four (4) participants files, and we found that two (2) of them do not have the Eligibility Certification. For that reason, we could not validate the eligibility of these participants. Auditor’s Recommendations: Management must implement internal control to ensure that the eligible participant is properly documented at the time of receiving services. Corrective Action: The Municipality will take steps to request the documentation again from the two participants for whom the corresponding eligibility certification was unavailable. In addition, instructions will be issued to ensure that all participants' eligibility documentation is reviewed periodically. Name of Contact Person: Responsible Person: Aracelis Fuentes Rodríguez, Child Care Center Director Completion Date: June 30, 2026

View Audit 391846

Finding 1179425 (2025-001)

Material Weakness 2025

Anson County

NC

Eligibility Internal Control / Segregation of Duties Questioned Costs

Anson County Finance Department 101 S. Greene Street, Suite 238 Wadesboro, NC 28170 None reported Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Corrective Actions for findings 2025-001 also apply to the State Award findings. Section IV- State Awa...

Anson County Finance Department 101 S. Greene Street, Suite 238 Wadesboro, NC 28170 None reported Name of Contact Person: Nia Broadway, Medicaid Manager Corrective Action: Proposed Completion Date: Corrective Actions for findings 2025-001 also apply to the State Award findings. Section IV- State Award Findings and Questioned Costs Section III - Federal Award Findings and Questioned Costs Corrective Action Plan 2/13/2026 Inadequate Request for Information Management will meet with staff on November 13, 2025, to discuss and train on findings from the Single County Audit All staff responsible for Single County Finding were placed on work plan related to the finding. For the next 60 days 50% of all Medicaid Staff work will have a complete Second Party and the findings will be discussed with the individual staff and training for all Staff based off the findings. For the Year Ended June 30, 2025 Section II - Financial Statement Findings Finding: 2025-001 124

View Audit 391837

Finding 1179424 (2025-001)

Material Weakness 2025

Franklin & Marshall College

PA

Student Financial Aid Subrecipient Monitoring Eligibility

The College will ensure the accuracy of reports sent to NSLDS by making changes to their staffing structure and roles surrounding student leave of absences and withdrawals. The College hired a single administrator who assists students through the process of requesting a leave of absence or a withdra...

The College will ensure the accuracy of reports sent to NSLDS by making changes to their staffing structure and roles surrounding student leave of absences and withdrawals. The College hired a single administrator who assists students through the process of requesting a leave of absence or a withdrawal and processes all leaves, making the system more efficient. The Office of Financial Aid will continue to process Return to Title IV calculations immediately when notified about a Title IV recipient’s leave of absence or withdrawal.

View Audit 391825

Finding 1179395 (2025-001)

Material Weakness 2025

Washington County

NC

Eligibility Internal Control / Segregation of Duties Questioned Costs

None reported. Finding: 2025-001 Inaccurate Resources Information Entry Name of Contact Person: Lynn Swett, Human Services Deputy Director Corrective Action: Proposed Completion Date: For the Year Ended June 30, 2025 Corrective Action Plan Section II. Financial Statement Findings Section III. Federa...

None reported. Finding: 2025-001 Inaccurate Resources Information Entry Name of Contact Person: Lynn Swett, Human Services Deputy Director Corrective Action: Proposed Completion Date: For the Year Ended June 30, 2025 Corrective Action Plan Section II. Financial Statement Findings Section III. Federal Award Findings and Questioned Costs Corrective Actions for Finding 2025-001 also apply to State Award Findings. Section IV - State Award Findings and Question Costs Staff were re-trained on effective date of change, and how to verify those dates are correct in NC FAST before the continuation of case processing, along with how to verify resources and the proper way to request information and what information is vital to case processing. Policy and procedures were used to ensure staff are trained appropriately. Second party reviews will continue to occur to ensure dates are correct in NC FAST, and second party reviews have increased to target 100% of all applications. The majority of cases found in error were in error prior to this training in December of 2024. Re-training occurs monthly during staff meetings to continue to improve outcomes. More difficult eligibility determination like those involving Special Needs Trust or Pooled Trust will be assigned to senior staff for processing and will immediately be second partied by the supervisor to ensure that resources and income are accounted for properly. Any noted discrepancies will be consulted with State Operation Support Team during processing of case. Second party reviews will continue to occur to ensure accuracy on information entered, including the use of resources. Trainings were completed by December 31, 2024, monthly staff meetings have been used to reinforce those training materials. 136

View Audit 391795

Finding 1179394 (2025-001)

Material Weakness 2025

Hyde County

NC

Eligibility Internal Control / Segregation of Duties Questioned Costs

None reported Name of Contact Person: Heather Owens - Medicaid Supervisor Corrective Action: Proposed Completion Date: Corrective actions for findings 2025-001 also apply to the State Awards findings. Section IV - State Award Findings and Questioned Costs All cases now undergo two separate superviso...

