Corrective Action Plans

Finding 1202983 (2025-002)

Material Weakness 2025

IL

Internal Control / Segregation of Duties Cash Management Reporting § 200.303

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal co...

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Management Response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

View Audit 396260

Finding 1202970 (2025-001)

Material Weakness 2025

Ahoskie Housing Authority

NC

Eligibility HUD Housing Programs Reporting

Name of Contact Person: Tarsha Dudley, Executive Director. Corrective Action: Management will review the recertification process and plan to monitor recertifications. Proposed Completion Date: Immediately.

View Audit 396244

Finding 1202962 (2025-001)

Material Weakness 2025

Mid-Willamette Valley Community Action Agency, Inc.

OR

Reporting Internal Control / Segregation of Duties

The Agency will (1) clearly identify and communicate staff responsibilities for the preparation, review, and submission of required federal reports, (2) strengthen internal controls over reporting by implementing additional internal deadline reminders to ensure reports are completed and submitted pr...

The Agency will (1) clearly identify and communicate staff responsibilities for the preparation, review, and submission of required federal reports, (2) strengthen internal controls over reporting by implementing additional internal deadline reminders to ensure reports are completed and submitted prior to due dates, (3) establish procedures to monitor reporting deadlines based on applicable grant requirements and reporting periods, and (4) provide management oversight to confirm all required reports are reviewed, approved, and submitted timely. These actions are intended to address the delays in submitting required reports under the Head Start program and to help ensure ongoing compliance with federal reporting requirements.

View Audit 396230

Finding 1202959 (2025-003)

Material Weakness 2025

Felician University

NJ

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

2025-003 – Pell Under-Award Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that a review is implemented to ensure calculations of Pell awards are performed based on the accurate cost of attendance, SAI and enrollment status of the student. Explanation of disa...

2025-003 – Pell Under-Award Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that a review is implemented to ensure calculations of Pell awards are performed based on the accurate cost of attendance, SAI and enrollment status of the student. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the audit review, it was determined that student (ID: 0364337) was under-awarded a Federal Pell Grant due to a manual calculation error. Based on remaining Lifetime Eligibility Used (LEU), the student was eligible for $1,085 but was awarded $627.97. To address this finding, the institution has strengthened internal controls by eliminating manual calculations as a primary method for determining Pell eligibility, implementing a mandatory secondary review prior to disbursement, and requiring verification of LEU through the COD system. In addition, ongoing monthly quality assurance reviews have been established, and staff training has been completed to reinforce compliance with Pell Grant calculation requirements, including Cost of Attendance (COA), Student Aid Index (SAI), and enrollment status. Name(s) of the contact person(s) responsible for corrective action: Kathy Prieto -Executive Director Student Financial Services Planned completion date for corrective action: March 2026.

View Audit 396217

Finding 1202950 (2025-002)

Material Weakness 2025

MacCormac College Dba Generations College

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding 2025-002 Student Financial Aid Cluster, Assistance Listing # 84.063, 84.268 Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Corrective Action ...

Finding 2025-002 Student Financial Aid Cluster, Assistance Listing # 84.063, 84.268 Condition: The College did not send changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled changes to the NSLDS within 60 days of the change. Corrective Action Plan: Objective: To ensure the timely reporting of changes in attendance levels of students, including students who graduated, withdrew, dropped out, or enrolled, to the National Student Loan Data Center (NSLDS) within 60 days of the change. Corrective Actions: Management concurs with this finding. The College did not consistently report student status changes to NSLDS within the required 60-day timeframe due to inefficient tracking processes and system misalignment between internal records and reporting systems. Corrective actions implemented as follows: 1. Automated Tracking & Reporting Calendar 1. Established a compliance calendar with hard deadlines (<30 days internal target) 2. System Integration Improvements 1. Enhanced data alignment between: Ellucian Colleague, National Student Clearinghouse, and NSLDS 3. Accountability Structure 1. Assigned a designated compliance owner for NSLDS reporting 2. Introduced escalation protocols for missed deadlines 4. Monitoring & Reporting 1. Monthly compliance certification to senior leadership Timeline: Process corrections implemented in Summer 2025; Full compliance expected in Fall 2025 onward Person(s) Responsible for Corrective Action Plan: Anahi Huerta, Director of Financial Aid, Phone: 312-922-1884

View Audit 396203

Finding 1202948 (2025-001)

Material Weakness 2025

MacCormac College Dba Generations College

IL

Student Financial Aid Material Weakness Internal Control / Segregation of Duties

Finding 2025-001 Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268 Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals related to student records. Corrective Action Plan: Objective: To ensure the timely...

