Corrective Action Plans

Finding 1205637 (2025-001)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid Eligibility Internal Control / Segregation of Duties

Finding 2025-001 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Satisfactory Academic Progress (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit for the fiscal year ending June 30, ...

Finding 2025-001 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Satisfactory Academic Progress (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit for the fiscal year ending June 30, 2025, regarding Finding 2025-001 (Material Weakness). We recognize the gravity of the systemic issues related to the monitoring of Satisfactory Academic Progress (SAP) and the associated questioned costs of $346,764.00. The College is committed to full compliance with 34 CFR 668.34 and is implementing the following corrective actions to ensure the integrity of our Title IV Student Financial Aid Programs. • Automation and System Integration: The College is transitioning from manual SAP monitoring to an automated tracking system within our Student Information System (SIS). This will ensure that academic standing—specifically GPA and completion rates are calculated systematically at the end of each Spring Semester. • Audit of Appeal Documentation: We are establishing a centralized digital repository for all SAP appeals. Effective immediately, no Title IV funds will be disbursed to students on financial aid probation without a documented, approved appeal and a corresponding academic plan on file. • Staff Training and Accountability: The Office of Financial Aid will undergo mandatory training focused specifically on federal SAP criteria. We have revised our internal "Check and Balance" protocol, requiring a secondary review by the Director of Financial Aid before any student failing SAP is cleared for disbursement. • Annual Policy Review: In alignment with the Auditor’s Recommendation, Tougaloo College will conduct a comprehensive annual evaluation of all students. This evaluation will be reconciled against the Registrar’s records to ensure data consistency. • We have updated our SAP policy to allow us to review at end of each Spring The College has already begun the look-back process to review the eligibility of the 16 students identified in the sample. We anticipate that the new automated monitoring and revised internal controls will be fully operational by the start of the Fall 2026 semester to prevent any further repeat findings.

View Audit 397293

Finding 1205565 (2025-002)

Material Weakness 2025

School District of Waukesha

WI

Cash Management Reporting School Nutrition Programs

The District will review their processes and procedures for reimbursement claims. In addition, there will be a manager level review of claims for reasonableness.

View Audit 397253

Finding 1205564 (2025-001)

Material Weakness 2025

School District of Waukesha

WI

Cash Management Reporting Internal Control / Segregation of Duties

The District will implement internal controls to properly record accounts payable on a timely basis prior to audit fieldwork. This will include an in-depth review and account reconciliation with substantiating support for all payables on our financials as of year-end.

View Audit 397253

Finding 1205562 (2025-005)

Material Weakness 2025

The Shaw University, Inc.

NC

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

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), University Registrar (Charee Ellison) Corrective Action: The University concurs with this finding. Shaw University acknowledges the finding regarding variances between institutional records and the status re...

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), University Registrar (Charee Ellison) Corrective Action: The University concurs with this finding. Shaw University acknowledges the finding regarding variances between institutional records and the status reported in NSLDS. For students 1-3 listed for campus enrollment details, the students withdrew then subsequently re-enrolled. The University, to date has had static to confer degrees which do not coincide with the required timeframe of NSLDS reporting. The University will change degree conferral dates to better coincide with timely NSLDS reporting. Management will continue to monitor this process to ensure ongoing compliance. Anticipated Completion Date: May 15, 2026

View Audit 397245

Finding 1205557 (2025-003)

Material Weakness 2025

The Shaw University, Inc.

NC

Student Financial Aid Internal Control / Segregation of Duties Reporting

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the findings. Shaw University acknowledges the findings regarding variances between institutional records and the a...