None reported Name of Contact Person: Heather Owens - Medicaid Supervisor Corrective Action: Proposed Completion Date: Corrective actions for findings 2025-001 also apply to the State Awards findings. Section IV - State Award Findings and Questioned Costs All cases now undergo two separate supervisory checks: One before the worker disposes of the case. A second check after disposal and worker sign-off to confirm that every identified correction was fully completed. This double-verification step was implemented immediately upon discovery of the issue. Each caseworker now receives a personalized checklist based on errors identified in their secondparty reviews. Workers must complete and submit this checklist at the time of review to acknowledge and address recurring issues. Immediate staff meetings were held to review audit findings and relevant policy. Additional training on correct income rules for recertifications is being developed (due to repeated findings). The supervisor has drafted the material, which will be submitted to State staff for review and approval. Training will be delivered to the entire team no later than the end of December 2025 (subject to State review timeline and holiday schedule). Weekly team meetings continue to cover Medicaid policy updates. Individual one-on-one meetings are held with each worker to review second-party errors, clarify policy, and provide coaching. A lead worker has been designated and is actively in training. The lead worker is already assisting with case staffing and troubleshooting while continuing to deepen her knowledge (particularly in the more complex Adult Medicaid program). Full lead-worker responsibilities are expected to be in place within the next six months. Second-party reviews now include checks of other active cases in the household or agency to ensure required changes are addressed and reported. This practice is reinforced with staff and monitored for compliance. The supervisor will complete a full review of pending COVID-related cases by the end of January 2026, followed by targeted team training on proper ongoing handling. All trainings and policy implementations will be completed by end of January 2026. Finding: 2025-001 Section III - Federal Award Findings and Questioned Costs Corrective Action Plan For Year Ended June 30, 2025 Section II - Financial Statement Findings 159

View Audit 391788

Finding 1179390 (2025-002)

Material Weakness 2025

Genesee Community College

NY

Student Financial Aid Questioned Costs Eligibility § 200.516

The College implemented additional procedures to allow earlier detection of fraud.

View Audit 391778

Finding 1179368 (2025-003)

Material Weakness 2025

Salem Community School Corporation

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2025-003 Finding Subject: Title I Grants to Local Educational Agencies – Eligibility Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the f...

FINDING 2025-003 Finding Subject: Title I Grants to Local Educational Agencies – Eligibility Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Due to continued turnover in the Title I administrator position, application details have not been mastered. The treasurer and current Title I administrator are continuing to learn the process through guidance from our DOE Title I specialist and what we have learned from this audit. We will continue to work together on applying for future Title I grants and for the necessary implementation of the current Title I grant. Internal control over the processes will be developed and implemented, and will be notated with a “reviewed by” signature and date. Anticipated Completion Date: 2/16/2026

View Audit 391728

Finding 1179366 (2025-002)

Material Weakness 2025

Pillar College and Subsidiaries

NJ

Student Financial Aid Reporting Eligibility

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Report training has been implemented and will continue on an ongoing basis to ensure compliance. We will implement periodic spot checks to prevent this issue from recurring and to ensure that all s...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Report training has been implemented and will continue on an ongoing basis to ensure compliance. We will implement periodic spot checks to prevent this issue from recurring and to ensure that all students are properly enrolled each semester. Person Responsible for Corrective Action Plan: Registrar, Elena Majerowicz Anticipated Date of Completion: Already Implemented

View Audit 391727

Finding 1179364 (2025-003)

Material Weakness 2025

Pillar College and Subsidiaries

NJ

Questioned Costs Student Financial Aid Eligibility

Need Analysis Planned Corrective Action: System-generated notifications have been implemented within our student information system to flag any academic year changes or required reviews. In addition, a periodic review process of student award packages has been established to ensure funds are awarded...

