Corrective Action Plans

Finding 1191583 (2025-005)

Material Weakness 2025

PR

Questioned Costs Subrecipient Monitoring Reporting § 200.302 § 200.328 § 200.329

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordan...

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Finance Director Phone: (787) 788-0404 Original Finding Number: 2025-005 Statement of Concurrence or Nonconcurrence: We concur we the finding. Corrective Action: Adopted Measures • Expense Synchronization: A protocol will be implemented requiring contracted consultants to record and report incurred expenses only when a validated disbursement voucher is available, thereby ensuring the integrity of the financial flow. • Reconciliation: The office will conduct a detailed comparison between the draft quarterly report and the general ledger to identify and correct any discrepancies prior to final submission. • Compliance Timeline: An internal deadline will be established for the submission of the report, ensuring attainment of the minimum percentage required under the Quality Activities category through accurate financial data. Expected Outcome To ensure that all financial information submitted is complete, accurate, and fully aligned with the Municipality’s accounting records, thereby eliminating the risk of audit findings. Implementation Date: March 2026. Responsible persons: • Person responsible for the implementation: Mr. Carlos Flores, Federal Program’s Subdirector • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director

View Audit 395450

Finding 1191580 (2025-002)

Material Weakness 2025

Municipality of Catano

PR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.1

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordan...

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Finance Director Phone: (787) 788-0404 Original Finding Number 2025-002 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: Objective of the plan: The objective of this Corrective Action Plan is to address the observations identified in the audit and establish preventive measures to avoid future recurrences. Corrective Actions: 1. Schedule restructuring: • Create a detailed calendar with clear dates to define intermediate delivery deadlines to avoid delays (collection of information, analysis, writing, review, and submission) 2. Implementation of alerts and reminders: • Set up automatic alerts and email reminders for key dates (for example, 3 days before each deadline) 3. Review and Quality Control: Establish an internal review of reports before final submission to ensure that the information reported is accurate and complete. The revision includes compliance with the requirements established by the agency. Compliance Monitoring: • Biweekly meetings: The team will have biweekly meetings to have updates regarding the progress and achievement of the deadlines. • Email notifications: Emails will be sent to document the timely submission of reports and when needed, waivers will be requested explaining situations that may have delayed the process to prepare accurate and complete reports on time. Evaluation: • Monthly evaluations will be performed to measure the compliance of the submission of the reports on the timeframe established by the agency. • Adjustments to the processes according to the response of the team. Implementation Date: Fiscal Year 2025-2026. Responsible persons: • Person responsible for the implementation: Mr. Carlos Flores, Federal Program’s Subdirector • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director

View Audit 395450

Finding 1191568 (2025-006)

Material Weakness 2025

PROJECT WORTHMORE

CO

Internal Control / Segregation of Duties Questioned Costs HUD Housing Programs § 200.303

Management will implement a formal review and approval process for Federal reporting to ensure compliance with 2 CFR 200.303. • Review Process: Establish standardized procedures for preparation, review, and submission of Federal reports. • Roles and Responsibilities: Assign responsibility for prepar...

Management will implement a formal review and approval process for Federal reporting to ensure compliance with 2 CFR 200.303. • Review Process: Establish standardized procedures for preparation, review, and submission of Federal reports. • Roles and Responsibilities: Assign responsibility for preparation and independent review of reports. • Documented Approval: Require documented evidence of review and approval. • Supporting Documentation: Ensure all reported amounts are supported by underlying records and reconciliations. • Training: Prior to next Federal Grant requiring a single audit, provide training on Federal reporting requirements and internal control expectations.

View Audit 395436

Finding 1191566 (2025-002)

Material Weakness 2025

Tasc, Inc.

IL

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.309

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND OTHER MATTERS U.S. Department of Justice 2025-002 Department of Justice Second Chance Act Community-based Reentry Program – Assistance Listing No. 16.812 Recommendation: We recommend that TASC follow its established procedures for chargi...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND OTHER MATTERS U.S. Department of Justice 2025-002 Department of Justice Second Chance Act Community-based Reentry Program – Assistance Listing No. 16.812 Recommendation: We recommend that TASC follow its established procedures for charging allowable expenses to the grant during the period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will follow established procedure to make sure costs are recorded in the proper period. Management will review the procedure with all accounting staff. Name(s) of the contact person(s) responsible for corrective action: Roy Fesmire, CFO Planned completion date for corrective action plan: June 30, 2026

View Audit 395434

Finding 1191565 (2025-001)

Material Weakness 2025

Tasc, Inc.