Name of Responsible Individual: Vice President of Enrollment Management (Dr. Stacey Sowell), Director of Financial Aid (Dr. Ojebe Ifegwu) Corrective Action: The University concurs with the findings. Shaw University acknowledges the findings regarding variances between institutional records and the amounts reported on the FISAP, as well as the delay in submitting corrections by the required deadline. The variances were due to insufficient reconciliation between the University’s records and the FISAP prior to submission. In addition, controls were not adequate to ensure that identified discrepancies were corrected within the required timeframe. The University has since completed a full reconciliation of the FISAP, and further corrections will be made. To prevent recurrence, the University has implemented procedures requiring a formal reconciliation of supporting records to the FISAP prior to submission, along with enhanced review and approval controls to ensure accuracy and timely reporting. Management will continue to monitor this process to ensure ongoing compliance. Anticipated Completion Date: April 30, 2026

View Audit 397245

Finding 1205549 (2025-001)

Material Weakness 2025

The Shaw University, Inc.

NC

Cash Management Student Financial Aid Internal Control / Segregation of Duties

Name of Responsible Individual: Vice President of Financial Operations/CFO (Michelle Lane) Corrective Action: The University concurs with the findings. Shaw University acknowledges that this finding is a repeat condition related to excess cash balances for Pell Grant, Direct Loan, and FSEOG funds no...

Name of Responsible Individual: Vice President of Financial Operations/CFO (Michelle Lane) Corrective Action: The University concurs with the findings. Shaw University acknowledges that this finding is a repeat condition related to excess cash balances for Pell Grant, Direct Loan, and FSEOG funds not being eliminated within the required seven business days. Management has determined that prior corrective actions were not sufficiently formalized or consistently executed, particularly with respect to reconciliation and monitoring controls. Since that time, the University has strengthened its internal controls over Title IV cash management. A formal monthly reconciliation between G5 drawdowns and the general ledger has been implemented to ensure excess cash balances are identified and resolved timely. In addition, procedures have been revised to limit drawdowns to actual or immediate disbursement needs, and monitoring controls have been established to ensure compliance with the seven-business-day requirement. Management will continue to monitor these processes to ensure ongoing compliance with federal cash management regulations. Anticipated Completion Date: June 30, 2026

View Audit 397245

Finding 1205544 (2025-103)

Material Weakness 2025

Bay County District School Board

FL

Special Tests & Provisions Student Financial Aid Material Weakness § 200.303

Finding Number: 2025-103 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Enforcing secure system access protocols, including multi-factor authentication The institution will implement multi-factor authentication (MFA) across all financial a...

Finding Number: 2025-103 The deficiencies resulted from the absence of a comprehensive, system-based control structure capable of: ● Enforcing secure system access protocols, including multi-factor authentication The institution will implement multi-factor authentication (MFA) across all financial aid and student information systems to: ● Protect Title IV data from unauthorized access ● Align with federal information security expectations ● Ensure compliance with institutional cybersecurity policies Anticipated Completion Date: 8/31/2026 Responsible Contact Person: Angela Reese

View Audit 397241

Finding 1205530 (2025-003)

Material Weakness 2025

Alpha One

ME

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Management concurs in part and disagrees in part with this finding. Management has always understood that alcohol purchases may not be charged to a Federal program and are unallowable under Uniform Guidance, and we are committed to ensuring full compliance with federal cost principles. Upon identifi...

Management concurs in part and disagrees in part with this finding. Management has always understood that alcohol purchases may not be charged to a Federal program and are unallowable under Uniform Guidance, and we are committed to ensuring full compliance with federal cost principles. Upon identification of this exception, management initiated corrective measures to reinforce internal controls surrounding expense review and documentation. The accounting staff member did not have the itemized receipt at the time the expense was initially allocated. Had the receipt been available, the unallowable cost would have been identified, and the expense would not have been allocated to program costs. Once the receipt was reviewed, the alcohol purchase was identified as unallowable under Federal programs and allocated correctly to administration costs. To prevent similar issues moving forward, accounting staff have been re-trained on expense documentation and receipt-tracking requirements, with emphasis on ensuring that itemized receipts are obtained and reviewed prior to allocation, reimbursement, or payment. Staff have also been reminded of the importance of validating expenditures against Uniform Guidance allowability requirements as part of their routine review procedures. Management will continue to monitor expense activity to ensure the effectiveness of these reinforced controls. The anticipated completion date for this corrective action is 11/1/2025.

