Corrective Action Plans

Finding 1213508 (2025-003)

Material Weakness 2025

WA

Questioned Costs Special Tests & Provisions Material Weakness

Finding 2025-003 – Special Tests and Provisions (Material Weakness in Internal Control Over Compliance) Planned Corrective Action: Seattle Indian Health Board will implement the following actions to ensure accurate application and documentation of the Sliding Fee Discount Program: - EPIC System Upda...

Finding 2025-003 – Special Tests and Provisions (Material Weakness in Internal Control Over Compliance) Planned Corrective Action: Seattle Indian Health Board will implement the following actions to ensure accurate application and documentation of the Sliding Fee Discount Program: - EPIC System Update: Configure EPIC to automatically assign the appropriate sliding fee discount level to patients with zero income to ensure consistent application of the discount schedule. - Required Income Documentation at Intake: Update procedures to require front desk staff to record a patient’s income level at intake for all patients, including a reasonable estimate when documentation in unavailable. This is required for both an accurate sliding fee application and UDS reporting. - Standardized Documentation Requirements: Require retention of supporting documentation for income and family size in the patient record, or documented attestation when estimates are used, in accordance with policy. - Front Desk Training and Accountability: Provide targeted training to front desk and registration staff on sliding fee discount program requirements, with emphasis on proper data entry, documentation standards, and discount application. - Ongoing Monitoring: Implement monthly reviews of a sample of patient accounts to confirm sliding fee discounts are supported, accurately applied, and properly documented. Errors will be corrected and addressed with the staff as needed. Name of Responsible Party: Tempest Dawson, Director of Clinic Operations Anticipated Completion Date: December 31, 2026.

View Audit 400452

Finding 1213503 (2025-001)

Material Weakness 2025

Seattle Indian Health Board

WA

Questioned Costs Eligibility Significant Deficiency

Finding 2025-001 – Eligibility (Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance) Planned Corrective Action: The Seattle Indian Health Board is implementing enhanced corrective actions to ensure full compliance with Indian Health Service eligibility requiremen...

Finding 2025-001 – Eligibility (Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance) Planned Corrective Action: The Seattle Indian Health Board is implementing enhanced corrective actions to ensure full compliance with Indian Health Service eligibility requirements, specifically related to documentation of Tribal enrollment. While prior corrective actions established foundational training and audit processes, management has identified the need for stronger front-end controls, clearer accountability, and system-based safeguards to prevent recurrence. Seattle Indian Health Board will implement the following actions: 1. Strengthen Front-End Eligibility Controls - Eligibility verification protocols will be updated to require complete Tribal enrollment documentation prior to scheduling non-urgent appointments. - A standardized eligibility checklist will be embedded into intake workflows to ensure all required documentation is identified and collected before services are rendered. 2. System Enhancement and Documentation Tracking - Electronic health record workflows will be enhanced to include required fields and alters for missing eligibility documentation, including Tribal enrollment. - Patients with incomplete eligibility records will be flagged, and services will be limited to allowable scenarios until documentation is obtained. 3. Targeted Training and Competency Validation - All registration and front desk staff will undergo mandatory retraining focused specifically on Tribal enrollment documentation requirements and compliance standards. - Staff competency will be validated through post-training assessments and periodic spot checks. 4. Enhanced Monitoring and Internal Audit - Monthly eligibility audits will be expanded to include a statistically valid sample size and documented review of Tribal enrollment verification. - Audit results will be formally reported to executive leadership, with identified deficiencies tracked through resolution. - Repeat errors or noncompliance will be addressed through corrective coaching and performance management, as appropriate. Management believes these enhanced corrective actions directly address the root cause of the finding by strengthening preventive controls, improving staff competency, and increasing oversight and accountability. Name of Responsible Party: Tempest Dawson, Director of Clinic Operations Anticipated Completion Date: December 31, 2026.

View Audit 400452

Finding 1213492 (2025-018)

Material Weakness 2025

The Howard University

DC

Cash Management Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.305

FINDING 2025-018 Name of Responsible Individual: Director of Post Award Compliance and Training Budget Analyst Corrective Action: The University receives advance payments from the sponsor, with the amount determined by the sponsor and adjusted as financial reports are submitted by the University. In...

FINDING 2025-018 Name of Responsible Individual: Director of Post Award Compliance and Training Budget Analyst Corrective Action: The University receives advance payments from the sponsor, with the amount determined by the sponsor and adjusted as financial reports are submitted by the University. In response to the auditor’s recommendation to strengthen internal controls, Howard University will implement procedures to document and reconcile all cash payments received from sponsors on a quarterly basis to actual expenses incurred. This reconciliation process will help ensure that sponsor payments are fully accounted for and appropriately matched to related expenditures, thereby enabling the University to clearly demonstrate which expenses have been reconciled to payments received. Anticipated Completion Date: June 30, 2026

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Finding 1213490 (2025-017)

Material Weakness 2025

The Howard University

DC

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring § 200.512

FINDING 2025-017 Name of Responsible Individual: Director of Post Award Compliance and Training Senior Associate Vice President of Financial Strategy Corrective Action: In response to the auditor’s recommendation to strengthen internal controls and ensure timely submission of the Single Audit Report...