Finding 2025-001 Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.063, 84.268 Condition: The College could not timely retrieve all student records and show documentation of reviews and approvals related to student records. Corrective Action Plan: Objective: To ensure the timely retrieval of all student records and the proper documentation of reviews and approvals to meet regulatory requirements and to improve accountability in the Student Financial Aid Cluster. Corrective Actions: Management agrees with this finding. The College admits that before Spring 2025, formal documentation for review and approval of financial aid processes, including Return of Title IV (R2T4) calculations, was not consistently kept. Although controls were performed in most cases, the lack of documented evidence for students selected prior to the internal processing improvements prevented demonstrating control effectiveness, which is required under the Uniform Grant Guidance. Corrective actions implemented as follows: 1. Formal SOP Implementation Developed and implemented standardized SOPs for: 1. Financial Aid packaging and disbursement 2. Return of Title IV (R2T4) calculations 3. Review and approval workflows 2. Documentation & Audit Trail Controls 1. Introduced mandatory review/approval checklists for all financial aid transactions 2. Implemented centralized digital storage of supporting documentation 3. Segregation of Duties & Oversight 1. Established defined roles for: Preparer, Reviewer, Final approver. 4. Ongoing Monitoring 1. Monthly internal compliance reviews 2. Quarterly audit-readiness assessments led by senior leadership Timeline: Process corrections implemented in Spring 2025; Full compliance expected by June 30, 2026 Person(s) Responsible for Corrective Action Plan: Anahi Huerta, Director of Financial Aid, Phone: 312-922-1884

View Audit 396203

Finding 1202944 (2025-004)

Material Weakness 2025

Bond Community Health Center, Inc.

FL

Internal Control / Segregation of Duties § 200.303

Finding 2025-004: Payroll Processing Control Condition: During control testing over a major federal program, three instances were identified where payroll changes were not entered into the payroll system in a timely manner; however, the Organization subsequently processed appropriate retroactive adj...

Finding 2025-004: Payroll Processing Control Condition: During control testing over a major federal program, three instances were identified where payroll changes were not entered into the payroll system in a timely manner; however, the Organization subsequently processed appropriate retroactive adjustments. Corrective Actions 1. Formalize and strengthen payroll change procedures Create written procedures requiring that all Personnel Action Notices be entered into the payroll system within two business days of approval. Require preparer and reviewer signoffs on each change, documenting both data entry and verification steps. Completion Target: June 30, 2026 2. Implement payroll change review controls Before each payroll run, generate and review a “personnel change report” listing all recent pay rate, position, or status updates. Review to confirm accuracy against approved PANs, with evidence of review retained (e.g., initials and date on report). Completion Target: June 30, 2026 3. Enhance communication between HR and Payroll Require HR to transmit all approved PANs electronically to Payroll within a defined timeframe. Maintain a centralized shared log tracking each PAN’s status (“submitted,” “entered,” “verified”) to prevent omissions. Completion Target: June 30, 2026 4. Provide staff training on new procedures Conduct joint training for HR and Payroll personnel on updated workflows, timeliness expectations, documentation standards, and verification requirements. Include refresher training annually or when procedures are updated. Completion Target: June 30, 2026 5. Implement monitoring and periodic internal review The Payroll Manager will perform quarterly reviews of sample PANs to confirm timely and accurate system entry. Any discrepancies will be corrected immediately and reported to the Finance Director/CFO. Ongoing, beginning July 1, 2026 Responsible Party: HR Manager and Payroll Manager, under oversight of the Finance Director/CFO Monitoring and Verification: Payroll change log maintained and reviewed monthly. Quarterly internal review results documented and retained for audit.

View Audit 396201

Finding 1202933 (2025-001)

Material Weakness 2025

Hamilton College

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan: The College will implement a process to verify the enrollment update changes have taken effect on the NSLDS website. The registrar’s office will verify the student status updates for a sample size of 15% of the overall batch population for any given month’s transmission withi...

Corrective Action Plan: The College will implement a process to verify the enrollment update changes have taken effect on the NSLDS website. The registrar’s office will verify the student status updates for a sample size of 15% of the overall batch population for any given month’s transmission within the 60-day required timeframe. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented in Spring 2026.

