Corrective Action Plans

Finding 551549 (2024-008)

Significant Deficiency 2024

DC

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financi...

Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: Howard University uses automated processes to identify and send loan disbursement notifications to parents and students. The nightly UC4 process prompted Banner to send out a Direct Loan notification to the student and/or parent. This UC4 process showed all students who had a Direct Loan disbursement after the last nightly UC4 process was run. During a compliance review of disbursement notifications during the Fall 2023 semester and the Loans Team worked with Banner consultants to determine the reason for this. While this issue was being reviewed and a solution created, the Loans Team used the RLRDLDD report in Banner, which is a report that showed all loans disbursed. This report could be matched against the UC4 listing of loans disbursed. This check between UC4 and the RLRDLDD report was used to send out loan notifications that was missed during the UC4 process during the Fall 2023 semester. During a Spring 2024 compliance review of disbursement notifications, it was discovered the RLRDLDD report was missing disbursements as well. As a corrective action, the Loans Team then began using a loan audit report out of the Argos reporting system to identify students who may have a disbursement not included in the UC4 and/or RLRDLDD report. The support time required for maintenance of Banner was also reduced due to the ongoing integration and implementation efforts to prepare Workday for the Fall 2024 semester. This increased the length of time it took to correct the UC4 process and RLRDLDD reports. Howard no longer uses Banner to send out Graduate PLUS, Subsidized and Unsubsidized loan notifications. Workday now is now responsible for sending out the disbursement notification after a loan has disbursed and there is a record in the student’s Activity History to document the loan notification has been sent. Parent PLUS Loan notifications must be sent out manually due to Workday not having the capability to send a disbursement notification to the parent’s email on file. The “FA CR Parent PLUS Disbursement Notification Report” is run weekly out of Workday to identify all Parent Plus Loan disbursements and a notification is sent to the parent’s email address on file. Bi-semester reviews are completed by the Associate Director for Compliance to ensure the loan disbursement notifications are being sent to students and parent in the required 30-day timeline. These reviews also ensure inclusion in the loan notification of all federally required information. Anticipated Completion Date: This corrective action plan was completed during Fall 2024 implementation of Workday. Monitoring and reviewing of loan disbursements has been ongoing to ensure the Workday system is correctly identifying and transmitting Direct Loan disbursements. Given that Workday is a new ERP, Howard recognizes maintenance and review of the disbursement notification process will be ongoing.

View Audit 352153

Finding 551543 (2024-003)

Significant Deficiency 2024

The Howard University

DC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Oliver Street, Interim University Registrar; Saleem Sullivan, Associate Registrar for Compliance; La Estes, Records Specialist; Ben Carmichael, Associate Director for Compliance, Enrollment Reporting; Sarah Mariner, Assistant Director for Compliance, Financial Aid Co...

Name of Responsible Individual: Oliver Street, Interim University Registrar; Saleem Sullivan, Associate Registrar for Compliance; La Estes, Records Specialist; Ben Carmichael, Associate Director for Compliance, Enrollment Reporting; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and is responsible for transmitting enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submits the enrollment status report to NSLDS. The University Registrar resigned in July 2024 and the Associate Registrar position was also vacant at that time. These “peak time” staffing issues helped create confusion as to which enrollment files had been scheduled and sent to NSC. The University hired an experienced Associate Director Registrar for Compliance in December 2024 and is currently searching for a University Registrar with experience working in the Workday Enterprise Resource Planning system (ERP). Howard moved to using Workday Student as the University’s ERP beginning Fall 2024 and it has been confirmed the accurate program lengths for each program were entered in Workday. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program lengths are reported to NSLDS. Screenshots of the programs reported to NSLDS incorrectly have been provided to BDO as a way to document the program length will be accurately reported in the future. Graduation files are scheduled to be transmitted on the first of every month to NSC. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day timeline will be met. In Workday, the date the student has been cleared for graduation (i.e. the effective day) is available on the “Academics” tab. This should make it easier to show an audit trail for the student’s graduation clearance date. Anticipated Completion Date: The correction to the length of each program in Workday was implemented during setup prior to the start of the Fall 2024 semester. There will be a Spring 2025 review performed by the Associate Director for Compliance to ensure the program length is accurately reported and testing shows this issue to be resolved. Each semester, enrollment reporting samples will be selected (approximately) 2 to 3 weeks after the first enrollment file for the semester is sent to NSC. Howard has set up a transmittal calendar with NSC which determines when enrollment files, including the graduate files, are transmitted. Due to work completed regarding the integration of Workday with NSC, Howard worked closely with NSC during Fall 2024 to troubleshoot issues that could delay enrollment files transmission. The schedule for submission of files was setup during this time. Howard currently has a vacancy at the University Registrar position and experienced individuals with Workday user knowledge will be pursued for hire. The hiring date for the University Registrar has not been approximated due to the positional requirement of Workday experience and the newness of the ERP system into the higher education space. The current Interim Registrar has prior University Registrar experience with knowledge of the requirements to be effective in the position.