FINDING 2025-017 Name of Responsible Individual: Director of Post Award Compliance and Training Senior Associate Vice President of Financial Strategy Corrective Action: In response to the auditor’s recommendation to strengthen internal controls and ensure timely submission of the Single Audit Report to the Federal Audit Clearinghouse, Howard University will enhance cross collaboration across the University to improve audit readiness. During the May 2025 transition from the Grants and Contracts Accounting Office to the Sponsored Awards Office, the University experienced significant staff turnover and a loss of institutional knowledge, which contributed to audit readiness challenges. Since that time, the University has focused on stabilization efforts. The Office of Research Sponsored Programs has been restructured and is now almost fully staffed. The University will be establishing monthly check ins with key stakeholders to ensure adherence to a compliance calendar with clearly defined roles and responsibilities across core compliance areas. Additionally, the University has hired a Director of Post Award Compliance and Training to lead audit readiness efforts, strengthen internal controls, and support ongoing monitoring and compliance throughout the fiscal year. Anticipated Completion Date: March 31, 2027

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Finding 1213098 (2025-016)

Material Weakness 2025

The Howard University

DC

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Questioned Costs § 200.302

FINDING 2025-016 Name of Responsible Individual: Director of Post Award Compliance and Training Christina Flood, Budget Analyst Corrective Action: Monthly Settlement Reports are used to reconcile actual expenses. An outdated spreadsheet was previously used to convert travel expenses, which resulted ...

FINDING 2025-016 Name of Responsible Individual: Director of Post Award Compliance and Training Christina Flood, Budget Analyst Corrective Action: Monthly Settlement Reports are used to reconcile actual expenses. An outdated spreadsheet was previously used to convert travel expenses, which resulted in incorrect exchange rate calculations. The team has implemented an updated conversion process. Going forward, the Sponsored Program Office Team will review and approve the exchange rates to ensure they are reasonable, accurate, and applied consistently. Anticipated Completion Date: June 30, 2026

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Finding 1212721 (2025-014)

Material Weakness 2025

The Howard University

DC

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting § 200.430

FINDING 2025-014 Name of Responsible Individual: Assistant Vice President for Post Award Corrective Action: The University initiated the Effort Certification process to capture the full calendar year 2025 in April 2026. This represents a one-time extended certification period designed to include pre...

FINDING 2025-014 Name of Responsible Individual: Assistant Vice President for Post Award Corrective Action: The University initiated the Effort Certification process to capture the full calendar year 2025 in April 2026. This represents a one-time extended certification period designed to include previously uncertified periods that had concluded, specifically the second half of FY25 (January–June 2025) and the first half of FY26 (July–December 2025). In May 2025, the non-accounting functions of Grants and Contracts Accounting at Howard University were transitioned to the Office of Research, Sponsored Programs Office. During this organizational transition, the University prioritized the completion and accuracy of all costing allocations to ensure payroll data was complete and reliable for effort certification purposes. This period was also utilized to identify and resolve any backlog of costing allocations and award charges and stabilize the Office of Research. Addressing these items ensured that effort reflected complete and accurate payroll activity, thereby enabling Principal Investigators to appropriately review and certify their effort. The Sponsored Programs Office (SPO) now leads post-award financial oversight and collaborates with Human Resources (HR) and Finance to ensure designated personnel are identified and granted system access to enter costing allocations and labor cost transfers in Workday. In addition, in response to the auditor’s recommendation to enhance internal controls and ensure timely monitoring of effort reporting, Howard University has implemented the following corrective actions: Hired Dedicated Departmental Support – Six College Research Administrators (CRAs) and an Associate Director of CRA’s were hired to support high-volume research colleges. The CRAs ensure timely and accurate labor cost transfers, effort certification, and costing allocation entries during award setup and throughout the award lifecycle. Enhanced Effort Reporting Process – SPO will lead improvements to the effort certification process, including: • Advance communication to PIs, CRAs, and Deans outlining certification deadlines • Clear guidance on when labor cost transfers may occur outside the certification cycle • Reinforcement that all effort changes must be reflected in the effort system to ensure alignment with payroll. • Training – Targeted training will be delivered to Principal Investigators, CRAs, and other research stakeholders to support consistent application of policies and procedures. Monitoring and Oversight – Monthly and quarterly reconciliation reports will be developed to track and validate timely and accurate payroll allocations for research personnel. Anticipated Completion Date: August 30, 2026

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Finding 1212339 (2025-013)

Material Weakness 2025

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Questioned Costs

FINDING 2025-013 Name of Responsible Individual: Assistant Vice President for Pre-Award Corrective Action: Federal awards require that all publications resulting from federal grant support, including conference presentations, promotional materials, agendas, and internet sites, include an acknowledgm...