View Audit 397202

Finding 1205528 (2025-001)

Material Weakness 2025

Alpha One

ME

Internal Control / Segregation of Duties HUD Housing Programs Significant Deficiency

Management agrees with this finding. Upon identification of the issue, we initiated immediate corrective actions to reinforce our internal control environment and ensure full compliance with our cash disbursement approval policy. We have completed re-training for all accounting staff to reaffirm the...

Management agrees with this finding. Upon identification of the issue, we initiated immediate corrective actions to reinforce our internal control environment and ensure full compliance with our cash disbursement approval policy. We have completed re-training for all accounting staff to reaffirm the requirements of our payment approval policy and to emphasize the importance of verifying documented approval prior to processing any invoice, regardless of the payment method (check, automated withdrawals, or portals). Additionally, management has implemented a system upgrade, transitioning from a manual approval workflow to an automated approval process. This upgraded system is designed to require approval before an invoice can proceed to payment, thereby preventing invoices from being disbursed without documented written authorization. We expect this automated control to significantly reduce the risk of future exceptions and strengthen overall compliance. Management will continue to monitor disbursement activity to ensure ongoing adherence to policy and the effectiveness of the new control measures. The anticipated completion date for this corrective action is 11/1/2025.

View Audit 397202

Finding 1205518 (2025-004)

Material Weakness 2025

Michigan City Area Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2025-004 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We wil...

FINDING 2025-004 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure the proper documentation is in place for any students removed from the graduation cohort. Anticipated Completion Date: We anticipate that this correction will be in place by August 2026

View Audit 397194

Finding 1205515 (2025-002)

Material Weakness 2025

Michigan City Area Schools

IN

Allowable Costs / Cost Principles School Nutrition Programs Internal Control / Segregation of Duties § 200.208 § 200.303 § 200.403

FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We wil...

FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure that the Form 9 and all underlying expenditures are properly documented. Anticipated Completion Date: We anticipate that this correction will be in place by July 2027

View Audit 397194

Finding 1205505 (2025-001)

Material Weakness 2025

Hampton School District

NH

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Corrective Actions 1. Immediately cease noncompliant payment practices • Stop all direct payments or reimbursements to private schools • Communicate the change to all stakeholders 2. Establish compliant fiscal procedures • Ensure the district (LEA) retains control of Title I funds at all times • Pay...

Corrective Actions 1. Immediately cease noncompliant payment practices • Stop all direct payments or reimbursements to private schools • Communicate the change to all stakeholders 2. Establish compliant fiscal procedures • Ensure the district (LEA) retains control of Title I funds at all times • Payments must be made: o To third-party vendors, or o For district-managed services (staff, materials, contracts) • Update written fiscal procedures to explicitly prohibit: o Reimbursement-based arrangements with private schools o Direct cash transfers to private schools • Require pre-approval for all Title I expenditures related to equitable services 3. Implement a vendor-based service model • Contract with approved vendors to provide services to private school students 4. Strengthen review and approval processes • Require multi-level approval (program+ finance) before payments • Cross-check expenditures against: o Approved equitable services plan o Student eligibility and services provided 7. Provide targeted fiscal training • Train finance and program staff on: o Control of funds requirements o Allowable vs. unallowable costs under Title I

View Audit 397188

Finding 1205485 (2025-001)

Material Weakness 2025

Metropolitan Familly Services

IL

Procurement, Suspension & Debarment Reporting Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN FOR FINDING 2025-001 Identifying Number: 2025-001 Finding: For the Federal Award Identification Number: 84.215, contract number (S215J230147), the reporting requirement for FFAFTA reporting, due August 31, 2024 was not met. Required reporting was submitted on January 28, 2026,...