Need Analysis Planned Corrective Action: System-generated notifications have been implemented within our student information system to flag any academic year changes or required reviews. In addition, a periodic review process of student award packages has been established to ensure funds are awarded accurately and in accordance with applicable awards. Person Responsible for Corrective Action Plan: Giselle Atenco, Director of Financial Aid Anticipated Date of Completion: Already Implemented

View Audit 391727

Finding 1179163 (2025-003)

Material Weakness 2025

Southern California University of Health Sciences

CA

Questioned Costs Student Financial Aid Eligibility

Eligibility Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its procedures to ensure that title IV funds is awarded correctly. Explanation of disagreement with audit finding: There is no disagreement with...

Eligibility Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.033, 84.268, 84.007 Recommendation: We recommend the University review its procedures to ensure that title IV funds is awarded correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Pell Grant awards are reviewed prior to each disbursement. SCU has strengthened this control to ensure award amounts are adjusted to accurately reflect each student’s enrollment intensity at the time of disbursement. This review is documented and completed by the Director of Financial Aid before funds are released to ensure compliance with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Laney Morales, Director of Financial Aid Planned completion date for corrective action plan: 12/1/2025

View Audit 391545

Finding 1179046 (2025-003)

Material Weakness 2025

Maywood-Melrose Park-Broadview School District 89

IL

Questioned Costs Cash Management Eligibility § 200.402

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2025 Corrective Action Plan Finding No.: 2025- 003 Condition: It was noted during the audit that ineligible expenditures were charged to the food service expen...

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2025 Corrective Action Plan Finding No.: 2025- 003 Condition: It was noted during the audit that ineligible expenditures were charged to the food service expenditure function. These expenditures were for a back-to-school picnic and consisted of backpacks with school supplies that were provided to students, as well as a lunch provided to new teachers and staff. These expenditures should not have been charged to the food service function in the District’s general ledger system. Plan: The district is reviewing all expenditures monthly to ensure all of them are recorded with the proper account code. Any changes needed will get a journal entry through the Proviso Treasurer’s Office. The district has also identified the main vendors from which picnic supplies are purchased and stopped charging expenditures from these vendors to food service account codes. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Scott Wold, Business Manager

View Audit 391489

Finding 1177965 (2025-001)

Material Weakness 2025

County of Alpine

CA

Procurement, Suspension & Debarment Eligibility § 200.212 § 200.318

The County's current procedure requires documented acknowledgement that the vendor was verfied to not be suspended, debarred, or otherwise excluded prior to entering covered transactions. Effective February 25, 2026, the County's procedure will require documented verfication that vendors are not sus...

The County's current procedure requires documented acknowledgement that the vendor was verfied to not be suspended, debarred, or otherwise excluded prior to entering covered transactions. Effective February 25, 2026, the County's procedure will require documented verfication that vendors are not suspended, debarred, or otherwise excluded prior to entering into covered transactions and retain such documnetation within the procurement file, in accordance with CFR 200.212 and 200.318(h), 2 CFR 180.300, and 48 CFR 52.209-6.

View Audit 391401

Finding 1177956 (2025-001)

Material Weakness 2025

Morehouse College

GA

Student Financial Aid Eligibility

Corrective Action Plan Finding No. 2025-001 – Eligibility (Federal Work Study Program) Federal Program: Student Financial Assistance Cluster – Federal Work Study (ALN 84.033) Federal Agency: U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Finding Summary During testing of stu...