FINDING 2025-013 Name of Responsible Individual: Assistant Vice President for Pre-Award Corrective Action: Federal awards require that all publications resulting from federal grant support, including conference presentations, promotional materials, agendas, and internet sites, include an acknowledgment of federal support and a disclaimer that the contents reflect the authors' responsibility and not that of the sponsoring agency. As this is a repeat finding, the University has undertaken a comprehensive, multi-pronged corrective strategy to ensure sustained compliance going forward. Responsibility for publication acknowledgment and disclaimer compliance now resides with the Sponsored Programs Office (SPO) Pre-Award, in collaboration with the University Library. Key actions completed to date include: a formal Standard Operating Procedure finalized and approved in November 2025; mandatory publication compliance training with a required 80% passing score, serving as a prerequisite for new award setup effective November 2025; a Principal Investigator (PI) Acceptance Memo requiring signature within five business days of each award kickoff meeting to reinforce PI awareness of publication responsibilities; quarterly compliance communications issued to all federally funded PIs; and a dedicated publication compliance category added to the OOR ticketing system to streamline intake and support documentation. During Award Kickoff Meetings, acknowledgment and disclaimer requirements specific to each award are reviewed directly with the PI. SPO Pre-Award and the University Library conduct ongoing reviews of federally funded publications using available bibliometric tools, with periodic spot checks. PIs who do not meet training requirements are subject to a hold on proposal submissions until compliance is verified. Anticipated Completion Date: June 30, 2026

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Finding 1211964 (2025-012)

Material Weakness 2025

The Howard University

DC

Equipment & Real Property Management Internal Control / Segregation of Duties

FINDING 2025-012 Name of Responsible Individual: Assistant Vice President of Procurement Corrective Action: Since the prior audit period, the University implemented comprehensive corrective actions, including policy updates, strengthened receiving and tagging controls, enhanced supervisory review in...

FINDING 2025-012 Name of Responsible Individual: Assistant Vice President of Procurement Corrective Action: Since the prior audit period, the University implemented comprehensive corrective actions, including policy updates, strengthened receiving and tagging controls, enhanced supervisory review in WorkDay, and ongoing communications with Suppliers and internal stakeholders. Detective and corrective controls have been established through quarterly exception reporting, monthly equipment purchase audits, and completion of a University-wide physical inventory, and required follow-up to locate, tag, or correct asset records. Moreover, the corrective action plan aims to establish an integrated, sustainable control environment. With documented procedures, active monitoring, customer communications, training, and management oversight, the University expects future audit cycles to yield favorable results. Anticipated Completion Date: December 31, 2026

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Finding 1211214 (2025-010)

Material Weakness 2025

The Howard University

DC

Student Financial Aid Reporting Internal Control / Segregation of Duties

FINDING 2025-010 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management Associate Director of Loans Systems Analyst, Enrollment Management Assistant Director for Compliance, Financial Aid Loan Coordinator Corrective Action: Beginning with the Fall 2024 semester, H...

FINDING 2025-010 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management Associate Director of Loans Systems Analyst, Enrollment Management Assistant Director for Compliance, Financial Aid Loan Coordinator Corrective Action: Beginning with the Fall 2024 semester, Howard University transitioned from using Banner to using Workday as the University’s ERP. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” during Fall 2024 there would be no configuration issues that affect compliance. It is not possible for Financial Aid to fully test the COD disbursement reporting process prior to "go live" due to the inability to send test disbursement files to COD for reporting purposes. Once Howard disbursed loans and was able to send actual disbursement files to COD, the Enrollment Management Systems Analyst worked to identify and resolve outstanding issues. Initial reporting of disbursements to COD began on August 6, 2025. When the first disbursement file was sent to COD, the EM Systems Analyst identified the file schema sending out disbursements from Workday to COD kept rejecting the entire file. The Systems Analyst worked with the University Workday consultants to resolve the rejections and was able to correct the issue on August 28th. The cause of the rejected files between Workday and COD was an underlying Workday system issue that was corrected an updated released by Workday. There were issues in Workday regarding the school code that were identified which delayed a small cohort of students’ disbursements from being reported to COD. The Howard University enrollment school code is 00144800 and NSC required a “dummy” school code to be used for enrollment reporting of Graduate and Professional students. This “dummy” code was 00144880. A small cohort of students had loans that were rejected due to Workday reporting the 00144880 school code to COD instead of the 00144800 school code. Reconciliation identified the students and once the enrollment code sent to COD was corrected in Workday, the loan was accepted. The cost of attendance variance was a result of unfamiliarity with the Workday system. After a student's aid has been originated and disbursed, Workday will not automatically send the disbursement file back out to COD, which was not an issue Howard encountered when using Ellucian Banner. In Workday, when a student’s cost of attendance changes due to cost of attendance increase or the student’s housing status must be adjusted, there is manual intervention required. Students who have a change to their cost of attendance need to have a flag checked off in the origination record. This will allow the updated cost of attendance to be reported in COD when the next disbursement file is sent to COD. The current process is when a student's cost of attendance is manually adjusted, the flag for the record to be sent to COD is checked off in the origination record. The Associate Director for Compliance has completed internal compliance reviews testing whether disbursements are being sent to COD within 14 days. Thus far, no issues have been found in these reviews. Files are transmitted to COD at least four times per week and rejected disbursements are worked to meet the 14-day disbursement reporting timeline. A compliance review has been initiated to ensure the cost of attendance reported out of Workday matches the cost of attendance in COD. Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. The goal of these meetings is to have a constant flow of information on what is working effectively and what is not working effectively within Workday. This process is documented and staff are trained. Anticipated Completion Date: The underlying Workday system issue resulting in the COD disbursement file being rejected was internally resolved on August 28, 2024. The Fall 2024 update released by Workday in late-September/October 2024 corrected the system from the Workday side. The Systems Analyst receives an error when there is a rejected COD file, and the correction of these files is an ongoing process. Howard staff worked with the University’s Workday consultant to resolve the incorrect school code reported to COD, causing individual students’ disbursements to be rejected. This incorrect school code reported to COD was resolved for the 2025-2026 academic year by changing the configuration of disbursements to ignore any school codes other than 00144800. The Associate Director for Compliance sends a list of rejected loan disbursements to the Financial Aid Loans Team so these rejects can be worked on and resolved in 5-7 business days. The cost of attendance variance was identified in Fall 2025 and the change in the process when a student has a manual cost of attendance increase was implemented at that time as well. The compliance reviews for cost of attendance and COD reporting will take place twice per semester and any issues identified will be resolved to avoid future findings.

