Corrective Action Plans

Finding 524678 (2024-003)

Significant Deficiency 2024

PA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action tak...

Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have contracted with RPK, a leading higher educating consulting firm who has been assisting us with examining our systems, practices, policies, and procedures. We have reorganized the student accounts receivable functions into a seamless student financial service and created a student financial operations backend where all database maintenance, automation, processing, and audits are being coordinated by a team separate from those servicing students directly. We have replaced all ineffective staff members including those who oversaw the record keeping process based on the support and recommendations of RPK, and are completing audits of all files, current and past, in a manual review of all cabinets to correctly alphabetize and organize. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President, Student Financial Services Planned completion date for corrective action plan: Summer 2025

View Audit 344109

Finding 524677 (2024-002)

Significant Deficiency 2024

La Salle University

PA

Reporting Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordan...

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding : Like many US institutions, La Salle contractually relies on the National Student Clearinghouse (NSC) to conduct its enrollment reporting to NSLDS. In order to comply with established regulations, we set up an Enrollment Reporting Submission Schedule with the NSC. La Salle's schedule for 2025 is below: Term Begin Date Term End Date Transmission Type : Schedule Transmission Date Received Date Transmission Status 1/ 13/ 2025 5/ 9/ 2025 F rst of Term 1/ 31/ 2025 1/ 31 /2 25 Edtts Comp eted 1/13/ 2025 5/9/2025 Subsequent of - erm 2/ 17/ 2025 Not Yet Rece ed 1/ 13/ 2025 5/ 9/ 2025 Subsequent of Term 3/ 17/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5/ 9/ 2 25 Subsequent of-erm t./ 15/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5_/9/ 2025 Subsequent of -e,m 5/ 20/ 2025 Not Yet Rece v ed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er F,r;.: 6/ 3/ 2025 Not Yet Rece ved 5/ 19/ 2025 8/ 22/2025 Summer Subsequent 7/ 9/ 2025 Not Yet Recewed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er Subsequent 8/ 13/ 2025 Not Yet Recev ed 8/ 25/ 2025 12/ 13/2025 F rst of Terr, 9/ 23/ 2025 Not Yet Rece'ved 8/ 25/ 2025 12/13/ 2025 Subsequent of Term 10/ 28/ 2025 Not Yet ReceiVed 8/ 25 / 2025 12/ 13/ 2::>25 Subsequent of-erm 11/ 15/ 2025 Not Yet Rece·ved 8/ 25/ 2025 12/ 13/ 2025 Subsequent of-erM 12/16/ 2025 Not vet Receved Adherence to this reporting schedule would ensure timely reporting, as the NSC subsequently transmits data monthly to NSLDS, throughout the academic year, well within the requirement to report student enrollment status at least every 60 days. Our Associate Registrar for Academic Information Systems is specifically charged with maintaining, executing, and adhering to this schedule, as part of the routine duties assigned to that position in our office. Regarding accuracy, data structures are defined in our BANNER database to classify a given student's enrollment status in a given semester as full, three-quarter, half, or less-than-half time, and withdrawn. Those structures are long-established by student level (graduate, undergrad, doctoral), and do not change from semester to semester. BANNER processes extract the registration data and its timing, in light of those definitions and the data is formatted for transmission to the NSC as prescribed. Sound data entry practices have been established to make certain dates associated with those statuses, and the transition of a student within them, are accurately recorded. Consequently, we rely on the BANNER NSC extract, and the NSC's reporting relationship with NSLDS to accurately transmit that data accordingly. The NSC does work with us to rectify or resolve any seemingly inconsistent or incorrect data, based on prior transmissions and current regulations, prior to committing the given enrollment extract to the NSC database for our institution. They help us stay in compliance and consistent on both the campus-level and program-level basis upon which we're required to report. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Fall 2024

View Audit 344109

Finding 524672 (2024-001)

Significant Deficiency 2024

La Salle University

PA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are return...

Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to ensure that there is not an instance where a student does not receive their credit balance within the required 14-day window, the disbursement scheduled has been re-configured to ensure that there are no automatic disbursements running overnight the week leading up to a university and/or federal holiday. A new financial operations team has been created within the student financial services structure to ensure that processes are running smoothly and that systems between both financial aid and the finance office are effectively communicating with each other. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President for Student Financial Services Planned completion date for corrective action plan: Corrected as of Fall 2024.

