Corrective Action Plans

Finding 562303 (2024-009)

Significant Deficiency 2024

MD

HUD Housing Programs Eligibility Significant Deficiency § 200.303

Finding 2024-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 Home Investment Partnership Program Significant Deficiency in Internal Controls and Noncompliance over Eligibility Repeat Finding: No Auditee’s Corrective Action Plan: The agency concurs with and accepts these find...

Finding 2024-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 Home Investment Partnership Program Significant Deficiency in Internal Controls and Noncompliance over Eligibility Repeat Finding: No Auditee’s Corrective Action Plan: The agency concurs with and accepts these findings. Our grantees are aware of HOME record keeping requirements and are reminded of these requirements annually in the text of our file inspection compliance notifications. The management of the cited properties will be given a formal letter making them aware of the findings of this audit and reminded of HOME Investment Partnership Program record keeping requirements. We will also add the record keeping reminder to our Annual Desk Review notification. We will ensure that 100% of active HOME properties receive the record keeping requirements reminder, not just properties that receive file inspections. Additionally, the one file missing support documentation will be selected as a part of that property’s annual file inspection in 2025. We will also instruct the property that failed to submit its requested tenant file to continue searching for the file. The file in question is for a former tenant and was maintained by the previous management company. DHCD will reach out to the former management company to see if they can assist in the search. Contact Person: Eugene Greene, Operations Officer, Baltimore City DHCD – Development Division Completion Date: Effective immediately.

View Audit 357839

Finding 562213 (2024-001)

None 2024

Falcon Housing Corporation 023-Ee-122

MA

HUD Housing Programs Subrecipient Monitoring Eligibility

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensur...

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all current and new staff are trained on tenants’ 90-day EIV reports and ensuring they are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments. ACTION TAKEN The Project will be monitoring use of the EIV system for move ins and recertifications.

View Audit 357820

Finding 562088 (2024-001)

Material Weakness 2024

Genesee County, Michigan

MI

Eligibility Subrecipient Monitoring Material Weakness § 200.303

Condition: During testing, it was noted that although there was a process in place to review eligibility criteria received by program, there was not an independent review or control to ensure eligibility was accurate. Planned Corrective Action: After the initial review for eligibility, a second empl...

Condition: During testing, it was noted that although there was a process in place to review eligibility criteria received by program, there was not an independent review or control to ensure eligibility was accurate. Planned Corrective Action: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review. This was implemented in September of 2024. Contact person responsible for corrective action: Lucy Rosenberg and Michelle Estell Anticipated Completion Date: 09/01/2024

View Audit 357726

Finding 562079 (2024-101)

Material Weakness 2024

Cochise County

AZ

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Cochise County WIC leadership and staff is committed to full adherence with WIC policy and will continue to implement training, monitoring, and communication to ensure compliance with federal and state regulation. The County immediately corrected this issue by conducting a mandatory training sessio...

Cochise County WIC leadership and staff is committed to full adherence with WIC policy and will continue to implement training, monitoring, and communication to ensure compliance with federal and state regulation. The County immediately corrected this issue by conducting a mandatory training session for all WIC staff regarding the Rights and Obligations policy. During this session, the policy was read aloud and distributed in written form to all attendees. Staff were directed to inform all participants of their rights and responsibilities to include having the rights and responsibilities form signed by the participants, prior to issuing benefits, during the participant’s initial certification, and recertifications for ongoing benefits. Staff received the Rights and Obligations Pledge for review and reference. Procedures for obtaining signatures from participants not physically present in the office were reviewed. Acceptable alternatives include sending the form via email for electronic or physical signature, scheduling a follow-up in-office visit for signature collection. All staff questions were addressed to ensure clarity and consistent understanding. Ongoing reminders have been disseminated through emails and during regular staff “huddles” since the training. In addition to the immediate actions taken to correct the finding, the County also implemented long-term action steps. These steps include annual training of all WIC Staff on the Rights and Obligations policy the 2nd Monday of January. Each employee will sign an attestation confirming their understanding and compliance post-training. This attestation will be stored in the employee’s personnel record. Monthly, the WIC Manager, or designee, will review the WIC Cert. for Audit Report the last Friday of each month to identify and address any instances of missing client signatures. Additionally, the WIC Manager will manually audit 3% of the total WIC members for the month. Continuous actions implemented by County staff to correct this finding includes consistent reinforcement of signature collection protocols and policy reminders during monthly meetings and weekly “huddles”. Of note, a request was submitted to the Arizona WIC Service Desk to determine whether a report could be generated identifying all participants lacking a signed Rights and Obligations form to strengthen monitoring efforts. The response received indicated that generating this type of report is extremely complex, and at this time it is not possible.