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Finding 1211212 (2025-009)

Material Weakness 2025

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Questioned Costs

FINDING 2025-009 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management Associate Director of Loans Systems Analyst, Enrollment Management Assistant Director for Compliance, Financial Aid Loan Coordinator Corrective Action: Beginning with the Fall 2024 semester, H...

FINDING 2025-009 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management Associate Director of Loans Systems Analyst, Enrollment Management Assistant Director for Compliance, Financial Aid Loan Coordinator Corrective Action: Beginning with the Fall 2024 semester, Howard University transitioned from using Ellucian Banner to Workday as the University’s ERP. As part of the transition to Workday, Howard spent several years configuring Workday to meet the needs of the institution and testing to ensure once the University went “live” in Fall 2024 there would be no configuration issues that affect compliance. Workday was not configured to send out Parent Plus Loans, therefore, Parent Plus notifications were as the result sent out as part of a manual process through the Financial Aid email box. Research into the issue and continued discussions with Workday consultants determined that Parent Plus disbursement notifications definitively cannot be sent out automatically after disbursement in Workday as a result of a flaw in Workday’s configuration capabilities. As a result, “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 through the Financial Aid Loans team email box. The three disbursement notifications that were not sent out within the 30-day timeline resulted from these Parent PLUS Loans not being shown on the “FA CR Parent PLUS Disbursement Notification” report. These disbursement notifications were originally sent to the student’s email address through Workday instead of being sent to the parent’s email address. While these disbursement notifications were sent timely, a compliance review of disbursement notifications discovered the Workday configuration was sending out some Parent PLUS Loan disbursement notifications to the student’s email address. This left the PLUS disbursement off the “FA CR Parent PLUS Disbursement Notification.” Upon discovery of this configuration error, the Loans Team worked with the University’s Workday consultant to prevent any Parent PLUS Loan disbursement notifications from being sent out through Workday. Bi-semester internal reviews by the Associate Director for Compliance in Enrollment Management are ongoing. The error with Parent PLUS Loan notifications being sent to the wrong individual in Workday was identified in the March 2025 disbursement notification compliance review. An August 2025 review of disbursement notifications for medical students resulted in there being no disbursement notifications found that were sent past the 30-day timeline and they were sent to the correct individuals. A September 2025 review of disbursement notifications was completed and resulted in enhancements to the mail merge template used to manually send out the Parent PLUS Loan disbursement notifications. An updated mail merge template was created, tested and implemented. A November 2025 disbursement notification review was completed to ensure the Parent PLUS notifications went out timely and to the parent’s email address. Anticipated Completion Date: The corrective action taken to prevent the Parent PLUS notifications from going out to the students in Workday was completed in March 2025. Monitoring and reviewing of loan disbursements have been ongoing to ensure the Workday system is correctly identifying and transmitting Direct Loan disbursements for Subsidized, Unsubsidized and Graduate PLUS Loans. Any significant issues are identified, documented and tracked until they are resolved. The Loan Coordinator is responsible for sending out the Parent Plus Loan notifications on a weekly basis and training has been provided to the designated individual who will perform this function in the absence of the Loan Coordinator.