CORRECTIVE ACTION PLAN FOR FINDING 2025-001 Identifying Number: 2025-001 Finding: For the Federal Award Identification Number: 84.215, contract number (S215J230147), the reporting requirement for FFAFTA reporting, due August 31, 2024 was not met. Required reporting was submitted on January 28, 2026, which was after the submission due date. Corrective Action Taken: Metropolitan Family Services will implement a process to ensure new contracts are reviewed so we are adhering to reporting requirements. The Assistant Budget Directors have been notified to review the reporting requirements more closely. The initial review of the reporting requirements will be conducted by the Assistant Budget Directors, and a final review will be by the Budget Director. Responsible Individuals: This will be completed by the following Assistant Budget Directors: Casey Maher Leticia Reyes Jeff Sklenar Emilia Vargas Gaz Meni Ramiro Chavez Reviews will be performed by the Budget Director (Don Pyznarski). Anticipated Completion Date: The anticipated completion date is June 1, 2026.

View Audit 397170

Finding 1205484 (2025-007)

Material Weakness 2025

Las Vegas City Schools

NM

School Nutrition Programs Equipment & Real Property Management Internal Control / Segregation of Duties § 200.303

Recommendation We recommend the District implement documented daily edit checks reconciling meal counts to attendance records and maintain records of this review. For food inventory, the District should establish a formal inventory system, including perpetual inventory records, monthly physical coun...

Recommendation We recommend the District implement documented daily edit checks reconciling meal counts to attendance records and maintain records of this review. For food inventory, the District should establish a formal inventory system, including perpetual inventory records, monthly physical counts, and supervisory review. Staff involved in Child Nutrition operations should receive training on USDA and federal compliance requirements Management Response Corrective Action The Food Service Director will implement the federally required daily edit check process. This will include comparing daily meal counts against the attendance and enrollment figures to ensure that claims do not exceed the number of students present. Any discrepancies identified during this process will be investigated and documented prior to submission of the monthly claim. The District will also change the tracking of meals served by using an official meal tracking device or by having students use their badge/ID cards to get a more accurate meal count each day. The District has a formal inventory process for all food service supplies including canned goods, dry goods, and freezer items. This system tracks items from receipt through consumption. The District conducts monthly physical inventory counts of all food service assets. These counts are reconciled and any significant variances are reviewed by the Food Service Director and reported to the Business Manager. The District will ensure that all nutrition staff is trained on these procedures as well. Due Date of Completion: June 30, 2026 Responsible Party Business Manager, Food Service Director

View Audit 397169

Finding 1205479 (2025-001)

Material Weakness 2025

Show-Me Central Habitat for Humanity

MO

Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Board of Directors be aware of the internal control deficiencies over financial reporting. And, if possible, implement procedures to ensure that the Organization has the expertise necessary to prevent, detect and correct misstatements and be capable of drafting ...

Recommendation: We recommend that the Board of Directors be aware of the internal control deficiencies over financial reporting. And, if possible, implement procedures to ensure that the Organization has the expertise necessary to prevent, detect and correct misstatements and be capable of drafting the financial statements, related footnote disclosures and SEFA in accordance with the accounting principles generally accepted in the United States of America (U.S. GAAP).

View Audit 397166

Finding 1205479 (2025-001)

Material Weakness 2025

Show-Me Central Habitat for Humanity

MO

Reporting Internal Control / Segregation of Duties

Views of responsible officials and planned corrective actions: The Board believes it has personnel who possess suitable skill, knowledge, or experience to oversee services the auditor provides in assisting with financial statement presentation which requires a lower level of technical knowledge than...

Views of responsible officials and planned corrective actions: The Board believes it has personnel who possess suitable skill, knowledge, or experience to oversee services the auditor provides in assisting with financial statement presentation which requires a lower level of technical knowledge than the competence required to prepare the financial statements, related footnote disclosures and SEFA in accordance with accounting principles generally accepted in the United States of America (U.S. GAAP).

View Audit 397166

Finding 1205471 (2025-002)

Material Weakness 2025

Clear Lake Community School District

IA

Internal Control / Segregation of Duties

We will continue to monitor our procedures and implement additional controls where possible.