View Audit 396193

Finding 1202926 (2025-002)

Material Weakness 2025

Housing Authority of the City of Greensboro

NC

Internal Control / Segregation of Duties Allowable Costs / Cost Principles HUD Housing Programs

2025-002 ALN 14.850 – Public Housing Operating Fund – Allowable Costs – Bonus/Incentive Payments The Executive Director agrees with the finding as listed in the Schedule of Findings and Questioned Costs and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. ...

2025-002 ALN 14.850 – Public Housing Operating Fund – Allowable Costs – Bonus/Incentive Payments The Executive Director agrees with the finding as listed in the Schedule of Findings and Questioned Costs and will follow the Auditor's recommendations. Person Responsible for Correction of Finding: Ms. Khristian Allen, Executive Director Projected Completion Date: June 30, 2026

View Audit 396190

Finding 1202923 (2025-004)

Material Weakness 2025

One City Schools, Inc.

WI

Cash Management Material Weakness Matching / Level of Effort / Earmarking § 200.303

2025--004 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Cash Management Auditor's Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Corrective Action: One City ad...

2025--004 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Cash Management Auditor's Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Corrective Action: One City adopted a new grants management process which requires that all submitted claims are reviewed and signed by two responsible officials. Evidence of approvals will be maintained in the electronic grant files. In addition, One City has developed a training tool so that all staff who have grant claiming authority must participate in the training. The new Chief Financial Officer will monitor compliance with the policy and ensure proper documentation exists. Responsible for Corrective Action: Scott R Haumersen CPA, CGMA Shaumersen@onecityschools.org 608-575-4950 Anticipated Completion Date: June 30th, 2026

View Audit 396186

Finding 1202697 (2025-039)

Material Weakness 2025

Liberty County District School Board

FL

Special Tests & Provisions Material Weakness Matching / Level of Effort / Earmarking

Finding Number: 2025-039 Planned Corrective Action: To proactively address these issues, FAHCA has taken several steps to improve efficiency and survey scheduling accuracy. The Quality Assurance and Performance Improvement Protocol, revised in 2024, has enhanced tracking measures to better identify ...

Finding Number: 2025-039 Planned Corrective Action: To proactively address these issues, FAHCA has taken several steps to improve efficiency and survey scheduling accuracy. The Quality Assurance and Performance Improvement Protocol, revised in 2024, has enhanced tracking measures to better identify and prioritize surveys requiring scheduling. Both management and schedulers participated in targeted training sessions held in August 2024 and December 2024. In addition, Monthly Scheduler calls are conducted to provide ongoing guidance and support to field offices regarding scheduling needs and best practices. Furthermore, scheduling workload updates are reviewed every two weeks during Bureau Call Meetings with schedulers and managers to ensure continual monitoring of survey scheduling needs and progress. This improvement reflects the commitment of staff and leadership to proactively respond to challenges and implement strategies that advance the agency’s overall performance. Anticipated Completion Date: September 15, 2026 Responsible Contact Person: Mary Maloney

View Audit 396183

Finding 1201604 (2025-002)

Material Weakness 2025

Circle the City

AZ

Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Item: 2025-002 Assistance Listing Number: 93.224 Programs: Health Center Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A Contract Number: 24H80CS28365; H8JCS54690; 21H8HCS44987 Award Year: June 1, 2024 to May 31, 2025; December 1, 2024 to November 30, 20...

Item: 2025-002 Assistance Listing Number: 93.224 Programs: Health Center Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A Contract Number: 24H80CS28365; H8JCS54690; 21H8HCS44987 Award Year: June 1, 2024 to May 31, 2025; December 1, 2024 to November 30, 2025; September 1, 2023 to August 31, 2025 Compliance Requirement: Special Tests and Provisions Criteria: Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Condition: For five claims tested, the discount for eligible patients was inaccurately calculated and billed. Name of Contact Person: Michele Grebisz, CFO Phone Number: (602)776-0776 Anticipated Completion Date: March 31, 2026 Views of Responsible Officials and Corrective Actions: Management agrees with the finding and will implement additional controls to ensure sliding fee discounts applied are reviewed and approved before patients are billed. Management will ensure this additional process includes clearly documenting the review and approval.