View Audit 344109

Finding 524671 (2024-001)

Significant Deficiency 2024

Selma Housing Authority

NC

Questioned Costs Eligibility HUD Housing Programs

Finding 2024-001 Name of Contact Person: Melody Wilkins Executive Director Corrective Action: We will implement proper internal control procedures for the Public and Indian Housing program eligibility requirements. Proposed Completion Date: Immediately

View Audit 344104

Finding 524659 (2024-001)

Material Weakness 2024

University of Southern Indiana

IN

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

FINDING 2024-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Summary of Finding: The University had designed a key control that one employee would perform the required verifications, and a second employee would then review a sample of those ver...

FINDING 2024-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Summary of Finding: The University had designed a key control that one employee would perform the required verifications, and a second employee would then review a sample of those verifications. However, the control was not properly implemented or operating effectively as the University had not established proper segregation of duties. The same employee was responsible for performing and reviewing verifications during the audit period without an independent oversight, review, or approval process involving a second employee. Contact Person Responsible for Corrective Action: Joanna Riney, Director of Student Financial Assistance Contact Phone Number and Email Address: 812-465-7049; jriney@usi.edu Views of Responsible Officials: We concur with the finding. While the University of Southern Indiana had internal controls in place to prevent aid from disbursing before verification was marked complete and assigned responsibility for verification processing to a well-trained employee with 20 years of verification processing experience, staff vacancies in the department in addition to training and preparation for vast changes in application, award calculation, and system controls for the 2024-2025 aid year limited the ability to conduct an independent review on a sample of students for which verification had been performed. Given the fact that there were very minimal changes to the verification process from the verification process performed in the last several years, in lieu of an independent review, management determined that for the 2023-2024 aid year, utilizing an after-the-fact review on a sample of completed verifications by the employee performing the verification, to review/double-check the verification procedures, provided reasonable assurance that compliance would be achieved. No instances of non-compliance in verification procedures were detected in the audit. Description of Corrective Action Plan: Staffing levels are returning to normal and new staff have a more complete understanding of overall financial aid including the verification process. Also, the Department of Education has provided additional clarification and guidance for all 2024-2025 processing and reduced the number of students selected for verification, allowing management the ability to resume the performance of an independent review on a sample of students for which verification had been performed. Anticipated Completion Date: The independent review was reinstated effective for verifications performed in Fall 2024 and going forward.Per Uniform Guidance: 2 CFR § 200.511(a) – “The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . .􀀃The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ” 2 CFR § 200.511(c) – “At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in § 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.”

View Audit 344100

Finding 524649 (2024-007)

Significant Deficiency 2024

Eureka College

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a significant deficiency in internal control over compliance relating to the Special Tests and Provisions compliance requirement. Management Response: Management agrees with the finding Corrective Action Plan: JFA deletes prior reconciliation reports. Separate file location on the cloud has been created to hold these monthly reconciliation files. Corresponding reconciliation within Sonis (see above corrective action plan for excess cash) will also occur. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088

Finding 524638 (2024-002)

Significant Deficiency 2024

Eureka College

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2024-002 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-002 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not report actual loan disbursement dates to the COD system for 4 of 40 students in the sample (10%). We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: Implementation of a newer process based on the system and program defaults in Jenzabar Financial Aid. Will use posted dates in Sonis to ensure they match COD within the 3-day regulatory requirement. New reporting usages of SAS loan files will be checked in Sonis to ensure matching disbursement dates. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088

Finding 524609 (2024-003)

Significant Deficiency 2024

Marymount University

VA

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

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanatio...