View Audit 357695 Questioned Costs: $1

Finding 562061 (2024-002)

Significant Deficiency 2024

Roosevelt University

IL

Questioned Costs Special Tests & Provisions Student Financial Aid

University awarded Subsidized Federal Direct Loans to one student in excess of their Subsidized Federal Direct Loan eligibility, and therefore did not comply with all requirements associated with excess loan proceeds. Corrective Actions Taken or Planned: This finding is considered an isolated occurr...

University awarded Subsidized Federal Direct Loans to one student in excess of their Subsidized Federal Direct Loan eligibility, and therefore did not comply with all requirements associated with excess loan proceeds. Corrective Actions Taken or Planned: This finding is considered an isolated occurrence and is not indicative of Roosevelt University’s standard administrative practices or institutional policies. The University has taken the following corrective actions to address the issue and prevent recurrence Student Account Adjustment: A reallocation of $2,900 from the Federal Direct Subsidized Loan to the Federal Direct Unsubsidized Loan was completed to correct the student’s account. All necessary updates were submitted to the U.S. Department of Education on May 16, 2025. Root Cause Analysis and System Improvements: The University will conduct a thorough root cause analysis to determine the underlying factors that led to the overaward. This analysis will be completed within 30 days. Preventative Measure and On-going Monitoring: Based upon the outcome of the root cause analysis, Roosevelt will implement appropriate system controls and develop an on-going monitoring plan to prevent similar issues in the future. These preventative measures will be established within 45 days. Roosevelt University remains committed to maintaining compliance with federal regulations and to continuously strengthening its internal controls to ensure accurate administration of Title IV funds. Anticipated Completion Date: July 15, 2025 Contact Person: Michelle Hayes, Senior Director, Financial Aid and Compliance // Michelle Stipp, Associate Vice President, Enrollment Management

View Audit 357660 Questioned Costs: $1

Finding 562039 (2024-002)

None 2024

Stanford University

CA

Student Financial Aid Eligibility Reporting

– Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numb...

– Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Number: 84.033 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Stanford agrees with this finding and will be taking proactive steps to ensure that similar issues do not arise in the future. For the issue affecting 6 out of 25 students, whose status change effective dates did not match their program level information, the Academic Records and Compliance Officer will work closely with systems staff to perform tests to identify a cause and ensure accuracy between the enrollment file extract and records themselves. Expected completion by December 31, 2025. For the issue affecting 2 out of 25 students, whose graduated status was not accurately reflected in their enrollment history, the Academic Records and Compliance Officer is leading a system enhancement currently in progress to replace the ‘G from DV’ file to a ‘Grads Only’ file to report degrees, which is expected to be completed by December 31, 2025. The new and improved file type will ensure the third-party servicer applies graduated statuses for students enrolled in multiple programs. Until the system enhancement is completed, the Academic Records and Compliance Officer will begin carefully reviewing ‘G Not Applied’ error files for manual correction after degrees are reported at the end of each quarter.

View Audit 357625

Finding 562030 (2024-001)

Significant Deficiency 2024

Fife School District No.417

WA

School Nutrition Programs Subrecipient Monitoring Cash Management

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of Fife School District contact person: Dany Wanner, Business Services Director 1720 Oa...