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Finding 1211211 (2025-008)

Material Weakness 2025

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Questioned Costs

FINDING 2025-008 Names of Responsible Individuals: Manager Systems & Administration (Office of the Bursar) Associate Director for Compliance, Enrollment Management Associate Vice President for Finance and University Bursar Director of Cash Management, Treasury Operations Treasury Specialist Systems ...

FINDING 2025-008 Names of Responsible Individuals: Manager Systems & Administration (Office of the Bursar) Associate Director for Compliance, Enrollment Management Associate Vice President for Finance and University Bursar Director of Cash Management, Treasury Operations Treasury Specialist Systems Analyst, Enrollment Management Corrective Action: Beginning with the Fall 2024 semester, Howard University transitioned from using Ellucian Banner to Workday as the University’s ERP. The Bursar’s Office was not able to fully test the Title IV refunds process prior to "go live" due to the inability to disburse and create refunds to be sent to the University’s bank, JP Morgan. In August 2024, the Bursar’s Office identified configuration issues with JP Morgan where parents were not associated with students’ IDs and addresses in delivered refund files sent to JP Morgan Chase. These Title IV checks and direct deposits could not be sent to parents until JP Morgan completely migrated to Workday, in September 2024. After this date, there have not been issues with the JP Morgan Chase configuration with Workday. Workday is a date-driven ERP. Meal charges for Spring 2025 were placed on the students’ account, the due date for payment on the referenced meal charges was put in Workday as 12/23/2025 instead of 12/23/2024. This due date is when the charge is factored into the application of payments for the Office of the Bursar. The result was that housing charges were not being applied for the Spring 2025 semester until the error was discovered by the University during reconciliation. These meal charge dates were corrected to 12/23/2024 in March 2025. Internal controls have been created where there is a second level of review of due dates for charges placed on the students’ account. Due dates for charges during a semester are now reviewed by the Bursar and Housing to ensure the application of payments will pick up all charges for a semester. There are also continuing corrective actions being taken to best capture students who were eligible for a Title IV refund and deliver Title IV credit balances to students within the 14-day timeframe, including the use of reports available in Workday. Beginning with Fall 2025 semester, the on-demand “SF Refund Review Report” in Workday is used to identify students that are eligible for a Title IV refund. Howard University staff meet daily with Workday consultants from AVAAP to provide feedback and discuss any current issues experienced in Workday. The goal of these meetings is to have a constant flow of information on what is working effectively and what is not working effectively within Workday. There are also more Howard University staff focused on the Title IV credit balance process and more stages of approval required for the process to be completed. A list of Title IV credit balance refunds is captured from the “SF Refund Review Report,” the settlement run of refunds are reviewed by the refund approver in the Office of the Bursar, then the refund listing goes to the University Bursar for approval. After approval by the University Bursar the listing of students who will receive Title IV refunds by direct deposit and/or check is sent to the Treasury Specialist for approval. Once the Treasury Specialist approves the refunds, the Cash Manager approves the transmittal of this information to JP Morgan, and the funds are then transmitted to JP Morgan for delivery to parents and students. There has also been identification of a backup employee in the Bursar’s Office and Treasury responsible for the Title IV refund process. These backups have been trained so there is no disruption to the workflow, and they are currently running the Title IV credit balance delivery process when there is a workload balance need to do so to ensure timely refunds. Bi-semester internal reviews by the Associate Director for Compliance in Enrollment Management have taken place which complement the additional levels of review put in place by the Bursar. An internal review of 10 Title IV refunds sent to students for Summer 2025 was completed in July 2025. A review of 100 students who received refunds for Summer 2025 and Fall 2025 was completed in August 2025. All the students who received a refund for the Fall 2025 semester had their Title IV credit balance delivered timely. A review of 86 Title IV refunds for Fall 2025 completed in October 2025 showed that 0 students in the sample received their Title IV refund past the 14-day timeline. Anticipated Completion Date: Both issues which created the Title IV credit balance findings for FY25 have been identified and resolved. The issue with JP Morgan’s migration to Workday was identified and resolved during the Fall 2024 semester. The importance of due dates in Workday is now reinforced with a second level of staff members reviewing charge due dates in Workday. Additional steps have also been taken to ensure compliance with the 14-day credit balance delivery timeframe. The identification of the “SF Refund Review” report as the best report to capture Title IV credit balance information was completed in July 2025. The bi-semester reviews of continuing compliance with the 14-day timeline are ongoing and will continue to be used as a tool to identify any potential compliance issues. As of July 2025, there is identification of a backup employee in each office responsible for the Title IV refund process should there be employee turnover.

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Finding 1211205 (2025-007)

Material Weakness 2025

The Howard University

DC

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

FINDING 2025-007 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management AVP for Finance & Bursar Director of Student Billing and Engagement Associate Director for Compliance, Financial Aid Assistant Controller Director of Accounting Corrective Action: Federal Perk...