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The findings stemmed from how the Student Information System (SIS) transmitted graduation dates and the accuracy of submission files. Our previous SIS was unable to determine the correct graduation dates, leading to incorrect data uploads to the National Student Clearinghouse (NSC). We reviewed the NSC error report and made individual corrections. Unfortunately, we missed the data transmission at the beginning of the month and had to wait for the corrections to be sent to the National Student Loan Data System (NSLDS) the following month. Additionally, we did not conduct a comprehensive review of the file to ensure that all data matched after the upload. Marymount has transitioned to a new SIS starting in Fall 2024. We are working closely with the NSC during this transition to provide more timely and accurate data. We have also improved our processes by having multiple staff members review data files before posting them to the NSC, ensuring that every data point is correct. Furthermore, we have joined user groups related to our SIS and NSC reports to stay informed about changes made by the SIS vendor and to be aware of potential complications faced by other universities. Any errors identified during the data upload to the NSC will be corrected within 2-3 business days. This process will ensure that the enrollment status is certified within 60 days and that all dates match. If we are unable to update the NSC before the file is submitted to the NSLDS, we will collaborate with our Financial Aid department to manually update the NSLDS. Name(s) of the contact person(s) responsible for corrective action: Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: March 2025

View Audit 344056

Finding 524601 (2024-005)

Significant Deficiency 2024

Vance County

NC

Questioned Costs Eligibility Internal Control / Segregation of Duties

Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-005 Name of contact person: Corrective Action: Proposed Completion Date: Finding 2024-006 Name of contact person: Corrective Action: Proposed Completion Date: Finding 2024-007 Name of contact person: Corrective Action: Proposed Com...

Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-005 Name of contact person: Corrective Action: Proposed Completion Date: Finding 2024-006 Name of contact person: Corrective Action: Proposed Completion Date: Finding 2024-007 Name of contact person: Corrective Action: Proposed Completion Date: Review of Verifications needed for Adult cases to determine eligibility correctly will be presented by supervisor to ensure workers know what verifications are needed at time of review or application. Documentation standards will be implemented to ensure workers are applying the correct documentation to the case. For the untimely reviews, Magi and Traditional Recertification Recertification Job Aid will be discussed. Acceptable timeframes and processing times will be discussed. Magi pending recertification details report and traditional recertification details report will be reviewed with staff. 1/31/2025 Section III - Federal Award Findings and Question Costs (continued) 1/31/2025 Ebony Mitchell, Medicaid Program Manager Ebony Mitchell, Medicaid Program Manager Ebony Mitchell, Medicaid Program Manager Review of Adult Policy section 2230 (Financial resources) and acknowledgement required with signature. 1/31/2025 NC Fast Learning gateway (Magi Budgeting: Income Determination) training. Review of family and children’s Medicaid policy section MA – 3300 Income and MA – 3306 Modified adjusted gross income (MAGI). Review of Adult Medicaid income policy section MA – 2250 Income. 145

View Audit 344037

Finding 524564 (2024-001)

Significant Deficiency 2024

The Chicago School-Cal INC Dba the Chicago Sch of Pro Psychology

IL

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federa...

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $528,450 to $1,238,306, from November 13, 2023, to December 18, 2023. While the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the amounts were not returned within the seven-day period as required. Summary: The College draws a portion of funds for student stipends while award reconciliation is in progress to ensure timely disbursement. An administrative oversight led to excess cash being held longer than allowed. Specifically, the prior stipend drawdown was not netted out when calculating subsequent fund requests, resulting in excess cash being held for 24 business days. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure compliance with the seven-day return requirement. 2. Process Change: Going forward, the College will refrain from drawing funds for student stipends until reconciliations have been fully completed. This will ensure that funds are drawn in alignment with actual disbursement needs, reducing the risk of excess cash. 3. Internal Control Strengthening: The College will enhance internal controls around cash management to ensure that excess cash instances are identified and corrected promptly. 4. Staff Training: All relevant staff will undergo training on revised cash management procedures and the importance of timely reconciliation and returns. 5. Improved Monitoring: The College will implement a more robust monitoring process to track excess cash and ensure compliance with Federal regulations, including daily checks during peak disbursement periods. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343996

Finding 524524 (2024-004)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Questioned Costs Student Financial Aid Reporting

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding:...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Fully implement and utilize existing reporting functionality in Jenzabar for National Student Clearinghouse • Review existing reporting procedures and process configurations for NSC reporting in Jenzabar to ensure that things are working correctly and being reported in a timely manner • Document the full process internally in the Registration and Records department Name(s) of the contact person(s) responsible for corrective action: Chris Cook, Registrar Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524519 (2024-003)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is reviewing the updated GLBA requirements and updating the WISP to ensure it includes all of the required elements. Name(s) of the contact person(s) responsible for corrective action: Justin Sin, IT Director Planned completion date for corrective action plan: May 31, 2025