IL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.414

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE U.S. Department of Justice 2025-001 Department of Justice Second Chance Act Community-based Reentry Program – Assistance Listing No. 16.812 Recommendation: We recommend that TASC follow its established procedures for segregation of duties ov...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE U.S. Department of Justice 2025-001 Department of Justice Second Chance Act Community-based Reentry Program – Assistance Listing No. 16.812 Recommendation: We recommend that TASC follow its established procedures for segregation of duties over the calculation of indirect cost allocations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will follow established procedure to make sure that segregation of duties over the calculation of indirect cost allocations is properly documented. Management will review the procedure with all accounting staff. Name(s) of the contact person(s) responsible for corrective action: Roy Fesmire, CFO Planned completion date for corrective action plan: June 30, 2026

View Audit 395434

Finding 1191562 (2025-012)

Material Weakness 2025

Leech Lake Tribal College

AZ

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid

The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

View Audit 395432

Finding 1191558 (2025-010)

Material Weakness 2025

Leech Lake Tribal College

AZ

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid

The College will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

View Audit 395432

Finding 1191554 (2025-008)

Material Weakness 2025

Leech Lake Tribal College

AZ

Questioned Costs Student Financial Aid Eligibility

Annual performance reports will be submitted on time as required by the funding agency. Management has developed a comprehensive listing of all reporting requirements and will utilize this information to ensure all reporting requirements are met.

View Audit 395432

Finding 1191552 (2025-007)

Material Weakness 2025

Leech Lake Tribal College

AZ

Questioned Costs Student Financial Aid Eligibility

Management will provide additional resources to the Financial Aid department to include training and assistance and will implement verification procedures to ensure that amounts awarded are accurate.

View Audit 395432

Finding 1191540 (2025-003)

Material Weakness 2025

Leech Lake Tribal College

AZ

Internal Control / Segregation of Duties Questioned Costs Material Weakness

The College has implemented IT and DATA governance policies. Additionally, data backup processes have been implemented, and a Disaster Recovery Plan is being developed.

View Audit 395432

Finding 1191534 (2025-002)

Material Weakness 2025

Community Health Law Project, Inc.

NJ

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Internal Control over Compliance and Other Matters FEDERAL: United States Department of the Treasury Ocean ARPA (State and Local Fiscal Relief) -Assistance Listing No. 21.027 STATE: New Jersey Department of Human Services Division of Mental Health and Addiction Services System Advocacy and Division ...

Internal Control over Compliance and Other Matters FEDERAL: United States Department of the Treasury Ocean ARPA (State and Local Fiscal Relief) -Assistance Listing No. 21.027 STATE: New Jersey Department of Human Services Division of Mental Health and Addiction Services System Advocacy and Division of the Deaf and Hard of Hearing Recommendation: We recommend that management implement automated payroll and timekeeping systems to reduce reliance on manual calculations. Additionally, formal review procedures should be established to ensure that all manual entries are verified for accuracy and compliance prior to posting. There is no disagreement with the audit finding. Action taken in response to finding: CHLP management acknowledges the deficiency and is evaluating options for automating payroll processes. In the interim, additional review steps will be introduced to mitigate the risk of errors. Name of the contact person responsible for corrective action: James Lorenz, Financial Administrator Planned completion date for corrective action plan: This corrective action plan is effective immediately.

View Audit 395427

Finding 1191530 (2025-009)

Material Weakness 2025

City of Montgomery, Alabama

AL

Questioned Costs Subrecipient Monitoring Material Weakness § 200.303 § 200.328

Management concurs. The City will strengthen its policies and procedures over the grant reporting process to ensure that the review and approval of federal reports is documented. This will be implemented by September 2026.

View Audit 395426

Finding 1191479 (2025-001)

Material Weakness 2025

Housing Authority of the City of Westwego, Louisiana

LA

Material Weakness Reporting Internal Control / Segregation of Duties

FINDING 2025 001 — MATERIAL WEAKNESS — CONTROLS OVER GRANT ACCOUNTING, YEAR END CLOSING, AND FINANCIAL REPORTING Contact Person: Cantrese Wilson Jones, Executive Director Corrective Action Planned: The Housing Authority will implement a formal, documented monthly and year end closing calendar that i...