View Audit 352153

Finding 551540 (2024-005)

Significant Deficiency 2024

The Howard University

DC

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

Name of Responsible Individual: Keith Anderson, Associate Provost, Office of Undergraduate Studies; Paapa Berko, Federal Work-Study Coordinator; Tina Knight, Director, Center for Career & Professional Success; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Dani Hollis, Ass...

Name of Responsible Individual: Keith Anderson, Associate Provost, Office of Undergraduate Studies; Paapa Berko, Federal Work-Study Coordinator; Tina Knight, Director, Center for Career & Professional Success; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Dani Hollis, Associate Director of Operations & Customer Service; John Hooth, Senior Director of Payroll; Sasha Quinga, Senior Director, Human Resources Information Systems Corrective Action: Federal Work Study (FWS) supervisors are required to have training on the appropriate policies and procedures when hiring a FWS student. They sign off on the Federal Work Study supervisor agreement stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours, as this is a not a best practice. The Center for Career & Professional Success began using this updated FWS supervisor agreement beginning with the Spring 2025 semester. All FWS supervisors who had students for Fall 2024 were required to review and sign the updated agreement as well. The Federal Work Study Coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works. The Federal Work Study Coordinator also ensures supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. The full-time Federal Work Study Coordinator position was filled prior to the end of the Fall 2024 semester, and this ensures a full-time employee is now in place to help provide a more active review of the Federal Work Study program. One student was not paid FWS earnings within 30 days. At the time, Howard University did not print out paper checks, only providing FWS payments as a direct deposit. The student was to be paid for those two pay periods (10/8/23-10/21/23 and 10/22/23-11/4/23) on 11/3/23 and 11/17/23. The student did not have any payment selections set up in the system for the earnings to be deposited into and this delayed the receipt of the Federal Work Study payment. Working with the AVP for Enrollment Management, we have discussed with Payroll the need to process a paper check if a student chooses this delivery method. The University is also working on an awareness campaign that will encourage students to set up their direct deposit information in Workday. Students understanding the need to set up direct deposit and the willingness to process paper checks, if necessary, should prevent this finding from recurring. The Associate Director for Compliance or designee will review when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working during class hours. These reviews of FWS hours matching the students’ earnings will provide another layer of oversight. Anticipated Completion Date: The Center for Career and Professional Services hired a full-time Federal Work Study Coordinator towards the end of the Fall 2024 semester. All FWS supervisor training occurs prior to the hire of any FWS students, and the supervisor agreement has been updated as of December 2024 to reflect supervisors signing they understand students are not to have time approved prior to working those hours. The awareness campaign encouraging students to choose the direct deposit option in Workday will begin in late Spring as the Fall 2025 class prepares to enter Howard.

View Audit 352153

Finding 551538 (2024-007)

Significant Deficiency 2024

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Name of Responsible Individual: Carmela Goodall, Manager, Systems and Administration (Office of the Bursar); Robin Whitfield, Associate Vice President for Finance & Bursar; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Linda Coles, Director of Cash Management, Treasury Op...