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of Fife School District contact person: Dany Wanner, Business Services Director 1720 Oak St, Milton, WA 98354 (253) 517-1000 ext 29121 Corrective action the auditee plans to take in response to the finding: The Fife School District implemented the following to Ensure Adequate Internal Controls for Compliance with Federal Eligibility: The Business Services team and Nutrition Services staff have conducted a thorough review of the process of monthly paid lunch equity and modified its procedures including developing a checklist for the process to ensure that it is completed in a timely manner, signed/dated and saved both electronically and in hard copy on a shared district server folder. The Fife School District implemented the following to Ensure Adequate Internal Controls for the annual completion of the Paid Lunch Equity Tool. The Business Services team and Nutrition Services staff have conducted a thorough review of the process of completing both the PLE tool and GL 828 reconciliation and modified its procedures to ensure that it is completed, signed and saved both electronically and in hard copy on a shared district server folder. Further, the Business Services team and Nutrition Services staff have developed a checklist for the completion of the tool and the checking of the box that indicates that we will be opting not to increase meal prices, but instead to demonstrate using the GL 828 Reconciliation (signed and dated) that we have sufficient fund balance to offset the paid lunches and not utilize Federal funds, including calendar reminders and a shared Google Drive to hold all related documents and procedures. Anticipated date to complete the corrective action: 5/16/2025

View Audit 357621

Finding 561967 (2024-001)

Significant Deficiency 2024

Orting School District No. 344

WA

School Nutrition Programs Subrecipient Monitoring Cash Management

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of District contact person: Marci Bannan, Director of Business Services 121 Whitesell S...

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of District contact person: Marci Bannan, Director of Business Services 121 Whitesell St NE Orting, WA 98360 Corrective action the auditee plans to take in response to the finding: Eligibility: The District will document the internal controls that are in place for the monthly direct certification downloads and will print the certification download along with saving it electronically so that the files are easy to provide for future audits. Paid Lunch Equity: The District will document the internal controls that are in place for the completion of the PLE tool and ensure that the form is completed appropriately to show the continued use of nonfederal funds that are used yearly to fund the food service account fully. The District will also make sure to ‘print’ the GL 828 tab of the Fund Balance Reporting tool that is done yearly no later than November and sign it immediately after completion of the year end process to provide for the proof that the district has and continues to contribute sufficient nonfederal funds to the food service account. Anticipated date to complete the corrective action: July 31, 2025

View Audit 357586

Finding 561884 (2024-001)

Material Weakness 2024

Careerwise New York, Inc.

NY

Eligibility

CareerWise will implement enhanced internal control procedures to ensure that all eligibility documentation, including selfattestation forms verifying date of birth, is consistently collected, signed, and retained in each apprentice's case file. These procedures will include standardized checklists,...

CareerWise will implement enhanced internal control procedures to ensure that all eligibility documentation, including selfattestation forms verifying date of birth, is consistently collected, signed, and retained in each apprentice's case file. These procedures will include standardized checklists, mandatory document review prior to disbursement, and staff training to reinforce compliance expectations. Additionally, CareerWise will conduct a comprehensive review of all case files under the ABA grant to identify and remedy any gaps in eligibility documentation. This retrospective review will be completed as part of the corrective action plan. All corrective actions, including implementation of the updated documentation process and the full case file review, will be completed on or before December 31, 2025.

View Audit 357542

Finding 561695 (2024-001)

Significant Deficiency 2024

Seattle Indian Health Board

WA

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Planned Corrective Action: The Seattle Indian Health Board has adopted a sliding fee program that provides discounts to eligible patients and Indian tribes. To address the auditors' concerns and further strengthen our internal controls, we are implementing a comprehensive corrective action plan. Fir...