Corrective Action Plan Finding No. 2025-001 – Eligibility (Federal Work Study Program) Federal Program: Student Financial Assistance Cluster – Federal Work Study (ALN 84.033) Federal Agency: U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Finding Summary During testing of student eligibility, auditors identified one instance in which a student’s Cost of Attendance (COA) was increased by $2,810 due to participation in the Federal Work Study (FWS) program. Federal regulations do not permit an institution to increase COA solely to accommodate FWS eligibility. Although the adjustment did not result in the student receiving aid exceeding financial need, the adjustment occurred due to a misunderstanding of guidance related to the FWS program. Corrective Action Plan Management agrees with the finding. To address the finding and ensure compliance with federal regulations governing the Federal Work Study program, the Office of Financial Aid will implement the following corrective actions: 1. Policy Clarification and Documentation The Office of Financial Aid will revise its internal awarding policies and procedures to clearly state that the standard practice of awarding Federal Work Study funds must fit within the student established Cost of Attendance (COA). Additionally, the revised policy will explicitly include flexibility to increase the Cost of Attendance only because of approved Special Circumstance appeals, consistent with federal guidance and institutional professional judgment policies. Federal Student Aid Handbook: Application and Verification Guide: Chapter 5 – Special Cases 2. Award Adjustment Procedures When a student’s aid package exceeds need due to the addition of FWS, staff will take the following steps: • Reduction of loan awards, when applicable, to allow FWS funding to be added within the student’s financial need limits.A Loan Adjustment Form will be required for all downward adjustments to loan awards to ensure documentation and transparency. These procedures will ensure that aid adjustments remain compliant with federal need-analysis requirements. Implementation Timeline • Policy updates and procedural documentation: Within 60 days • Process implementation: Beginning with the 2026-2027 academic year packaging cycle

View Audit 391374

Finding 1177908 (2025-100)

Material Weakness 2025

Commonwealth of Virginia

VA

Questioned Costs Eligibility Significant Deficiency § 200.303

Responsible Person(s): Kavansa Gardner, Business Program Manager Senior, Benefit Programs; David Carico, Business Operations Manager Corrective Action Planned: Below is the narrative for CR901 and CR902 Records Retention, including current production deployment timelines. CR901 establishes the datab...

Responsible Person(s): Kavansa Gardner, Business Program Manager Senior, Benefit Programs; David Carico, Business Operations Manager Corrective Action Planned: Below is the narrative for CR901 and CR902 Records Retention, including current production deployment timelines. CR901 establishes the database infrastructure required to support compliant records retention within case management system. This includes partition creation across 75 plus high volume tables to enable structured aging and controlled purge activity aligned to retention thresholds. Production Deployment Timeline; scheduled as part of the February 2026 technical release. This phase is foundational and will be completed before purge logic can safely execute. CR902 Retention Logic and controlled execution; CR902 operationalizes the records retention policy by implementing controlled purge jobs leveraging the partitioning framework established in CR901. This Change Request moves the solution from infrastructure readiness to active lifecycle management. Phase 1 Database partition creation (February 2026 production release schedule) Phase 2 Controlled purge implementation (March 2026 release schedule) Phase 3 Validation, audit confirmation, and reporting controls (April 2026 release schedule) Phase 4 Reoccurring operational retention cycles with documented runbooks (ongoing/living) Estimated Completion Date: 4/30/2026

View Audit 391258

Finding 1177907 (2025-093)

Material Weakness 2025

Commonwealth of Virginia

VA

Questioned Costs Eligibility Significant Deficiency § 200.303

Responsible Person(s): Kavansa Gardner, Business Program Manager Senior, Benefit Programs; Lunita Browder-Harris, Business Operation Specialist, Business Operations Corrective Action Planned: DSS has identified critical or conflicting roles in the management system. The roles in scope have the capab...

Responsible Person(s): Kavansa Gardner, Business Program Manager Senior, Benefit Programs; Lunita Browder-Harris, Business Operation Specialist, Business Operations Corrective Action Planned: DSS has identified critical or conflicting roles in the management system. The roles in scope have the capability to perform all actions within the system, including inputting applications, determining eligibility, and authorizing benefits. DSS is in the process of implementing a procedure for reviewing and revoking conflicting roles ands privileges for all localities. DSS will work with APA to ensure adequate separation of duties is implemented within the eligibility system. Estimated Completion Date: 6/30/2026

View Audit 391258

Finding 1177889 (2025-021)

Material Weakness 2025

Commonwealth of Virginia

VA

Eligibility Matching / Level of Effort / Earmarking Questioned Costs § 200.516

Responsible Person(s): Meredith Lumpkin/J’Noie Parker, Child Care Subsidy Program Manager Corrective Action Planned: 1.) Process Redesign and Standardization: DSS has redefined the redetermination packet to require submission of the application and all required verifications to ensure complete docum...