Name of Responsible Individual: Carmela Goodall, Manager, Systems and Administration (Office of the Bursar); Robin Whitfield, Associate Vice President for Finance & Bursar; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Linda Coles, Director of Cash Management, Treasury Operations; Keynesha Wilson, Treasury Specialist; Kathleen Harrod, Accounts Payable Disbursement Manager; Rawle Howard, Assistant Vice President, Procurement Corrective Action: There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023. The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester. Anticipated Completion Date: Howard feels this finding has been mitigated and there will be no further findings where students received a Title IV credit balance check past the 14-day deadline. Semester or bi-semester reviews will be completed by Financial Aid to ensure the University is sufficiently meeting the federal requirements for students and/or parents to receive the Title IV credit balance check within 14 days.

View Audit 352153

Finding 551537 (2024-006)

Significant Deficiency 2024

The Howard University

DC

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

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Sarah Mariner, Assistant Director for Compliance, Financial Aid; Robin Whitfield, Associate VP for Finance & Bursar; Guillermo Creamer, Collections Manager; Robert Muhammad, Executive Director o...

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Sarah Mariner, Assistant Director for Compliance, Financial Aid; Robin Whitfield, Associate VP for Finance & Bursar; Guillermo Creamer, Collections Manager; Robert Muhammad, Executive Director of Financial Aid; Brenda Willis, Senior Executive Director of Financial Grants & Contracts; Educational Computer Systems, Inc. Corrective Action: Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University. Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31. Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity. It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP. The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15. Anticipated Completion Date: Summer 2025 is the date the University anticipates having liquidated the Perkins program. Cash on Hand will be reported as of June 30 and updated again on October 31. Completion of the FISAP is due September 30, 2025 and final edits to the FISAP are due December 15, 2025. Howard will update the Cash on Hand and tuition and fees as of December 15, 2025 for final submission. The U.S. Department of Education will then review the submitted FISAP for errors or inconsistencies. Should there be no errors or inconsistencies from ED’s review, they will accept the FISAP and begin basing any Excess Liquid Capital return request on the Cash on Hand reported.

View Audit 352153

Finding 551536 (2024-001)

Significant Deficiency 2024

Bay Area Air Quality Management District

CA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.435 § 200.459

View of Responsible Officials and Corrective Action Plan Air District Management concurs with the recommendation under Finding Reference Number F-2024-001. Upon review of the supporting travel expense documentation, management has found no discrepancies. Moving forward, the Air District will contin...

View of Responsible Officials and Corrective Action Plan Air District Management concurs with the recommendation under Finding Reference Number F-2024-001. Upon review of the supporting travel expense documentation, management has found no discrepancies. Moving forward, the Air District will continue to ensure that all supporting travel documentation agrees with the corresponding invoices to maintain compliance and accuracy. Regarding the overstatement of program expenditures, the Air District will initiate the recovery of the identified overcharges by deducting the amount from future reimbursement requests submitted to the Department of Homeland Security (DHS). Specifically, the Air District plans on recovering the $9,316 in overcharges from the contractor for fiscal year ending June 30, 2024. Additionally, the Air District is in the process of reviewing Fiscal Year 2025 invoices to identify any potential overcharges and will request reimbursement from the contractor, as necessary. To strengthen oversight and compliance, the Air District has begun implementing process changes as of February 2025. These changes ensure that consultant invoices align with the terms of the Air District’s contract prior to approval and payment processing. Name: Daniel Meer Title: Manager, Government Outreach & Special Projects Email: dmeer@baaqmd.gov

View Audit 352146 Questioned Costs: $1

Finding 551531 (2024-001)

Significant Deficiency 2024

Alameda Health Consortium

CA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

The audit was filed late in 2023 due to an extended vacancy of a key finance position combined with the selection of a new audit firm, which resulted in additional time to prepare for and complete the audit. It is expected that this should not be an issue going forward.