Planned Corrective Action: The Seattle Indian Health Board has adopted a sliding fee program that provides discounts to eligible patients and Indian tribes. To address the auditors' concerns and further strengthen our internal controls, we are implementing a comprehensive corrective action plan. Firstly, we will ensure that all personnel involved in eligibility checks, including front desk staff and benefits specialists, are fully trained and aware of federal regulations and internal policies. This will be achieved through comprehensive training sessions and the development of a detailed training manual outlining eligibility criteria, documentation requirements, and procedural steps. Periodic refresher training sessions will reinforce adherence to these policies. Secondly, we will establish a robust internal audit system to regularly review and verify compliance with eligibility requirements. This includes integrating a monthly audit of eligibility determinations into the month-end reporting process, conducted by the clinical operations team. The clinical operations team will use a standardized checklist during these audits to ensure consistency and thoroughness. They will document findings and follow up on any issues or discrepancies with the relevant personnel to ensure timely corrections and adherence to procedures. Management believes that we have adequate internal control systems to safeguard the organization's assets and comply with federal and local regulations. However, we remain committed to further strengthening our controls and processes where necessary. Name of Responsible Party: Mary Kelley, Director of Revenue Cycle Anticipated Completion Date: September 30, 2025

View Audit 357322

Finding 561677 (2024-002)

Significant Deficiency 2024

Jericho Road Ministries D/b/a Jericho Road Community Health Center

NY

Eligibility

Previously, all sliding fee scale applications were reviewed and processed by the billing manager. Effective September 10, 2024, the Center assigned a specific billing specialist (Stephanie Rivera Rivera) to process the sliding fee scale applications. Billing managers’ responsibilities now include a...

Previously, all sliding fee scale applications were reviewed and processed by the billing manager. Effective September 10, 2024, the Center assigned a specific billing specialist (Stephanie Rivera Rivera) to process the sliding fee scale applications. Billing managers’ responsibilities now include auditing the applications that are processed by the billing specialist. The auditing process completed by the billing manager, Yeny Roggie, is to ensure that the application is complete and that the proper sliding fee scale was offered to the patient.

View Audit 357305

Finding 561625 (2024-001)

Significant Deficiency 2024

Legal Aid of Wyoming, Inc.

WY

Eligibility Significant Deficiency

Corrective Actions: Implement a Pre-Closure Checklist for every client file to ensure a signed retainer is present. Train all administrative and legal staff on document retention policies. Require all supervisors to review and initial the checklist before a case is marked complete. Monitoring Plan: ...

Corrective Actions: Implement a Pre-Closure Checklist for every client file to ensure a signed retainer is present. Train all administrative and legal staff on document retention policies. Require all supervisors to review and initial the checklist before a case is marked complete. Monitoring Plan: Quarterly audits of 10% of closed cases; reports to Executive Direcotr and included in board compliance summary.

View Audit 357233

Finding 561573 (2024-001)

None 2024

Springdale Housing, Phase Ii, Inc.

NC

Questioned Costs Eligibility HUD Housing Programs

Management agrees with the finding. Corrections have been made to the tenant file. A refund has been processed.

View Audit 357198 Questioned Costs: $1

Finding 561572 (2024-001)

Significant Deficiency 2024

Beaufort Housing Authority

SC

HUD Housing Programs Subrecipient Monitoring Eligibility

2024-001 ALN 14.871 – Section 8 Housing Choice Vouchers Program - Eligibility The Executive Director agrees with the finding as listed in the Schedule of Findings and Responses and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ethan M. James, Boar...

2024-001 ALN 14.871 – Section 8 Housing Choice Vouchers Program - Eligibility The Executive Director agrees with the finding as listed in the Schedule of Findings and Responses and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ethan M. James, Board Chairman & Julie A. Davis, Executive Director Projected Completion Date: September 30, 2024

View Audit 357195

Finding 561571 (2024-001)

None 2024

Olde Town Village Housing, Inc.

NC

Questioned Costs Eligibility HUD Housing Programs

Management agrees with the finding. Corrections have been made to the tenant file and a refund was processed for the tenant.

View Audit 357191 Questioned Costs: $1

Finding 561570 (2024-001)

None 2024

Senior Citizens Housing Development Corporation of South Boston, Inc.

FL

HUD Housing Programs Eligibility Reporting

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of South Boston, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Driv...