View Audit 396169

Finding 1201601 (2025-001)

Material Weakness 2025

Southeast Coastal Ocean Observing Regional Association

SC

Subrecipient Monitoring Internal Control / Segregation of Duties

Corrective Action Plan (CAP) Award Information: NOAA Program Office: NOS Integrated Ocean Observations Systems (IOOS) Federal Award Numbers (FAIN): NA21NOS0120097, NA24NOSX012C0024, and NA23NOS0120243 Recipient Organization: Southeast Coastal Ocean Observing Regional Association Recipient UEI: EEL2L...

Corrective Action Plan (CAP) Award Information: NOAA Program Office: NOS Integrated Ocean Observations Systems (IOOS) Federal Award Numbers (FAIN): NA21NOS0120097, NA24NOSX012C0024, and NA23NOS0120243 Recipient Organization: Southeast Coastal Ocean Observing Regional Association Recipient UEI: EEL2LR5E2R85 Project Title: SECOORA: Delivering actionable coastal and ocean information from high-quality science and observations for the Southeast Project Period: 7/1/21-6/30/26 Criteria: During our single audit for the year ended June 30, 2025, we identified that required subawards were not reported in SAM.gov (previously in the FFATA Subaward Reporting System (“FSRS”)) within the 30-day FFATA reporting window, as required by 2 CFR Part 170 and NOAA award terms. This constitutes noncompliance with federal award requirements and may trigger remedies under 2 CFR § 200.339. Cause: The Association was subject to FFATA reporting requirements under its cooperative agreement with the Integrated Ocean Observing System (“IOOS”) Office within the National Oceanic and Atmospheric Administration (“NOAA”). The cause of the FFATA reporting lapses was an interpretation gap of requirements under a cooperative agreement versus a prime grant award, and management has agreed to promptly remediate and implement controls. The noncompliance resulted from a good-faith misunderstanding regarding the applicability of FFATA to cooperative agreements and did not stem from intentional misconduct or an overall deficient control environment. Immediate Corrective Actions Taken: The Association acknowledges lapses in timely reporting of first-tier subawards in the FSRS/SAM.gov and gaps in internal controls, including procedure documentation, tracking of subaward obligation dates, and staff training. The overdue FSRS/SAM.gov reports will be submitted, and NOAA/IOOS will be provided documentation of completion. Long-Term Corrective Actions / Preventive Measures: The Association is in the process of establishing written internal controls, including procedures and tracking mechanisms to ensure timely FFATA reporting, as well as provide training to grants management personnel responsible for FFATA submissions to ensure timely and accurate reporting. Management will continue to use standardized subaward agreements to clearly capture obligation dates and FFATA applicability. Subawards will not be fully executed in the system until the FFATA data fields are completed. There will be a separation of duties for distinct roles for preparer and reviewer/approver. The Association will evidence retention with a central archive of FSRS confirmations, checklists, and supporting documentation and maintain a tracking log with automated reminders for key reporting deadlines. Responsible Personnel: Chief Financial Officer: Megan Lee – Oversees, Reviews, and Approves FFATA reporting compliance and SAM.gov reporting. Ensures required reporting of subaward obligations for FFATA reporting on a monthly basis and ensures timely data submission. Pre/Post Award Grant Specialist– Prepares required reporting of subaward obligations for FFATA reporting on a monthly basis. Timeline for Completion Corrective Action Responsible Party Completion Date Submit overdue FFATA report Chief Financial Officer 06/30/2026 Update written procedures Chief Financial Officer 04/30/2026 Staff online training on FFATA requirements Chief Financial Officer 05/31/2026 Implement dual review of reporting Chief Financial Officer 04/30/2026 Internal Monitoring and Verification: The Association will perform quarterly internal reviews of a sample of subawards to verify: timeliness, data accuracy, documentation, and adherence to reporting process. Finally, the Chief Financial Officer and Pre/Post Award Grant Specialist will report to the Executive Director and escalate any issues identified and implement corrective training as needed. Certification: I certify that the information provided in this Corrective Action Plan is accurate and that the organization is committed to full compliance with the terms and conditions of the NOAA award and the Uniform Guidance (2 CFR Part 200), including remediation of noncompliance consistent with 2 CFR § 200.339.

View Audit 396152

Finding 1201560 (2025-002)

Material Weakness 2025

The Kennedy Collective, Inc. and Affiliates

CT

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

Coronavirus State and Local Fiscal Recovery Funds 21.027 Recommendation: CLA recommends that management reinforce and consistently apply key control procedures requiring documented review and approval of all program invoices prior to payment. Management should ensure that reviews explicitly address ...