View Audit 352145

Finding 551524 (2024-001)

Significant Deficiency 2024

Pontifical Catholic University of Puerto Rico

PR

Internal Control / Segregation of Duties

Management has already written the basic Security of information Plan as required by 6 C.F.R. 313.3 and 313.4. This plan was sent to the Federal Student Aid (FSA) Cybersecurity Team (CCT). In July 18, 2024, after closing of the fiscal year, the CCT sent a letter stating they had reviewed the univers...

Management has already written the basic Security of information Plan as required by 6 C.F.R. 313.3 and 313.4. This plan was sent to the Federal Student Aid (FSA) Cybersecurity Team (CCT). In July 18, 2024, after closing of the fiscal year, the CCT sent a letter stating they had reviewed the university submission and has determined that the CAP acceptably addresses the auditor finding for audit year 2023. Contracting of an independent third party to carry out a NIST CS IT Risk Assessment and Penetration Testing & vulnerability Assessment for PUCPR was completed. GM Security Technologies, is a qualified Security Assessor Company (QSAC) certified by the PCI Security Council. The initial report for a Pen Test & Vulnerability Assessments report by April 21st,2025. When evaluation is completed, GM Sectec will perform a retest to high/critical remediated vulnerabilities and a guide roadmap mapped to NIST Cyber Security Framework. These assessments are planned to be completed by June 2025

View Audit 352134

Finding 551512 (2024-001)

None 2024

St. Thomas University Inc.

FL

Questioned Costs Special Tests & Provisions Student Financial Aid

Corrective Action Plan – Thorough Review of FWS Payroll All timesheets are electronically saved, in the event an employee submits a paper time sheet due to a missed time period, the document is scanned and saved in the shared payroll file. On a bi-monthly basis FWS payroll is reviewed and reconcil...

Corrective Action Plan – Thorough Review of FWS Payroll All timesheets are electronically saved, in the event an employee submits a paper time sheet due to a missed time period, the document is scanned and saved in the shared payroll file. On a bi-monthly basis FWS payroll is reviewed and reconciled to ensure students are getting paid for amounts earned. Contact Person: Neville Bates, Payroll Manager Telephone: 305.474.6702 Email: nbates@stu.edu Completion Date: 9/30/2024

View Audit 352117 Questioned Costs: $1

Finding 551509 (2024-002)

None 2024

Valor Christian College

OH

Special Tests & Provisions Reporting Internal Control / Segregation of Duties

FINDING 2024-002: UNTIMELY PAID CREDIT BALANCE- the auditor tested forty files, twenty-three of which had credit balances, and one credit balance was not paid in a timely manner. It is recommended the College increase controls over credit balances. Comments on Finding and Recommendation(s): We concu...

FINDING 2024-002: UNTIMELY PAID CREDIT BALANCE- the auditor tested forty files, twenty-three of which had credit balances, and one credit balance was not paid in a timely manner. It is recommended the College increase controls over credit balances. Comments on Finding and Recommendation(s): We concur with the finding and we believe that htis a unique situtaiton be we can create a revised review process. Actions Taken or Plannded: To address discrepancies in the student refund check process and prevent late returns the Finance Office will implement a structured verification and tracing procedure. After the Financial Aid office approves the calcuation sheets for refunds, a POPULI report capturing all credit balances from the start of the term to the latest financial aid disbursement will be generated. Finance Office will cross-reference refunds in process to determine completeness.

View Audit 352114

Finding 551506 (2024-003)

Significant Deficiency 2024

Clarkson University

NY

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

Management accepts this finding. The error on the verification (1 student) was made by a former staff that did not verify the student wages. Clarkson’s procedure clearly states the income is required to be verified, however the former staff member made an error in processing this verification. Impr...