View Audit 343891

Finding 524514 (2024-002)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support the loan such as repayment history, documentation showing the original payment was accepted by the student, etc. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Subsequent to the audit testing, all Perkins loan MPNs were located and the College is finalizing its assignment of the loans to the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO and Grant Drinnen, Cash and Accounts Receivable Specialist Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524509 (2024-001)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with a...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed and updated its procedures related to the process of reviewing and remitting unclaimed student refund checks. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO Planned completion date for corrective action plan: January 31, 2025

View Audit 343891 Questioned Costs: $1

Finding 524497 (2024-001)

Material Weakness 2024

Franklin Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection repor...

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors were performed during the audit period. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Reporting compliance requirement which includes documentation of the operation of the controls. Contact Person Responsible for Corrective Action: Camilla Hoffman, Assistant Deputy Treasurer Contact Phone Number and Email Address: hoffmanca@franklinschools.org, 317-346-8748 Views of Responsible Officials: We concur with the finding, but we would like to emphasize that the review had been implemented. It just was not documented by the reviewer. Description of Corrective Action Plan: The Assistant Deputy Treasurer will begin documenting her review of the required ESSER reporting via email, so that this review can be verified by auditors or other inquirers. Anticipated Completion Date: This corrective action will be added to the district’s procedures immediately, but ESSER reporting is not anticipated until later in the Spring 2025.

View Audit 343871

Finding 524492 (2024-005)

Material Weakness 2024

Henning Public School District 545

MN

Internal Control / Segregation of Duties Questioned Costs Material Weakness

Contact Person – Melissa Sparks, Superintendent Corrective Action Plan – The District staff will work with the construction manager to ensure wage rates requirements are monitored. Completion Date – June 2025

View Audit 343854

Finding 524490 (2024-001)

Significant Deficiency 2024

Hoke County, North Carolina

NC

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

Finding: 2024-001 Name of Contact Person: Diane Simmons, Program Integrity Supervisor Corrective Action/Management’s Response: Management agrees with the audit finding. The Program Integrity Investigator will ensure that all documentation and evidence relative to the case is scanned into NCFAST u...

Finding: 2024-001 Name of Contact Person: Diane Simmons, Program Integrity Supervisor Corrective Action/Management’s Response: Management agrees with the audit finding. The Program Integrity Investigator will ensure that all documentation and evidence relative to the case is scanned into NCFAST under the Program Integrity Investigative Case. The Invesitgator will complete the DSS-1682 and review for accuracy prior to submitting the form to the Program Integrity Supervisor for approval. The Program Integrity Supervisor will complete a second party review of all DSS-1682’s and documentation to ensure that investigations and forms are completed correctly and timely. The Program Integrity Investigator will enter the claim into NCFAST after approval by the Supervisor. The second party review results will be reviewed with Program Integrity Staff monthly. Remedial training will be conducted if any errors are found. Proposed Completion Date: the above mentioned procedures will be Implemented immediately.

View Audit 343849

Finding 524481 (2024-001)

Significant Deficiency 2024

Town of Middlebury, Vermont

VT

Internal Control / Segregation of Duties Reporting Special Tests & Provisions

Recommendation: To correct these deficiencies, management would need to hire personnel with adequate accounting experience to perform these functions. The Town would need to weigh the costs of these corrections verse the benefit.

View Audit 343825

Finding 524469 (2024-002)

Significant Deficiency 2024

Baldwin-Whitehall School District

PA

Internal Control / Segregation of Duties HUD Housing Programs School Nutrition Programs

CORRECTIVE ACTION PLAN Department of Education: The Baldwin-Whitehall School District respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of the independent public accounting firm: J. Martin and Associates, LLC P.O. Box 498 Beaver, PA 1...