FINDING 2025 001 — MATERIAL WEAKNESS — CONTROLS OVER GRANT ACCOUNTING, YEAR END CLOSING, AND FINANCIAL REPORTING Contact Person: Cantrese Wilson Jones, Executive Director Corrective Action Planned: The Housing Authority will implement a formal, documented monthly and year end closing calendar that includes required reconciliation deadlines, supervisory review steps, and documentation standards. Grant activity will be reconciled monthly, and financial reporting schedules will be completed prior to auditor arrival. Internal review procedures will be strengthened to ensure the timeliness and accuracy of journal entries, reconciliations, and SEFA related information. Anticipated Completion Date: June 30, 2026 Management Response: Management concurs with the finding. The Authority will implement a structured closing calendar and improve grant related reconciliations beginning in FY 2026.

View Audit 395397

Finding 1191467 (2025-003)

Material Weakness 2025

Montcalm Community College

MI

Questioned Costs Student Financial Aid Reporting

Fiscal Operations Report and Application to Participate (FISAP) Reporting Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items (information on eligible aid applicants) identified in the com...

Fiscal Operations Report and Application to Participate (FISAP) Reporting Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items (information on eligible aid applicants) identified in the compliance supplement as critical information. As a result, the College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Auditor Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. Corrective Action. The College is improving its documentation and retention processes to ensure all information used in preparing the annual FISAP report is fully supported and available for review. Moving forward, all data underlying the eight key line items identified in the compliance supplement will be saved, documented, and stored in a consistent and accessible manner. Information obtained from other departments will be retained in its original format, and any data extracted from PowerFAIDS or related systems will be saved at the time of report preparation. By implementing these documentation and retention procedures as standard operating practice, the College ensures FISAP submissions are accurate, verifiable, and compliant with federal audit requirements. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026

View Audit 395393

Finding 1191373 (2025-006)

Material Weakness 2025

Langston University

OK

Questioned Costs Student Financial Aid Significant Deficiency § 200.303

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds ar...

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is evaluating its current Title IV funds procedures and implementing additional procedures to ensure timely return of refunds. This includes assigning additional staff to manage this process. Also, relevant staff have been reminded of the need to notify Financial Aid of student withdrawals timely. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid Planned completion date for corrective action plan: March 2026

View Audit 395389

Finding 1191337 (2025-004)

Material Weakness 2025

Langston University

OK

Questioned Costs Eligibility Significant Deficiency § 200.303

Student Financial Aid Cluster: TEACH Grant – Assistance Listing No. 84.379 Recommendation: We recommend the University review and update current procedures to ensure that students meet eligibility requirements prior to receiving the TEACH Grant. Explanation of disagreement with audit finding: There ...

Student Financial Aid Cluster: TEACH Grant – Assistance Listing No. 84.379 Recommendation: We recommend the University review and update current procedures to ensure that students meet eligibility requirements prior to receiving the TEACH Grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated procedures to ensure verification of student GPA prior to disbursement of TEACH Grant funding. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid and Ms. Courtney Youngblood, Assistant Director of Financial Aid Planned completion date for corrective action plan: September 2025

View Audit 395389

Finding 1191227 (2025-004)

Material Weakness 2025

Isd # 13 Columbia Heights

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Questioned Costs § 200.318

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-004 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Findi...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-004 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Bryan Hennekens, Director of Finance and Operations. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Bryan Hennekens, Director of Finance and Operations, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

View Audit 395377

Finding 1191219 (2025-006)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Finding Reference 2025-06 Corrective Action Plan: To strengthen internal controls, improve monitoring, and reduce delays in the certification and payment process, the Authority will implement the following operational improvements: The Authority is using the Finance Office Dashboard to track the sta...

Finding Reference 2025-06 Corrective Action Plan: To strengthen internal controls, improve monitoring, and reduce delays in the certification and payment process, the Authority will implement the following operational improvements: The Authority is using the Finance Office Dashboard to track the status of certifications and invoices in real time, identify bottlenecks in the approval process, and support proactive management of pending payments. A standardized Construction Certification Compliance Checklist will be used to validate all required federal compliance documentation before certifications are submitted to the Finance Office. This measure is expected to reduce the number of returned submissions and prevent delays during the billing review process. The Authority will develop a Help Desk platform for certification and invoice inquiries to formally manage, document, and track inquiries or claims related to Construction Certifications and Pre- Construction invoices, improving transparency and response times. The Authority will launch the ICMM Payment Tracking Table to consolidate and monitor the payment status of certifications and invoices. Additionally, the Authority is establishing intermediate milestones to progressively reduce the payment processing cycle, with the objective of moving from the current 40-day average toward the 30-day target. As part of this initiative, the Authority is expanding the use of the Project Management Information System (PMIS) to standardize and streamline the processing of construction certifications and payment documentation. Responsible: Mr. Angel M. Felix Cruz, Acting Director, Confidential Finance Office Planned Implementation Date: In process. The first operational improvement has been implemented. The remaining three measures are pending implementation. Expected to be completed on or before June 30, 2026.