FINDING 2025-007 Names of Responsible Individuals: Associate Director for Compliance, Enrollment Management AVP for Finance & Bursar Director of Student Billing and Engagement Associate Director for Compliance, Financial Aid Assistant Controller Director of Accounting Corrective Action: Federal Perkins Loan program records are traditionally paper based, as a result, these school records can often be inconsistent. Due to inconsistent data transfer during Howard University’s move from Campus Partners to ECSI (Educational Computer Systems, Inc.) as the Perkins Loan servicer after the 2013-2014 academic year, the University’s Perkins disbursement data did not match the records Howard had from ECSI. In 2022, the University began to work with ECSI on converting the Howard internal records to match ECSI’s records. In mid-April 2026, ECSI notified Howard that the conversion of ECSI Perkins disbursement data to Howard disbursement data was complete. Currently, the adjustments ECSI made to match Howard are being reviewed by the Associate Director for Compliance in Enrollment Management, and feedback will be provided to ECSI. Matching Perkins Loan data between Howard and ECSI will strengthen the data consistency on the FISAP. The consistency of Perkins Loan data between ECSI and Howard University on the FISAP will also assist in strengthening internal controls for determination of the Cash on Hand amount. ECSI works with schools whose general ledger Cash on Hand does not match what is on the FISAP in Part III. It was conveyed by ECSI that it is more important to have awareness of what data does not match and why than to have parity. After the conversion of Perkins data from ECSI has been approved, the Associate Director for Compliance will meet with Director of Accounting to begin the process of reviewing Perkins wind-down procedures and the accounting related. Howard University is in the process of liquidating the Federal Perkins Program. Due to staffing changes, the Director of Student Billing and Engagement, is now responsible for the Federal Perkins Loan liquidation process. The University is working with ECSI and the Department of Education to complete the liquidation. As part of the liquidation process, the Director of Billing and Engagement contacted the Department of Education to determine the remaining steps for Perkins liquidation. 13 Perkins Loans remaining need to be assigned. Howard is in the process of determining if these loans can be assigned to ED or if the school will need to purchase them. Anticipated Completion Date: September 30, 2026, is the target date for the Federal Perkins Loan program to be completely liquidated at Howard University. All but 13 Federal Perkins Loans have been assigned, and the Bursar is working on sending credit balances to Accounts Payable for payment for those Perkins Loans that can be assigned. The conversion of ECSI records to match Howard internal records was completed in April 2026 and final will be completed by May 2026. Once the conversion is approved by Howard, the June 30, 2026 Perkins Annual Report from ECSI will match what Howard has in their Perkins records. This will enable this Perkins Annual Report to be used on the 2027-2028 FISAP due on September 30, 2026.

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Finding 1211199 (2025-006)

Material Weakness 2025

The Howard University

DC

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid

FINDING 2025-006 Name of Responsible Individual: Associate Provost AVP, Human Resources Senior Director of Payroll Corrective Action: The Offices of Undergraduate Studies, Financial Aid, Human Resources, and Payroll have worked to re-configure our Enterprise Resource Planning system, Workday, to sig...

FINDING 2025-006 Name of Responsible Individual: Associate Provost AVP, Human Resources Senior Director of Payroll Corrective Action: The Offices of Undergraduate Studies, Financial Aid, Human Resources, and Payroll have worked to re-configure our Enterprise Resource Planning system, Workday, to significantly reduce early time approval and minimize incorrect time attribution. We introduced new controls on May 7, 2025, and provided additional training throughout Academic Year 2024-2025. Although we have made much progress, we are still working to minimize FWS program risks. Specifically, we have noticed that retrofitting the staff and faculty hiring system may not be an ideal solution for handling the unique needs of the Federal Work Study program. As such, we are working with our official Workday partner to enact a distinct student hiring portal, that will also leverage Workday. We expect that this portal will be more nimble and better able to address FWS program management and controls. The expected launch date is Fall 2026. Anticipated Completion Date: December 31, 2026

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Finding 1211187 (2025-001)

Material Weakness 2025

Syntiro

ME

Allowable Costs / Cost Principles Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303 § 200.403 § 200.414

We agree with the finding and will review and implement the recommendations accordingly. We are committed to ensuring proper application of indirect costs, avoiding duplication of costs across reporting periods, and maintaining compliance with allocability requirements under Uniform Guidance on a pr...

We agree with the finding and will review and implement the recommendations accordingly. We are committed to ensuring proper application of indirect costs, avoiding duplication of costs across reporting periods, and maintaining compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan will be implemented by June 30, 2026.

View Audit 400399

Finding 1211186 (2025-002)

Material Weakness 2025

Iowa Falls Community School District

IA

Internal Control / Segregation of Duties

We understand the importance of maintaining strong internal controls and acknowledge the concerns related to segregation of duties. Given our limited staffing levels, full segregation is not always practical. However, we have established compensating controls, including enhanced supervisory oversigh...

We understand the importance of maintaining strong internal controls and acknowledge the concerns related to segregation of duties. Given our limited staffing levels, full segregation is not always practical. However, we have established compensating controls, including enhanced supervisory oversight, routine transaction reviews, and board-level monitoring when appropriate. Following a mid-year retirement, we reassessed and updated our internal procedures to strengthen controls and improve segregation of duties where feasible. We will continue to explore additional ways to address this challenge.