CORRECTIVE ACTION PLAN Department of Education: The Baldwin-Whitehall School District respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of the independent public accounting firm: J. Martin and Associates, LLC P.O. Box 498 Beaver, PA 15009 Audit period: June 30, 2024 The findings for the year ended June 30, 2024 schedule of findings are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section B – Financial Statement Findings 2024-1 Best Practices Recommendation: Ideally, the District would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the School District’s financial position. Management’s Response: The School District recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Business Manager has to take an active role in the day-to-day operations of the Business Unit. He actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, he approves all check disbursements through the Positive Pay process and physically signs every accounts payable check that is issued by the School District. Recommendation: We recommend that the District strongly encourage the tax collectors to obtain a SOC report in order to ensure proper controls are in place. Management’s Response: The School District understands the importance of obtaining SOC reports from service organizations and will continue to inquire of the appropriate entities to ensure they obtain the proper reports. In discussion with the Delinquent Tax Collector, they notified the District that it is extremely cost prohibitive for them to go through a review that would end with the issuance of a SOC report. Section C – Major Federal Award Findings 2024-2 Segregation of Duties – Child Nutrition, Title I, ESSER Recommendation: Ideally, the District would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on his knowledge of the everyday operations to discover any material changes in the School District’s financial position. Management’s Response: The School District recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Business Manager has to take an active role in the day-to-day operations of the Business Unit. He actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, he approves all check disbursements through the Positive Pay process and physically signs every accounts payable check that is issued by the School District. If you have questions about this report or need additional financial information, please contact Mark Cherpak, Business Manager at: 4900 Curry Road Pittsburgh, PA 15236 412-884-6300

View Audit 343824

Finding 524468 (2024-001)

Significant Deficiency 2024

The Colleges of Law

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Feder...

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had one instance of excess cash for the Federal Direct Student Loan program, ranging from $172 to $10,314, from March 25, 2024, to April 5, 2024. Although the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the funds were not returned within the required seven-day period. Summary: The College inadvertently retained excess cash for the Federal Direct Student Loan program beyond the seven-day tolerance period due to administrative oversight. The delay in returning the excess cash was attributed to the reconciliation process taking longer than anticipated. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure excess funds are returned to the Secretary within the seven-day tolerance period. 2. Process Change: The College will enhance its reconciliation process to expedite the identification and return of excess cash within the required timeframe. 3. Internal Control Strengthening: The College will implement more rigorous internal controls, including automated alerts and checks, to ensure compliance with cash management requirements. 4. Staff Training: Relevant staff will receive additional training on updated cash management procedures and the importance of timely returning excess cash. 5. Improved Monitoring: The College will introduce enhanced monitoring and tracking mechanisms to ensure that excess cash is promptly identified and returned within the mandated period. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343821

Finding 524467 (2024-001)

Significant Deficiency 2024

Realife Cooperative of Phalen Village

MN

Questioned Costs Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperativ...

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 343816

Finding 524461 (2024-005)

Material Weakness 2024

City of Lincoln City, Oregon

OR

Questioned Costs Subrecipient Monitoring Material Weakness

Beginning March 2025, the City's Finance department will review and sign off on any annual financial reports submitted to the U.S. Department of Treasury. The City will provide training to appropriate staff that Finance Departmental review is required.

View Audit 343795

Finding 524448 (2024-002)

Significant Deficiency 2024

Big Beaver Falls Area School District

PA

Internal Control / Segregation of Duties HUD Housing Programs School Nutrition Programs

CORRECTIVE ACTION PLAN

View Audit 343773

Finding 524441 (2024-001)

Significant Deficiency 2024

McDaniel College and Subsidiary

MD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Y...

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Year – May 31, 2024 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan Corrective Action Planned: {The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring. Identify the specific actions to be taken to eliminate or mitigate the recurrence of the finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Kemia Himon, Financial Aid Director Anticipated Completion Date: 3.3.25

View Audit 343760 Questioned Costs: $1

Finding 524434 (2024-003)

Significant Deficiency 2024

Payne Theological Seminary

OH

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The seminary will update our current WISP to comply with all requirements and updated standards. Name(s) of the contact person(s) responsible for corrective action: Raymond Ingram Planned completion date for corrective action plan: April 2025

View Audit 343723

Corrective Action Plans

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