Management accepts this finding. The error on the verification (1 student) was made by a former staff that did not verify the student wages. Clarkson’s procedure clearly states the income is required to be verified, however the former staff member made an error in processing this verification. Improvements to the training process have been implemented including emphasis on the requirement that staff verify income as part of the review process. A multi-tier review system has been implemented whereby after the initial review process has been completed, verification documents are submitted to the Director who then performs a second review to ensure that the initial review process was correctly followed and that the data is reliable. Anticipated Completion Date December 2024 - completed Responsible Person Nicole Adner, Director of Financial Aid

View Audit 352112

Finding 551505 (2024-002)

Material Weakness 2024

Clarkson University

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management accepts this finding and notes there were issues with the disbursement records that prevented them from being sent to COD. Unexpected turnover in the workforce resulted in 25% normal processing capacity during the timeframe in question. Staffing levels in that area have been fully restore...

Management accepts this finding and notes there were issues with the disbursement records that prevented them from being sent to COD. Unexpected turnover in the workforce resulted in 25% normal processing capacity during the timeframe in question. Staffing levels in that area have been fully restored with appropriate training to the employees. A formal schedule has been developed whereby records are reconciled and sent to COD on a weekly basis to reduce the risk of late filings. In addition, the University is considering methods of improved redundancy and backup to prevent systemic issues going forward. Anticipated Completion Date December 2024 - completed Responsible Person Nicole Adner, Director of Financial Aid

View Audit 352112

Finding 551503 (2024-005)

Significant Deficiency 2024

South Carolina State University

SC

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Student Financial Aid § 200.303

Corrective Action Plan The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken: 1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and ...

Corrective Action Plan The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken: 1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and internal controls related to the submission of origination and disbursement records to the COD system. This includes implementing stricter monitoring mechanisms to ensure all records are submitted within the required timeframes. 2. Implement Advanced Technology Solutions: To improve the efficiency and accuracy of financial reporting, the University will adopt advanced technology solutions. These tools will facilitate timely and accurate submission of required data to the COD system. The newly established internal audit team will oversee the implementation and management of these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal origination and disbursement requirements. By taking these steps, the University aims to rectify the identified deficiency and prevent future occurrences, thereby maintaining the integrity of its financial reporting processes. Anticipated Completion Date: September 1, 2025

View Audit 352110

Finding 551502 (2024-004)

Significant Deficiency 2024

South Carolina State University

SC

Questioned Costs Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal financial aid regulations. The following steps will be undertaken: 1. Strengthen Financial Aid Coordination: The Financial Aid team will enhance coo...

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal financial aid regulations. The following steps will be undertaken: 1. Strengthen Financial Aid Coordination: The Financial Aid team will enhance coordination among various programs and between federal and non-federal aid sources to ensure that total aid awarded does not exceed a student’s financial need or cost of attendance. This aligns with federal regulations requiring institutions to prevent over awards by adjusting aid packages accordingly. 2. Implement Advanced Technological Solutions: The University will collaborate with technology support teams to develop data platforms and scripts that monitor and control award amounts, ensuring they do not surpass students’ cost of attendance. This proactive approach will aid in preventing future over award situations. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal financial aid regulations and to uphold the integrity of its financial aid programs. By implementing these measures, the University aims to rectify the identified over award issue and prevent similar occurrences in the future, thereby maintaining compliance with Title IV funding requirements. Anticipated Completion Date: September 1, 2025

View Audit 352110 Questioned Costs: $1

Finding 551494 (2024-003)

Significant Deficiency 2024

South Carolina State University

SC

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid § 200.303

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The Univ...

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies. 2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines. 3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds. By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements. Anticipated Completion Date: September 1, 2025

View Audit 352110

Finding 551395 (2024-001)

Significant Deficiency 2024

The Montessori Network

IL

Allowable Costs / Cost Principles Cash Management Internal Control / Segregation of Duties

Audit Recommendation: Procedures should be consistently applied requiring the reconciliation of submitted personnel activity reports to the employees' actual costs allocated and charged to federal and other programs. Planned Corrective Actions: This finding was initially identified during fiscal ye...