Coronavirus State and Local Fiscal Recovery Funds 21.027 Recommendation: CLA recommends that management reinforce and consistently apply key control procedures requiring documented review and approval of all program invoices prior to payment. Management should ensure that reviews explicitly address allowability, eligibility and within the period of performance under the program and that evidence of such review is retained in accordance with record retention requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will enforce the internal controls in place to ensure full compliance. Name of the contact person responsible for corrective action: Maria Giaimo, CFO Planned completion date for corrective action plan: June 30, 2026

View Audit 396125

Finding 1201547 (2025-002)

Material Weakness 2025

Beulah Heights University

GA

Student Financial Aid Internal Control / Segregation of Duties Subrecipient Monitoring

Finding 2025-002 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Work-Study Community Service Requirement Not Met and Failure to Report FWS Earnings (significant deficiency): Criteria – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-...

Finding 2025-002 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Work-Study Community Service Requirement Not Met and Failure to Report FWS Earnings (significant deficiency): Criteria – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities unless the institution has received an approved waiver from the Department of Education. Per 34 CFR § 675.19(b), institution must maintain fiscal control and accountability over FWS funds and comply with all reporting requirements established by the Secretary. This includes accurately reporting FWS student earnings through required federal systems and maintaining documentation to support reported activity. Condition - Based on documentation provided for the 2024–2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, only $1,057 was identified as wages paid to students employed in community service activities. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from the U.S. Department of Education of not meeting the required 7 percent community service expenditure threshold. Additionally, during review of the institution’s 2024–2025 Federal Work-Study (FWS) activity, it was noted that FWS student earnings were not reported to the Common Origination and Disbursement (COD) System. The institution’s financial aid records and payroll registers indicate that students earned a total of $23,131 in FWS wages during the award year; however, no corresponding COD submissions or COD acknowledgment files were provided for review to demonstrate that these earnings were reported as required. Cause – The infraction appears to have resulted from failure to monitor compliance with the 7 percent FWS community service requirement and inadequate internal controls to ensure timely and accurate reporting of FWS earnings. Effect – The institution did not comply with the statutory community service spending requirement and FWS earnings were not reported through required federal reporting channels, limiting transparency and federal oversight. Questioned Costs - $0 Perspective – The Federal Work-Study Program includes explicit statutory spending and reporting requirements that are considered key compliance controls. In this instance, the institution expended approximately 4 percent of its authorized FWS allocation ($1,057 of $26,649) on community service wages, compared to the required 7 percent, resulting in a 43 percent shortfall from the required threshold. In addition, 100 percent of FWS earnings identified during testing ($23,131) were not reported to the COD System, as no submission or acknowledgment records were available. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen monitoring of community service requirements and establish formal FWS reporting controls and perform periodic internal audits of FWS expenditures and reporting to identify and correct issues prior to year-end and federal reporting deadlines. Management’s Response – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities. Based on documentation provided for the 2024-2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, $1,057 was identified as community service wages. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from ED was requested or approved

View Audit 396108

Finding 1201534 (2025-002)

Material Weakness 2025

Drexel University

PA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Management agrees with this finding. During the merger process, the U.S. Department of Education required that Salus University’s academic year for federal loans be closed out in order to complete the institutional consolidation. During this closed period, several students withdrew from the Summer t...

Management agrees with this finding. During the merger process, the U.S. Department of Education required that Salus University’s academic year for federal loans be closed out in order to complete the institutional consolidation. During this closed period, several students withdrew from the Summer term, which made it difficult to complete the R2T4 process within the standard timeline. This situation was the result of the unique operational constraints associated with the merger and is considered an anomaly rather than a reflection of Salus and Drexel University’s standard procedures. Now that Salus University and Drexel University are fully consolidated, we do not anticipate this circumstance occurring again. Drexel University maintains a written R2T4 policy that includes established procedures, system edit checks, and clearly defined staff responsibilities. Financial Aid team members are fully trained on R2T4 requirements and are responsible for monitoring student withdrawals and completing R2T4 calculations within the required timeframes to ensure compliance with federal regulations.

View Audit 396098

Finding 1201526 (2025-001)

Material Weakness 2025

Drexel University

PA

Internal Control / Segregation of Duties

Management agrees with this finding and s currently working to implement an electronic consent (e-Consent) process for students to ensure compliance and improve documentation of student consent for electronic communications related to financial aid.Two processes are being implemented to address this...