View Audit 400390

Finding 1211182 (2025-001)

Material Weakness 2025

International Fresh Produce Association

DC

Cash Management Internal Control / Segregation of Duties

While it may be impractical to request a cash reimbursement monthly due to the lag in receivingtimely invoices from sub-awardees and/or contractors, the review and computation of submitted hours confirmed and recalculated as specified within each of the different grant guidelines, Management will be...

While it may be impractical to request a cash reimbursement monthly due to the lag in receivingtimely invoices from sub-awardees and/or contractors, the review and computation of submitted hours confirmed and recalculated as specified within each of the different grant guidelines, Management will begin after 3/31/2026: 1) Request cash reimbursement monthly where practical and underlying support has been received timely and substantiated, staff hours submitted and approved; or 2) Request cash reimbursement no greater than quarterly for those same expenses as specified in #1.

View Audit 400376

Finding 1211169 (2025-003)

Material Weakness 2025

Wesleyan College

GA

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.512

The auditee will finalize and submit future Single Audit reporting packages within the Uniform Guidance deadlines and will periodically review compliance procedures as part of its internal control monitoring activities.

View Audit 400359

Finding 1211164 (2025-002)

Material Weakness 2025

Wesleyan College

GA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

All donor‑restricted balances were reviewed to identify instances where restrictions had been satisfied but not released timely. Required releases were recorded to correct net asset classifications in the general ledger. Where available, supporting documentation (e.g., expenditure reports, grant ter...

All donor‑restricted balances were reviewed to identify instances where restrictions had been satisfied but not released timely. Required releases were recorded to correct net asset classifications in the general ledger. Where available, supporting documentation (e.g., expenditure reports, grant terms, and donor agreements) was acquired and reviewed to substantiate the timing of releases. Management plans to enhance controls over donor restriction tracking by implementing clearer procedures for identifying restriction satisfaction, improving cross-department communication, and strengthening review controls to ensure timely and accurate recording of donor restriction releases. Auditor’s Evaluation of the Corrected Action Plan: Wesleyan College’s response was appropriate for immediate remediation for the current affected period. Furthermore, the plan for preventative actions appears to be appropriately focused to achieve timely and documented of releases related to satisfied purpose or time conditions.

View Audit 400359

Finding 1211159 (2025-001)

Material Weakness 2025

Wesleyan College

GA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

Wesleyan College management has completed all outstanding reconciliations for the affected periods. Reconciling items noted during the delayed reconciliations were reviewed, investigated, and resolved or appropriately aged and documented. Evidence of supervisory review has been added to completed re...

Wesleyan College management has completed all outstanding reconciliations for the affected periods. Reconciling items noted during the delayed reconciliations were reviewed, investigated, and resolved or appropriately aged and documented. Evidence of supervisory review has been added to completed reconciliations where missing. Management is in the process of developing and implementing remediation and preventative actions, including strengthening reconciliation policies, assigning clear ownership and escalation procedures, and implementing monitoring controls to ensure reconciliations are prepared and reviewed timely. These actions are expected to improve the effectiveness of controls over material account balance reconciliations. Auditor’s Evaluation of the Corrected Action Plan: Wesleyan College’s response was appropriate for immediate remediation for the current affected period. Furthermore, the plan for preventative actions appears to be appropriately focused to ensure reconciliations are prepared and reviewed timely.

View Audit 400359

Finding 1211073 (2025-004)

Material Weakness 2025

City of West Melbourne, Florida

FL

Questioned Costs Reporting Matching / Level of Effort / Earmarking § 200.303

2025-004 Reporting Recommendation: The City should review the underlying data along with the report to ensure that report agrees with the support and the underlying data is correct. Corrective Action: Management recognizes the importance of accurate and complete reporting to the U.S. Treasury. While...

2025-004 Reporting Recommendation: The City should review the underlying data along with the report to ensure that report agrees with the support and the underlying data is correct. Corrective Action: Management recognizes the importance of accurate and complete reporting to the U.S. Treasury. While procedures were in place, the review of underlying data was not sufficient to ensure accuracy and completeness prior to submission. The issue was limited to a single report and was corrected in the subsequent U.S. Treasury reporting cycle in accordance with program requirements. To prevent recurrence, management has enhanced its review procedures over grant reporting to include reconciliation of underlying data and validation checks for inconsistencies prior to report submission. Additionally, a secondary level of review will be performed to ensure reports are complete and accurate before submission to the U.S. Treasury. Responsible Parties: B. Keith Smith, Finance Director Anticipated Correction Date: September 30, 2026

View Audit 400324

Finding 1211036 (2025-001)

Material Weakness 2025

Hui No Ke Ola Pono, Inc.