View Audit 395336

Finding 1191218 (2025-005)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Subrecipient Monitoring Internal Control / Segregation of Duties Questioned Costs

Finding Reference 2025-05 Corrective Action Plan: The Authority implemented the following actions in March 2026 to ensure compliance with the Davis-Bacon Act and strengthen payroll certification process: On March 11, 2026, all personnel of the Construction Office receive adequate training on Davis-B...

Finding Reference 2025-05 Corrective Action Plan: The Authority implemented the following actions in March 2026 to ensure compliance with the Davis-Bacon Act and strengthen payroll certification process: On March 11, 2026, all personnel of the Construction Office receive adequate training on Davis-Bacon Act requirements and payroll certification processes. On March 20, 2026, the Authority prepared a formal communication to reinforce the compliance with the Davis Bacon Act and to provide updated forms and instructions for completing certification payroll process. On March 3, 2026, the Authority contracted external consultants to enhance monitoring procedures over contractors and subcontractors, including timeliness tracking of properly certified payroll on a weekly basis and follow-up on missing or incomplete documentation Responsible: Mr. Emilio Garay, PE, Construction Office Director Planned Implementation Date: In process. Expected to be completed on or before June 30, 2026.

View Audit 395336

Finding 1191216 (2025-003)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Internal Control / Segregation of Duties Subrecipient Monitoring Questioned Costs

Finding Reference 2025-03 Corrective Action Plan: The Authority has assigned an Analyst and a Supervisor the responsibility of monitoring compliance with all federal requirements related to the reporting process of these funds. In addition, an adequate training will be provided to the personnel invo...

Finding Reference 2025-03 Corrective Action Plan: The Authority has assigned an Analyst and a Supervisor the responsibility of monitoring compliance with all federal requirements related to the reporting process of these funds. In addition, an adequate training will be provided to the personnel involved in the administration of this program. The Authority has also implemented the following procedure to ensure accurate financial reporting and supervision: The Analyst will prepare the reports in accordance with the work plan and submit them to the Supervisor for review and approval. The Supervisor will review the reports and will send an email confirming the approval. Once approved, the Analyst will send the reports to the pass though entity. Responsible: Mrs. Johanna Perez Falcon, Acting Director of the Office of Budget Planned Implementation Date: Completed.

View Audit 395336

Finding 1191215 (2025-002)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Reporting Internal Control / Segregation of Duties § 200.510

Finding Reference 2025-02 Corrective Action Plan: The Designated Office responsible for processing federal funds received through state agencies will deliver to the Finance Office a transaction list and a reconciliation of the disbursements made during the fiscal year. The Finance Office will review...

Finding Reference 2025-02 Corrective Action Plan: The Designated Office responsible for processing federal funds received through state agencies will deliver to the Finance Office a transaction list and a reconciliation of the disbursements made during the fiscal year. The Finance Office will review all transactions recorded during the current fiscal year and will prepare an accrual entry. These transactions will be reconciled against the transactions recorded during the subsequent fiscal year to confirm that funds were recorded in the appropriate fiscal period. The review and recording of these transactions will be completed during the final phase of the accounting closing process and prior to delivery of the Trial Balance to the external auditors. Responsible: Ms. Maria Del R. Ramos Ocasio, Accounting and Finance Manager Planned Implementation Date: In process. Expected to be completed on or before September 30, 2026.

View Audit 395336

Finding 1191208 (2025-002)

Material Weakness 2025

Concordia University Chicago

IL

Questioned Costs Student Financial Aid Reporting

2025-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with au...

2025-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) All enrollment reporting was submitted to the National Student Clearinghouse in a timely manner. The delay occurred during the National Student Clearinghouse’s processing and submission to NSLDS. 2) The Office of the Registrar will work with the Office of Financial Aid to learn more about NSLDS compliance requirements and gain a better understanding of their relationship with the National Student Clearinghouse. 3) The Office of the Registrar will work with the National Student Clearinghouse to confirm the submitted reporting schedule for academic year 2026 – 2027 complies with and meets their expectations and will adjust (if needed). 4) The Office of the Registrar will continue to work with the Enrollment Offices to remind them that students who are not enrolled (and not on leave of absence, graduated, and/or deceased) must be marked as withdrawn based on external reporting compliance requirements. 5) The Office of the Registrar continues to work with IT (Banner Team) to improve reporting to capture students who are not enrolled (and not on leave of absence, graduated, and/or deceased) to be marked as withdrawn to comply with the National Student Clearinghouse and NSLDS compliance reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Ingrid Sorensen, Katarzyna Rodriguez Planned completion date for corrective action plan: June 30, 2026

View Audit 395330

Finding 1191202 (2025-001)

Material Weakness 2025

Concordia University Chicago

IL

Questioned Costs Student Financial Aid Eligibility

2025-001 Pell Grant Under Award Recommendation: We recommend the University implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit ...