Management agrees with this finding and s currently working to implement an electronic consent (e-Consent) process for students to ensure compliance and improve documentation of student consent for electronic communications related to financial aid.Two processes are being implemented to address this requirement: 1.Incoming Students:For new students, the e-Consent process will be incorporated into the confirmation section ofSlate (University incoming student CRM, Customer Relationship Mangement System). This willallow incoming students to review and complete the e-Consent electronically during theadmissions and enrollment confirmation process. 2.Continuing Students:For currently enrolled students, the e-Consent acknowledgment will be incorporated into theStudent Financial Obligation and Tuition Repayment Agreement (SFO). This ensures thatcontinuing students provide consent as part of the annual financial responsibility agreement process. In addition, information about the e-Consent policy will be published on the Drexel University website within the Terms and Conditions section so students have clear access to the policy and understand the requirements for electronic communication. These updates will ensure that students formally acknowledge and consent to electronic communications regarding financial aid and student account information, strengthening institutional compliance and internal controls. We anticipate having this in place for the start of the 26-27 academic year processing.

View Audit 396098

Finding 1201514 (2025-001)

Material Weakness 2025

Family Planning Association of Maine, Inc. Dba Maine Family Planning

ME

Eligibility Internal Control / Segregation of Duties

A. Remediation of Identified Files For participants who are no longer active in the WIC program, no further action will be taken, as the certification period has concluded. For participants who remain active and whose files lack a signed WIC Agreement of Rights and Responsibilities, an “alert” will ...

A. Remediation of Identified Files For participants who are no longer active in the WIC program, no further action will be taken, as the certification period has concluded. For participants who remain active and whose files lack a signed WIC Agreement of Rights and Responsibilities, an “alert” will be placed in the WIC system to ensure the required signature is obtained at the participant’s next scheduled appointment. The signed agreement will be retained in the participant’s certification file in accordance with documentation requirements. B. Staff Reinforcement and Training The WIC Director meets with staff weekly and will formally address the requirement to obtain and retain a signed WIC Agreement of Rights and Responsibilities annually. Staff will be reminded that a certification file is not considered complete unless all required eligibility documentation, including the signed agreement, is present. C. Strengthened Supervisory Review Control (Monitoring Control) Beginning immediately, the WIC Director (or designated supervisory staff) will implement a documented monitoring control to ensure completeness of eligibility documentation: 1. On a monthly basis, supervisory staff will select a sample of newly certified and recertified participant files. 2. The review will verify that all required eligibility documentation is present, including: o Categorical determination o Proof of residency o Income documentation o Nutritional risk documentation o Signed WIC Agreement of Rights and Responsibilities 3. Evidence of supervisory review (e.g., initials, checklist, or review log) will be retained. 4. Any deficiencies identified during internal monitoring will be corrected promptly, and trends will be discussed with staff. This monitoring control is designed to ensure ongoing compliance with federal and state eligibility documentation requirements and to prevent recurrence of the deficiency.

View Audit 396093

Finding 1201504 (2025-001)

Material Weakness 2025

Hardee County District School Board

FL

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility

The District appreciates the opportunity to respond to the audit finding regarding inconsistencies between Title I rank order and the allocation of funds based on low-income student percentages for the 2024-2025 fiscal year. Our review indicates that the variance in allocations resulted from a budge...

The District appreciates the opportunity to respond to the audit finding regarding inconsistencies between Title I rank order and the allocation of funds based on low-income student percentages for the 2024-2025 fiscal year. Our review indicates that the variance in allocations resulted from a budget decision to provide additional Title I funding to Bowling Green Elementary to support after-school programming, without fully accounting for per-pupil allocation. Historically, Bowling Green Elementary has served one of the highest concentrations of students from low-income families in the District, and the additional allocation was intended to ensure continuity of extended learning opportunities for students with significant academic need. While this decision was grounded in student need, the District recognizes that the additional funds were not fully reconciled with updated poverty data and required rank-order calculations. The District has demonstrated compliance with rank and serve requirements in prior years; however, to prevent recurrence, we are strengthening our internal controls. Beginning immediately, the District will implement a structured monthly review of Title I school allocations involving the Title I Program Specialist, the Finance Director, and the Deputy Superintendent to ensure that the 2025-2026 allocations align with current poverty data and PSES calculations. Additionally, the District will seek guidance from the Florida Department of Education Title I Office to confirm that our procedures fully meet all regulatory expectations. The District is confident that these corrective actions will ensure full compliance in 2025-2026 moving forward and will strengthen the integrity of our allocation processes.