View Audit 397144

Finding 1205469 (2025-002)

Material Weakness 2025

Little City for Community Development

IL

HUD Housing Programs Internal Control / Segregation of Duties

Auditors Recommendation: We recommend that management implement and enforce procedures to ensure Replacement Reserve deposits are made in the required amounts and at the required frequency, including periodic review by management to ensure ongoing compliance with HUD requirements. Action Taken: Goin...

Auditors Recommendation: We recommend that management implement and enforce procedures to ensure Replacement Reserve deposits are made in the required amounts and at the required frequency, including periodic review by management to ensure ongoing compliance with HUD requirements. Action Taken: Going forward, we will create a procedure for the Finance team to make the required deposits to the HUD reserve accounts In the future, noting, dates, and amounts to make. They will be added to our month end reconciliations. We have caught up, and made necessary deposits to date, and are current.

View Audit 397143

Finding 1205468 (2025-001)

Material Weakness 2025

Little City for Community Development

IL

HUD Housing Programs Internal Control / Segregation of Duties

Auditors Recommendation: We recommend that management implement and enforce procedures requiring documented HUD approval prior to any use of replacement reserve funds, including review and approval by appropriate management personnel, to ensure compliance with HUD requirements. Action Taken: We were...

Auditors Recommendation: We recommend that management implement and enforce procedures requiring documented HUD approval prior to any use of replacement reserve funds, including review and approval by appropriate management personnel, to ensure compliance with HUD requirements. Action Taken: We were not aware that use of these funds required HUD approval. We are creating a policy to prevent any use of the HUD Reserve Account funds, without prior approval from HUD. We have subsequently returned all funds that were borrowed with prior HUD authorization, and will not access them in the future, without proper approval from HUD.

View Audit 397143

Finding 1205456 (2025-002)

Material Weakness 2025

Housing Authority of the County of Dauphin

PA

Special Tests & Provisions HUD Housing Programs Internal Control / Segregation of Duties

Finding Number: 2025-002; Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all client files contain documentation ensuring complia...

Finding Number: 2025-002; Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all client files contain documentation ensuring compliance with Rent Reasonableness requirements. Anticipated Completion Date: 6/30/26; Responsible Contact Person: Kristen Runion, HCV Supervisor

View Audit 397134

Finding 1205443 (2025-001)

Material Weakness 2025

Marillac Community Health Centers

LA

Special Tests & Provisions Subrecipient Monitoring Eligibility

The organization has implemented additional levels of review and prescreening of slide patient data to ensure accuracy and that the data is complete. Routine reviews done by front desk supervisors will be further documented in order to provide additional training to staff as needed. Results of mont...

The organization has implemented additional levels of review and prescreening of slide patient data to ensure accuracy and that the data is complete. Routine reviews done by front desk supervisors will be further documented in order to provide additional training to staff as needed. Results of monthly audits performed by service line leaders will be reported to senior leadership. An internal audit will be done by the compliance team and presented to leadership on a quarterly basis. All appropriate admitting staff will go through training to reinforce our slide process and review procedures for all FQHC services.

View Audit 397122

Finding 1205432 (2025-002)

Material Weakness 2025

Nash County

NC

Eligibility Internal Control / Segregation of Duties Significant Deficiency

Finding 2025-001 Name of contact person: Corrective Action: Proposed completion date: Finding 2025-002 Name of contact person: Corrective Action: Proposed completion date: Section IV - State Award Findings and Questioned Costs Corrective actions for Finding 2025-002 also apply to State Awards. Secti...