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of South Boston, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: January 1, 2024 through December 31, 2024 The finding from the December 31, 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2024-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should implement procedures to ensure that all initial and ongoing tenant eligibility documentation is obtained timely and maintained in tenant files as required by HUD. Action Taken: The Project has implemented additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding the plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips Irene Phillips CFO

View Audit 357175

Finding 561558 (2024-001)

Significant Deficiency 2024

Sunset Park Health Council, Inc. Dba Family Health Centers at Nyu Lang

NY

Eligibility

Finding 2024-001: Community Health Worker Training Program Eligibility Federal Agency: Department of Health and Human Services Program: Community Health Worker Training Program Assistance Listing #: 93.516 May 27, 2025 ________________________________________ Management Response: Sunset Park Healt...

Finding 2024-001: Community Health Worker Training Program Eligibility Federal Agency: Department of Health and Human Services Program: Community Health Worker Training Program Assistance Listing #: 93.516 May 27, 2025 ________________________________________ Management Response: Sunset Park Health Council Inc. acknowledges the audit finding related to the lack of documented verification for eligibility criterion (2)—proof of U.S. citizenship or permanent residency—for participants in the Community Health Worker Training Program (CHWTP) for the year ended August 31, 2024. While management initially performed a verbal verification, management subsequently began a retroactive verification to obtain documentation supporting that all trainees met eligibility criteria. We also recognize the need for a formalized control process to ensure documentation of compliance at the point of enrollment is maintained.________________________________________ Corrective Action Plan: To prevent recurrence of this issue, the following steps will be implemented: 1. Revised Intake Process A standardized intake form will be implemented and must be completed at the time of screening by the FHC Program Supervisor in collaboration with the participant. This form will: o Attest that all required eligibility documents have been collected, including proof of U.S. citizenship or permanent residency (criterion 2). o Include a checklist for all documentation required for program participation. o Require three signatures: - Participant - FHC Program Supervisor (who conducted the screening and verified eligibility documentation) - Program Director (PD) or Principal Investigator (PI), who will review and approve the documentation to confirm completeness. 2. Privacy and Data Security o All documentation will be redacted to block any sensitive Personally Identifiable Information (PII) to prevent potential identity theft. o Documents will be digitally archived in a secured, access-controlled location with appropriate cybersecurity protocols in place. 3. Training and Oversight o All staff involved in intake and eligibility verification will receive training on the updated intake process, documentation standards, and data privacy requirements. o A quarterly internal review will be conducted by the Program Director to ensure continued compliance.________________________________________ Timeline for Implementation: Sunset Park plans to begin the above actions in May of 2025 and complete implementation in August 2025. Responsible Individual Leonardo Arias - Director of Grants Email : Leonardo.Arias@nyulangone.org

View Audit 357169

Finding 561513 (2024-001)

Significant Deficiency 2024

Seattle School District No. 1

WA

School Nutrition Programs Allowable Costs / Cost Principles Eligibility

In response to this finding, the Culinary Services department under the guidance of the Operations team in SPS has made the following adjustments and changes to business practices: 1. The PLE tool has been formally integrated into the annual budgeting process to ensure routine compliance with this ...

In response to this finding, the Culinary Services department under the guidance of the Operations team in SPS has made the following adjustments and changes to business practices: 1. The PLE tool has been formally integrated into the annual budgeting process to ensure routine compliance with this guidance and accurate financial planning. 2. If a price increase is deemed necessary, it will undergo a thorough review and approval through the SPS board governance process. This will include a landscape review of meal prices in other districts in the Puget Sound region as well as similarly scaled districts nationally. This structured approach guarantees alignment with strategic objectives while maintaining transparency and accountability. 3. As of May 2025, the Culinary Services department under the direction of the Operations department will be taking action on a price increase for school lunches beginning for the 2025-26 school year with annual reviews scheduled for subsequent years.

View Audit 357117

Finding 561475 (2024-001)

Material Weakness 2024

North Mason School District No. 403

WA

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

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal Title I eligibility requirements. Name, address, and telephone of District contact person: Dan King 250 E Campus Dr. Belfair, WA 98528 (360) 277-2107 Corrective actio...