Audit Recommendation: Procedures should be consistently applied requiring the reconciliation of submitted personnel activity reports to the employees' actual costs allocated and charged to federal and other programs. Planned Corrective Actions: This finding was initially identified during fiscal year 2020, and corrective actions were taken by the School in 2021. To address the issue, the School implemented new procedures that require a monthly review by management, which includes a detailed reconciliation of submitted personnel activity reports to vouchers prepared for federal and other programs. This reconciliation process helps to ensure that payroll cost allocation accurately reflects the submitted personnel activity reports. In addition, the School has made changes to its payroll system to ensure accurate time tracking for its various programs. This includes changing the service provider responsible for voucher submissions. These changes will help to prevent similar issues from occurring in the future and ensure that employee-related costs are accurately allocated to the appropriate programs. As of 2022, the School has successfully implemented these changes and continues to review and monitor its procedures to maintain compliance with federal and other program regulations. Finding was repeated during FY23 and FY24, as the School was in the process of transitioning accountants and implementing control procedures during the period of exceptions noted. Anticipated Completion Date: June 30, 2024 Contact Person: Rita Nolan, Executive Director

View Audit 352104

Finding 551391 (2024-004)

Material Weakness 2024

Hampton University

VA

Student Financial Aid Special Tests & Provisions Reporting

The University concurs with the finding. The University is working with the Clearinghouse and consultants to correct system errors within Banner, so we do not have these concerns in the future. The Architect students mapping issue was corrected by the Registrar Office in March 2025. The Registrar’s ...

The University concurs with the finding. The University is working with the Clearinghouse and consultants to correct system errors within Banner, so we do not have these concerns in the future. The Architect students mapping issue was corrected by the Registrar Office in March 2025. The Registrar’s Office has created a new program code that will reflect next semester’s registrations and updated previous majors.

View Audit 352091

Finding 551208 (2024-019)

Material Weakness 2024

Upshur County Board of Education

WV

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.334

The Board will establish procedures that will ensure compliance with guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200 for Special Education.

View Audit 352084 Questioned Costs: $1

Finding 551189 (2024-003)

Material Weakness 2024

The City of New York

NY

Questioned Costs Internal Control / Segregation of Duties Eligibility § 200.303

Finding No. 2024-003 Department(s): New York City Administration for Children’s Services and Department of Education Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: The City is planning to transition to the New York State IT system o...

Finding No. 2024-003 Department(s): New York City Administration for Children’s Services and Department of Education Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: The City is planning to transition to the New York State IT system once it is fully developed and implemented by the New York State Office of Children and Family Services and New York State Information Technology for the Child Care Assistance Program. The State IT system will be programmed to reflect current State policy on authorized hours, mitigating the risk of this error in the future. In the interim, The City will implement a short-term, manual solution that will ensure enrollments match authorized hours with regard to full time or part time enrollment and days of enrollment. The first step of the manual solution requires a feasibility analysis to see if it is possible to add a field for recording authorized hours into The City's IT system of record. DOE: The DOE will continue working with ACS to ensure compliance with internal controls, applicable state and federal statutes, regulations, requirements and guidelines. The internal controls include a quality assurance check process on submitted eligibility applications. Anticipated Completion Date: ACS: August 2025 and ongoing DOE: Ongoing Person(s) Responsible for Implementation: ACS: Shari Gruber, Associate Commissioner, Policy and Compliance, Division of Child & Family Well-Being, shari.gruber@acs.nyc.gov, (212) 393-5109 DOE: Meg Barboza, Senior Director of Program Enrollment, mbarboza@schools.nyc.gov, (212) 287-1996 Jodina Clanton, Eligibility and Senior Director of Policy, jclanton@schools.nyc.gov, (212) 287-1927

View Audit 352075 Questioned Costs: $1

Finding 551186 (2024-002)

Significant Deficiency 2024

The City of New York

NY

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

Finding No. 2024-002 Department(s): New York City Department of Health and Mental Hygiene Program(s): Assistance Listing Number 93.323, Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Corrective Action(s): DOHMH agrees with the recommendation that “DOHMH enhance their internal ...