Responsible Person(s): Meredith Lumpkin/J’Noie Parker, Child Care Subsidy Program Manager Corrective Action Planned: 1.) Process Redesign and Standardization: DSS has redefined the redetermination packet to require submission of the application and all required verifications to ensure complete documentation to streamline eligibility review. Updated procedural guidance has been incorporated into the Interim Guidance Manual to clarify verification requirements and documentation standards. A standardized step-by-step resource guide and redetermination flow chart have been developed outlining required actions, decision points, and the importance of reviewing redetermination monitoring reports on a monthly basis to ensure cases do not exceed eligibility periods. 2.) Immediate Remediation: In January, following the initial APA audit, DSS conducted a statewide scope and scale review of all active cases to identify outstanding redeterminations. Through this analysis, DSS identified 88 overdue redeterminations (31 from January 2026 and 57 from periods prior to January 2026). Local departments and appropriate staff were notified individually of the specific cases requiring action and directed to take corrective steps. DSS will review cases at the end of March to ensure action has been taken. Going forward, DSS will direct all local departments to review the monthly system-generated redetermination monitoring report and resolve any cases identified as exceeding the eligibility period. DSS will distribute targeted overdue case lists to Regional Program Consultants (RPCs) and monitor locality progress through centralized tracking to ensure timely eligibility determinations and ongoing CCDF compliance. 3.) Centralized Oversight: DSS will implement a layered oversight process to ensure compliance with required monthly monitoring procedures: -Regional-Level Review: Regional Program Consultants (RPCs) will review redetermination monitoring activity monthly within their assigned localities and direct corrective action as needed to ensure timely processing and case closure when appropriate. -Home Office Verification: DSS Home Office, in collaboration with DOE, will conduct quarterly reviews of regional monitoring activity to verify compliance and provide direction to RPCs where additional corrective action or technical assistance is required. This dual-level oversight structure establishes both ongoing regional monitoring and periodic centralized verification to reduce the risk of recurrence. 4.) Training: Refresher training will be provided to staff at our Benefits Program Conference in April, emphasizing timely processing, required verifications, system documentation standards, and ongoing monitoring responsibilities. Additionally, DSS is collaborating with the Local Training and Development team to initiate the development of a targeted refresher course for tenured staff to reinforce critical requirements, including the redetermination process. Monthly report review, as outlined in bullet two, will inform ongoing training updates to address. 5.) System Control Evaluation: DSS will collaborate with IT to assess potential system enhancements in future releases to strengthen controls related to redetermination due dates, including additional automated functionality or reporting capabilities. DSS will deliver to CCSP leadership, by June 30, 2026, a prioritized list of recommended system enhancements with associated cost estimates for review and consideration. Estimated Completion Date: 6/30/2026

View Audit 391258

Finding 1177843 (2025-066)

Material Weakness 2025

Commonwealth of Virginia

VA

Internal Control / Segregation of Duties Questioned Costs Eligibility § 200.303

Responsible Person(s): Office of Information Management and Othello Dixon, Office of Information Security Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 ...

Responsible Person(s): Office of Information Management and Othello Dixon, Office of Information Security Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Federal awarding agencies and pass-through entities, please see the Appendix titled “Applicable Management Contacts for Findings and Questioned Costs” to request the corrective action planned from the applicable entity. Estimated Completion Date: 3/2/2026

View Audit 391258

Finding 1177815 (2025-002)

Material Weakness 2025

Antioch College Corporation

OH

Student Financial Aid Eligibility Significant Deficiency

Finding 2025-002 - Significant Deficiency in Internal Control over Compliance - Student Financial Condition Found: One undergraduate student had aggregate subsidized loans over the aggregate limit. Corrective Action Plan: Previously, Antioch College utilized loan history data from Free Application f...

Finding 2025-002 - Significant Deficiency in Internal Control over Compliance - Student Financial Condition Found: One undergraduate student had aggregate subsidized loans over the aggregate limit. Corrective Action Plan: Previously, Antioch College utilized loan history data from Free Application for Federal Student Aid (FAFSA). FAFSA data was utilized because National Student Loan Data System (NSLDS) loan history data was not always available when Antioch College prepared financial aid award letters. Due to the potential loan history discrepancies between data reported via FAFSA versus NSLDS, at the start of each academic year, Antioch College now uses NSLDS data to update loan history of each student to ensure Antioch College has the correct loan balances for each student. This procedural change was put into effect with the start of the 2025-2026 academic year. Person Responsible for Corrective Action Plan Implementation: Director of Financial Aid

View Audit 391175

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