Finding 2025-001 Name of contact person: Corrective Action: Proposed completion date: Finding 2025-002 Name of contact person: Corrective Action: Proposed completion date: Section IV - State Award Findings and Questioned Costs Corrective actions for Finding 2025-002 also apply to State Awards. Section III - Federal Award Findings and Questioned Costs Corrective Action Plan Refresher training sessions will be fully completed for all Medicaid staff by the end of January 2026. Documentation standards and quality review processes are already in effect, with ongoing monitoring. Angel Carpenter and Goldie Davis - Medicaid Supervisors All Medicaid caseworkers will complete targeted refresher training on key eligibility and budgeting rules, including the use of online verification systems, accurate income and deduction calculations, household composition, recertification processes, and proper case documentation standards. Training will be delivered through a combination of state Learning Gateway courses, webinars, and internal sessions, with knowledge checks to confirm understanding. Staff will be reminded that “if it’s not documented, it didn’t happen.” Standardized documentation templates have been created and are now required for all cases to ensure thorough, clear, and consistent case notes. Second-party case reviews will continue and be expanded as needed to monitor ongoing accuracy. Case errors and lessons learned will be regular agenda items at monthly staff meetings, with emphasis on double-checking determinations before authorizing or releasing cases in NC FAST. Dedicated weekly time will be protected for staff to work pending verifications and system reports, with supervisory review. Section II - Financial Statement Findings 8/14/2025 Nikki Stanton, Finance Director The Nash County Finance Director was appointed effective April 14, 2025. Since that time, Finance has undertaken the following measures to strengthen operations and internal controls: • Reclassified job duties to better align responsibilities with organizational needs and improve efficiency. • Implemented additional internal controls to enhance the reliability and accuracy of financial processes. • Recruited and onboarded a dedicated Accountant to support the Accounting Manager. These changes have enabled the Accounting Manager to concentrate on performing timely reconciliations and preparing accurate journal entries, thereby improving the overall timeliness and quality of financial reporting. For the Year Ended June 30, 2025 Claude Mayo Jr. Administration Building • 120 West Washington Street, Suite 3072 • Nashville, NC 27856 Phone (252) 459-9800 • Fax (252) 459-9817 188

View Audit 397103

Finding 1205411 (2025-001)

Material Weakness 2025

West River Transit Authority Dba Prairie Hills Transit

SD

Internal Control / Segregation of Duties § 200.303

Condition: During our testing of controls over payroll, we identified three instances of payroll summary reports lacking an indication of review and approval. Criteria: The Uniform Guidance 2 CFR 200.303 requires auditees to establish and maintain effective internal control over federal awards that ...

Condition: During our testing of controls over payroll, we identified three instances of payroll summary reports lacking an indication of review and approval. Criteria: The Uniform Guidance 2 CFR 200.303 requires auditees to establish and maintain effective internal control over federal awards that provides reasonable assurance that the awards are being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Organization should have a system of internal control in place to provide reasonable assurance that payroll summary reports are accurate and are being reviewed. Repeat of Prior Year Finding: No. Auditor’s Recommendation: We recommend that payroll summary reports be reviewed and approved prior to completing the payroll process. If the Executive Director is unavailable, another staff member should review and approve the reports so the payroll process can be completed. Management’s Response: Payroll reports will be reviewed and approved by the Executive Director. If the Executive Director is unavailable, another staff member will review and approve the reports. The Executive Director has reviewed and approved all payroll reports to date. Completion Date: March 17, 2026

View Audit 397085

Finding 1205381 (2025-001)

Material Weakness 2025

United Playaz

CA

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.317 § 200.318 § 200.321 § 200.322 § 200.324

Develop and formally adopt a written procurement policy compliant with 2 CFR 200.317 - 200.327 Train all staff involved in procurement to ensure consistent understanding and proper implementation Perform periodic reviews and updates of the procurement policy to maintain compliance with evolving fede...

Develop and formally adopt a written procurement policy compliant with 2 CFR 200.317 - 200.327 Train all staff involved in procurement to ensure consistent understanding and proper implementation Perform periodic reviews and updates of the procurement policy to maintain compliance with evolving federal requirements.

View Audit 397074

Finding 1205380 (2025-002)

Material Weakness 2025

South Carolina State University

SC

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

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct ...

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026

View Audit 397073

Corrective Action Plans

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