Finding No. 2024-002 Department(s): New York City Department of Health and Mental Hygiene Program(s): Assistance Listing Number 93.323, Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Corrective Action(s): DOHMH agrees with the recommendation that “DOHMH enhance their internal controls over the reporting process by ensuring that all financial and special performance reports undergo documented review and approval before submission within the required timeframe.” Anticipated Completion Date: Effective Immediately; 3/25/2025 Person(s) Responsible for Implementation: Yuming Li - Director, yli@health.nyc.gov Anthony Faciane - Assistant Commissioner, afaciane@health.nyc.gov Wai Ting Yu - Assistant Commissioner, wyu4@health.nyc.gov Jennifer Carmona - Senior Director, jcarmona@health.nyc.gov Xiu Mei Mai - Director, xmai@health.nyc.gov James Chan - Director, jchan6@health.nyc.gov Yulia Gudzinskiy - Grants Manager, ygudzinskiy@health.nyc.gov Jenny Tejada - Director, jtejada@health.nyc.gov Inna Dubrovenska - Assistant Director, idubrovenska@health.nyc.gov

View Audit 352075

Finding 551180 (2024-004)

Material Weakness 2024

The City of New York

NY

HUD Housing Programs Eligibility Material Weakness § 200.303

Finding No. 2024-004 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimiz...

Finding No. 2024-004 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. HPD continues to make progress in addressing this substantial backlog through the implementation of technological and streamlined program improvements. HPD increased its HUD reporting rate of actions taken on household cases by 34% from FY23. Although there has been significant progress towards on time recertifications, HPD anticipates it will continue to take time until the agency achieves pre-pandemic overall submission levels as HPD ensures that any enforcement action the agency takes is taken as a last resort. HPD’s COVID-era policies involving adverse action have ceased and normal processes are in effect. However, it takes intensive tracking and follow up to ensure participants comply with requirements to submit annual certifications or have due-process before terminating subsidy for failing to respond. As a result, there is a lag between the re-implementation of HPD’s policy to take enforcement actions and ensuring every active participant has a completed certification. 1. Continue to build on existing systems to more closely track recertifications that are mailed and not returned. 2. Build on the more robust digital operations that were started during the pandemic to track the submission of documents improving reporting capabilities that help track overdue recertifications. 3. Create a streamlined process for referring overdue cases for Community Based Organizations that can assist participants complete and return recertification package 4. Continue to provide automated reminders for participants at risk of termination of assistance because of their failure to submit a recertification package. 5. Invest in a training team to meet the training needs of new staff Anticipated Completion Date: Implemented as of March 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 352075

Finding 551178 (2024-005)

Material Weakness 2024

The City of New York

NY

HUD Housing Programs Internal Control / Segregation of Duties Eligibility § 200.303

Finding No. 2024-005 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Pro...

Finding No. 2024-005 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. HPD continues to make progress in addressing this substantial backlog through the implementation of technological and streamlined program improvements. HPD increased its HUD reporting rate of actions taken on household cases by 34% from FY23. Although there has been significant progress towards on time recertifications, HPD anticipates it will continue to take time until the agency achieves pre-pandemic overall submission levels as HPD ensures that any enforcement action the agency takes is taken as a last resort. HPD’s COVID-era policies involving adverse action have ceased and normal processes are in effect. However, it takes intensive tracking and follow up to ensure participants comply with requirements to submit annual certifications or have due-process before terminating subsidy for failing to respond. As a result, there is a lag between the re-implementation of HPD’s policy to take enforcement actions and ensuring every active participant has a completed certification. 1. Continue to build on existing systems to more closely track recertifications that are mailed and not returned. 2. Build on the more robust digital operations that were started during the pandemic to track the submission of documents improving reporting capabilities that help track overdue recertifications. 3. Create a streamlined process for referring overdue cases for Community Based Organizations that can assist participants complete and return recertification package 4. Continue to provide automated reminders for participants at risk of termination of assistance because of their failure to submit a recertification package. 5. Invest in a training team to meet the training needs of new staff Anticipated Completion Date: Implemented as of March 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 352075

Finding 551177 (2024-007)

Significant Deficiency 2024

The City of New York

NY

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

Finding No. 2024-007 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): HRA implemented the corrective actions noted in our response to the Fiscal 2023 Single Audit findings. In Nove...