View Audit 396085

Finding 1201503 (2025-001)

Material Weakness 2025

City of Newton, Massachusetts

MA

Cash Management Reporting School Nutrition Programs

Child Nutrition Cluster, ALN’s 10.553 & 10.555 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Explanation of disagreement with audit...

Child Nutrition Cluster, ALN’s 10.553 & 10.555 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Explanation of disagreement with audit finding: Management agrees with the finding. Action taken in response to finding: Newton operated the National School Lunch Program (NSLP) during the Extended School Year (ESY) for the first time during the summer 2024, which created a reporting challenge. Students from across the district's 23 schools attended ESY in seven (7) schools/sites, but their school-year home schools could not be changed in the Student Information System (Aspen). Therefore, student meal counts reported to their home school on the FP9 but had to be reported on the DESE School Report for the ESY school/site they attended. Given the system interface complexities, some counts had to be manually entered, for which two (2) meal counts were incorrectly entered for breakfast versus lunch. Given that the district did not operate the School Breakfast Program (SBP) and did not serve breakfast, these two (2) manual errors were counted as lunch counts when entered for the School Report. The total meal count did match on the FP9 and School Report. For this inconsistency, the correct action should have been to manually update these two counts in the Point of Sale system (Mosaic) so that the two breakfast counts reflected correctly as lunch counts. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: Newton was able to set conditional parameters in Aspen for ESY 2025 so that the student meal counts reported to their ESY school/site versus their home school, so this reporting issue was corrected the following summer.

View Audit 396079

Finding 1201495 (2025-003)

Material Weakness 2025

Lewistown Community Unit Schools District 97

IL

Internal Control / Segregation of Duties Reporting § 200.303

Condition: Multiple individuals are responsible for the preparation and submission of the District's quarterly exepnditure reports; however, the expenditure reports filed for September 30, 2024 included expenditures in the amount of $22,040 that were neither obligated nor liquidated by the date of t...

Condition: Multiple individuals are responsible for the preparation and submission of the District's quarterly exepnditure reports; however, the expenditure reports filed for September 30, 2024 included expenditures in the amount of $22,040 that were neither obligated nor liquidated by the date of the report. Plan: Mannagement will review all expenditure reports. Only expenditures obligated within the grant period will be included on the expenditure report. Any obligations not yet liquidated will be reported as such.

View Audit 396063

Finding 1201487 (2025-010)

Material Weakness 2025

William Peace Universirty

NC

Student Financial Aid Internal Control / Segregation of Duties Material Weakness § 200.303

Segregation of Duties Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. ...

Segregation of Duties Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review its staffing and the need for separation of duties as part of an effective internal control system and take appropriate actions.. Name(s) of the contact person(s) responsible for corrective action: Vice President for Enrollment Management Damon Wade, Director of Financial Aid Deniesha Newby, and Controller Will Gibbons Planned completion date for corrective action plan: June 30, 2026

View Audit 396041

Finding 1201483 (2025-009)

Material Weakness 2025

William Peace Universirty

NC

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Credit Balance Recommendation: We recommend the University evaluate its procedures and policies around credit balances to ensure that students are refunded within the fourteen day requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action tak...

Credit Balance Recommendation: We recommend the University evaluate its procedures and policies around credit balances to ensure that students are refunded within the fourteen day requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management understands this federal requirement and will ensure that it is met. Name(s) of the contact person(s) responsible for corrective action: Controller Will Gibbons Planned completion date for corrective action plan: June 30, 2026

View Audit 396041

Finding 1201479 (2025-008)

Material Weakness 2025

William Peace Universirty

NC

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Direct Loan Reconciliations Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as su...

Direct Loan Reconciliations Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support of performance monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will take action to ensure compliance with this recommendation.. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Deniesha Newby Planned completion date for corrective action plan: June 30, 2026

View Audit 396041

Finding 1201476 (2025-006)

Material Weakness 2025

William Peace Universirty

NC

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Direct Loan Overaward Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in res...

Direct Loan Overaward Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review existing procedures and modify as needed to ensure compliance with this recommendation.. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Deniesha Newby Planned completion date for corrective action plan: June 30, 2026

View Audit 396041

Corrective Action Plans

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