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal Title I eligibility requirements. Name, address, and telephone of District contact person: Dan King 250 E Campus Dr. Belfair, WA 98528 (360) 277-2107 Corrective action the auditee plans to take in response to the finding: The district is strengthening its internal controls for monitoring the Per Pupil Expenditure (PPE) to match higher poverty concentration in its schools by the following: 1. Developing and utilizing an Excel Spreadsheet as a “PPE Tool” to allocate funds appropriately a. The PPE Tool will be a shared working document between the Business Office, Human Resources, and Title I Coordinator, b. The PPE Tool will be utilized when applying for the 2025-2026 Consolidated Grant and all future Consolidated Grant applications; and, c. The PPE Tool will be used when completing budgetary reviews at cabinet meetings. These measures will be implemented going forward as internal controls for ensuring compliance with eligibility requirements for Title I funding. Anticipated date to complete the corrective action: Beginning July 2025 when the District will be completing the Consolidated Grant application in the Education Grants Management System (EGMS).

View Audit 357060

Finding 561289 (2024-003)

None 2024

Somers School District

MT

Subrecipient Monitoring Eligibility

FINDING 2024-003: Late Audit Submission (Repeated 2024-010) Response: The District will implement more timely actions to be taken.

View Audit 356929

Finding 561268 (2024-001)

Significant Deficiency 2024

White River Valley Electric Cooperative, INC

MO

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

Corrective Action Plan Assistance Listing Number 21.029 COVID-19 Coronavirus Capital Projects Fund U.S. Department of the Treasury Missouri Department of Economic Development Program Year 2024 Condition – The Cooperative was unable to provide evidence that vendors used in covered transactions wer...

Corrective Action Plan Assistance Listing Number 21.029 COVID-19 Coronavirus Capital Projects Fund U.S. Department of the Treasury Missouri Department of Economic Development Program Year 2024 Condition – The Cooperative was unable to provide evidence that vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Due to the current year finding, management set a goal to ensure the Missouri ARPA Broadband Infrastructure Grant Program guidelines related to debarred or suspended vendors are being met. To meet these guidelines management has compared the current vendor list to Excluded Parties List System found on SAM.GOV and found none of the currently used vendors on the list. Management has added this verification step to its new vendor process and will conduct annual self-assessment to ensure vendor eligibility documentation is current and up to date. Responsible Official: Jay Wallace, Manager of Accounting & Finance Implementation Date: April 25, 2025

View Audit 356890

Finding 561164 (2024-003)

Material Weakness 2024

Warren County Community Housing Agency, Inc.

IA

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

The Agency has attempted to segregate accounting duties by having a person who does not initiate, prepare or post disbursements review the bank statements and co-sign all checks. The Agency will continue to monitor its policies and procedures in an effort to improve control efficiencies, however, a...

The Agency has attempted to segregate accounting duties by having a person who does not initiate, prepare or post disbursements review the bank statements and co-sign all checks. The Agency will continue to monitor its policies and procedures in an effort to improve control efficiencies, however, at this time, the Agency has determined that the cost of eliminating this material weakness in internal control would exceed its benefit.

View Audit 356748

Finding 561163 (2024-001)

Significant Deficiency 2024

Warren County Housing Authority

IA

Internal Control / Segregation of Duties Special Tests & Provisions Eligibility

The Authority has attempted to segregate accounting duties by having a person who does not initiate, prepare or post disbursements review the bank statements and co-sign all checks. The Authority will continue to monitor its policies and procedures in an effort to improve control efficiencies, howe...

The Authority has attempted to segregate accounting duties by having a person who does not initiate, prepare or post disbursements review the bank statements and co-sign all checks. The Authority will continue to monitor its policies and procedures in an effort to improve control efficiencies, however, at this time, the Authority has determined that the cost of eliminating the deficiency would exceed its benefit.