Finding No. 2024-007 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): HRA implemented the corrective actions noted in our response to the Fiscal 2023 Single Audit findings. In November of 2023, HRA hired an Executive Director for the Home TBRA program, updated the quality assurance evaluation tool and trained staff on the differences of budgeting the “gross” and “net” income. Note that HRA began closing out the TBRA tenants with renewal lease dates starting on 8/1/2023, as the program fully closed and transitioned to the City Fighting Homelessness and Eviction Prevention Supplement (“CityFHEPS”) by the 6/30/24 HRA- Housing Preservation and Development Memorandum of Understanding expiration date. Although the rental assistance portion of the HOME TBRA program began phasing out, the following corrective actions were implemented as part of the Fiscal 2023 Single Audit recommendation: • Supervisory staff were retrained on case review and instructed to do a thorough and comprehensive review of the budget and documentation received to inform case decisions. There have been on-going team and individual meetings, informational sessions and trainings with staff involved with TBRA to improve performance and outcome. Anticipated Completion Date: Not Applicable. As noted above, the Rental Assistance portion of the program has been taken over by CityFHEPS. Person(s) Responsible for Implementation: Jordan Worrell, HTBRA Executive Director worrellj@hra.nyc.gov (929)-252- 5403

View Audit 352075

Finding 551168 (2024-101)

Significant Deficiency 2024

Pima County Community College District

AZ

Questioned Costs Student Financial Aid Special Tests & Provisions § 200.303

Assistance Listings number and program name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans This finding initially occurred in fiscal year 2024. Name of Contact Person: David Donderew...

Assistance Listings number and program name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans This finding initially occurred in fiscal year 2024. Name of Contact Person: David Donderewicz, M. Ed., Executive Director of Financial Aid and Scholarships Anticipated completion date: June 30, 2025 Corrective Action: 1. Perform calculations for all students who received Title IV funds and withdrew during the period November 2023 through June 2024 and immediately return all unearned aid to ED. 2. Review and update the student information system’s automated controls to properly identify and flag all students who receive Title IV funds and withdraw from the District. 3. Test any changes made to the student information system and verify controls are operating as designed to comply with the SFA cluster’s requirements. The College concurs with the recommendations from the Arizona Auditor General. The College will conduct an additional review to identify any students who may have impacted financial aid adjustments and will enact any necessary corrections (estimated completion, 3/31/25). Additionally, the College will review the automated controls process to ensure the accuracy of the enrollment change data and will conduct assessments at the end of each term to ensure R2T4 calculations are processed correctly (estimated completion 6/30/25).

View Audit 352069 Questioned Costs: $1

Finding 551149 (2024-003)

Significant Deficiency 2024

Bergen Community College

NJ

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

Views of Responsible Officials: The College agrees that it did not submit the data correction nor recalculated awards for one out of the forty of the students sampled. While the College does not believe that this failure rate represents a significant deficiency, we acknowledge the importance of the ...

Views of Responsible Officials: The College agrees that it did not submit the data correction nor recalculated awards for one out of the forty of the students sampled. While the College does not believe that this failure rate represents a significant deficiency, we acknowledge the importance of the finding and will take mitigation steps moving forward. The Financial Aid Office brought verifications back in-house for the 23-24 award year after a five-year contract was ended with a third-party agency. To strengthen compliance efforts, our financial aid staff underwent verification training from NASFAA as well as internal training over the past two years. The Financial Aid Office will review existing procedures to identify areas of improvement, specifically, verification corrections within our SIS Colleague system and the FAFSA Partner Portals for the 24-25 and 25-26 award years. Furthermore, efforts are under way to hire additional staff to strengthen the breadth of available resources to meet compliance requirements.

View Audit 352065

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