HI

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

2025-001-Internal Control over Financial Reporting, Health Resources and Services Administration Native Hawaiian Health Care 93.932, Significant adjusting journal entries, Due to lack of fiscal staff and high turnover, the organization fell behind on audits, and therefore, many adjusting entries wer...

2025-001-Internal Control over Financial Reporting, Health Resources and Services Administration Native Hawaiian Health Care 93.932, Significant adjusting journal entries, Due to lack of fiscal staff and high turnover, the organization fell behind on audits, and therefore, many adjusting entries were required to reconcile accounts. The audits have been completed, and all accounts have been reconciled as of July 31, 2025. In addition to the high turnover, during fiscal year ending 2024, there was an increase in donor funding to assist with the Lahaina wildfires recovery efforts. Again, our staff were challenged to meet the demands of the requirements of the funding and to continue to monitor the previous and current fiscal years financial state.

View Audit 400320

Finding 1211028 (2025-002)

Material Weakness 2025

Housing Authority of New Orleans

LA

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

The Housing Authority of New Orleans (HANO) acknowledges the finding related to the inability to provide documentation supporting the waiting list selection for certain admissions tested during the audit. The Authority's review indicates that the issue was primarily related to the accessibility of d...

The Housing Authority of New Orleans (HANO) acknowledges the finding related to the inability to provide documentation supporting the waiting list selection for certain admissions tested during the audit. The Authority's review indicates that the issue was primarily related to the accessibility of documentation during the transition from physical files to a digital file management system rather than a failure to follow established waiting list selection procedures. HANO maintains policies and procedures requiring that applicants be selected from the waiting list in accordance with the Authority's Administrative Plan and HUD regulations. HANO will review the admissions identified in the audit sample and locate or reconstruct supporting documentation where available. In addition, the Authority will conduct an internal review of additional admissions files to confirm that waiting list selection procedures were followed and that documentation is properly maintained. To prevent recurrence, HANO will strengthen internal controls by implementing standardized documentation requirements for voucher issuance, reinforcing staff training regarding waiting list selection procedures, and conducting periodic quality control reviews of admissions files to ensure documentation supporting waiting list selection is complete and accessible. HANO will also ensure that documentation associated with waiting list selection is properly retained within the Authority's digital file management system following the ongoing file digitization process. Responsible Party: Ashley Dennis, Director Implementation Timeline: Start Date: March 30, 2026 Completion Date: May 18, 2026

View Audit 400305

Finding 1211022 (2025-002)

Material Weakness 2025

School Nutrition Prog of the Archdiocese of La Education & Welfare Cor

CA

Internal Control / Segregation of Duties Questioned Costs Eligibility § 200.302 § 200.333

Recommendation: We recommend the SNP reviews its internal controls and policies to ensure all students receiving benefits have an application, or other supporting documentation, on file to support their eligibility. Action taken in response to finding: Management acknowledges the finding and will re...

Recommendation: We recommend the SNP reviews its internal controls and policies to ensure all students receiving benefits have an application, or other supporting documentation, on file to support their eligibility. Action taken in response to finding: Management acknowledges the finding and will revise and formalize internal controls as follows: • Eligibility Documentation Procedures: Develop a standardized checklist to confirm required documentation is obtained, reviewed and retained prior to approval. • Centralize Review and Approval Process: A designated reviewer will be responsible for verifying completeness and accuracy of all eligibility determinations. Approval will be formally documented. • Record Retention Controls: Management will establish controls to ensure that all eligibility documentation is: Properly maintained, readily accessible for audit or review and retained in accordance with federal, state and organization-wide policy. • Personnel Training: Training will be conducted annually and upon onboarding new personnel. Name of the contact person responsible for corrective action: Sean Jernigan, Chief of Operational Vitality, Department of Catholic Schools, Archdiocese of Los Angeles Planned completion date for corrective action plan: • Procedure and checklist implementation: Within 30 days of financial statement issuance • Staff training: Within 60 days of financial statement issuance • Full implementation and evidence of operation: 90 days of financial statement issuance

View Audit 400300

Finding 1211018 (2025-003)

Material Weakness 2025

YWCA West Central Michigan

MI

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.328 § 200.329

Our program leadership are playing a more active role in reporting and compliance and are actively involving directors of programs in the process of reporting.

View Audit 400298

Finding 1211006 (2025-005)

Material Weakness 2025

CITY OF CAMERON

WV

Questioned Costs Reporting Internal Control / Segregation of Duties

2025-05 Uniform Guidance Audit Submission Nichole Bryan March 24, 2027 View of Responsible Officials and Corrective Action Plan Taken: The City will work to develop and adopt controls to ensure that the year-end financial statements are prepared in a timely manner so as to facilitate a timely audit ...

2025-05 Uniform Guidance Audit Submission Nichole Bryan March 24, 2027 View of Responsible Officials and Corrective Action Plan Taken: The City will work to develop and adopt controls to ensure that the year-end financial statements are prepared in a timely manner so as to facilitate a timely audit submission as set forth in the Uniform Guidance.

View Audit 400297

Corrective Action Plans

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