View Audit 356747

Finding 561005 (2024-001)

Significant Deficiency 2024

Brigham Young University - Hawaii

HI

Student Financial Aid Reporting Eligibility

MANAGEMENT’S VIEWS AND CORRECTIVE ACTION PLAN For the year ended December 31, 2024 Finding 2024-001 - Non-Compliance with Accurate Student Enrollment Change Submissions to the National Student Loan Data System (Significant Deficiency) Grantor: U.S. Department of Education Program: Student Fina...

MANAGEMENT’S VIEWS AND CORRECTIVE ACTION PLAN For the year ended December 31, 2024 Finding 2024-001 - Non-Compliance with Accurate Student Enrollment Change Submissions to the National Student Loan Data System (Significant Deficiency) Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #: 84.268, 84.063 Award Titles: Federal Direct Student Loan Program, Federal Pell Grant Program Award Years: 7/2023 – 6/2025 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan: Due to non-compliance with timely and accurate student enrollment change submissions to the National Student Loan Data System (NSLDS), Brigham Young University – Hawaii (BYUH) Management proposes the following corrective action plan to mitigate reporting errors. The Registrar’s Office, in coordination with BYUH’s Enterprise Information Systems team, will review and enhance the processes used to extract student data from PeopleSoft and transmit it to the National Student Clearinghouse (NSC) and NSLDS. This includes: -Reviewing all relevant PeopleSoft updates and ensuring that corresponding changes are reflected in the data transmitted to NSLDS. -Testing and validating the reporting processes within PeopleSoft to confirm data accuracy and completeness. -Verifying that the correct data is being transmitted to NSLDS. -Testing the student data within NSLDS to ensure its integrity. -Documenting the entire process for future reference and ongoing quality assurance. In addition, the Registrar’s office has already added additional resources to run all reporting processes. The Registrar’s office has also reached out to Ensign College to learn about their reporting process. The University is considering contacting the PeopleSoft reporting specialist that Ensign used, although that decision will be made at a later date, and if necessary. These actions will enable the Registrar’s Office to more effectively review credit load determinations and accurately establish program begin dates for students. Daryl Whitford, Registrar, will remain responsible for enrollment reporting at BYUH. She will oversee the implementation of the revised process, provide training to all relevant staff members, and lead the development and implementation of a control mechanism to ensurefuture compliance with NSLDS reporting requirements within PeopleSoft. Timing: Daryl Whitford, Registrar, will be responsible for overseeing that all items noted in the corrective action plan will be implemented by September 1, 2025. Signed and Acknowledged Daryl Whitford, BYUH Registrar

View Audit 356635

Finding 560858 (2024-002)

None 2024

Ensign College

UT

Questioned Costs Eligibility Student Financial Aid

Management Views and Corrective Action Plan Year Ending December 31, 2024 Finding 2024-002 – Non-Compliance with Financial Need Requirements for Subsidized Direct Loans Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268 Award T...

Management Views and Corrective Action Plan Year Ending December 31, 2024 Finding 2024-002 – Non-Compliance with Financial Need Requirements for Subsidized Direct Loans Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.268 Award Titles: Federal Direct Student Loan Program Award Years: 7/2023 – 6/2026 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan The incomplete installation of a student information system (PeopleSoft) update resulted in certain EFCs not prorating correctly. The incomplete system update that created this issue has been corrected. Moving forward, all PeopleSoft updates will be reviewed upon completion by Jesus Garcia, PeopleSoft project manager, to ensure all steps have been finalized as expected. Additionally, with the implementation of the 2024–25 FAFSA Simplification Act, prorated EFCs are no longer applicable. As such, this issue will not recur in future processing cycles. Timing The incomplete PeopleSoft update was corrected in March 2024. PeopleSoft updates are done every quarter and will be reviewed upon completion by Jesus Garcia. Because the 2024-25 FAFSA Simplification Act eliminated the use of prorated EFCs in this process there will be no further action taken. Sincerely, S. Christopher Reitz Director of Financial Services and Controller creitz@ensign.edu 801-524-8109

View Audit 356621 Questioned Costs: $1

Corrective Action Plans

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