2025-001 Pell Grant Under Award Recommendation: We recommend the University implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The Office of Financial Aid will continue to run monthly or bi-monthly enrollment reports for Pell Grant recipients to ensure awards are accurately determined based on enrollment status. 2) Financial Aid Counselors will continue to review the daily and weekly Hour Change Reports for each payment period to ensure Pell Grant awards are adjusted appropriately in response to enrollment status changes. 3) The Director and Assistant Director of Financial Aid will continue providing Banner (student information system) training to staff to ensure Pell Grant amounts are updated accurately within the system. Name(s) of the contact person(s) responsible for corrective action: Vanesa Teran-Martinez, Jennifer Monroy Planned completion date for corrective action plan: June 30, 2026

View Audit 395330

Finding 1191138 (2025-001)

Material Weakness 2025

Antioch University

OH

Special Tests & Provisions Questioned Costs Student Financial Aid

Corrective Action Taken or Planned: A. Correction of "Day After" Reporting Logic The University previously identified a practice where the withdrawal (W) status was made effective the day following the student's notification. ● Process Update: This process was officially updated in April 2025 to ali...

Corrective Action Taken or Planned: A. Correction of "Day After" Reporting Logic The University previously identified a practice where the withdrawal (W) status was made effective the day following the student's notification. ● Process Update: This process was officially updated in April 2025 to align with the regulation, ensuring the withdrawal start date and the date of official notification are the same. The three findings all occurred prior to the April adjustment. ● Ongoing Diligence: The Registrar’s team is actively monitoring current and future records to ensure this logic is applied consistently going forward. B. Reporting Withdrawal Dates for Late-Term Requests To address students reported as withdrawn on the last day of the term rather than their actual date of request: ● Manual Tracking: For students who request a withdrawal between the official University withdrawal deadline and the end of the term, the Financial Aid Office will create a new process where they track students needing NSC manual corrections and share that information with the RO Team member doing the NSC reporting. ● NSC Overrides: The NSC reporting processor will utilize this information to perform manual date changes for these students, ensuring the reported date reflects the official date of notification rather than the term end date. C. Correlation of Withdrawal Date and Last Date of Attendance (LDA) To address findings where withdrawal dates did not correlate with the LDA: ● Faculty LDA Requirement: Although the University is a non-attendance-taking institution, a new requirement has been implemented for faculty to enter the Last Date of Attendance (LDA) for any student receiving a non-passing grade. ● Reporting Sync: The latest of the reported LDAs will be used by both the Financial Aid office (for calculations) and the NSC processor (for reporting) if a student is withdrawing from the University for the subsequent term and the student received all non-passing grades in the prior term. The Financial Aid office will notify the Registrar’s office if there are students with no passing grades and a LDA prior to the official withdrawal date to update their withdrawal date to match that LDA. ● Verification Workflow: The Registrar’s office will verify withdrawal information with the student, including the notification date, to ensure accuracy before manual NSC corrections are made. D. Internal Audit and Collaborative Controls To prevent recurrence and ensure compliance with federal reporting timelines: ● Collaborative Review: The Registrar and the Executive Director of Financial Aid & Scholarships will meet on a recurring basis to jointly review enrollment reporting procedures and ensure data alignment. ● Spot Checks: An internal audit process has been implemented to spot-check each submission file to verify that enrollment and withdrawal dates are accurate. The shared spreadsheet of manual dates will also be checked to ensure those dates are being changed. ● Petition and Request Review: The Registrar Team will carefully review all petitions and requests to determine which date to use as the original notification. ________________________________________ Person(s) Responsible for Corrective Action: University Registrar and Executive Director of Financial Aid & Scholarships. ________________________________________ Anticipated Completion: June 30, 2026 ________________________________________

View Audit 395313

Finding 1191129 (2025-001)

Material Weakness 2025

Dekalb County Board of Education

GA

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting § 200.303 § 200.403 § 200.430

Despite the high overall accuracy rate, the District is taking immediate steps to address identified compensation and documentation issues. We have corrected pay scale deficiencies to ensure employees receive proper compensation and implemented additional review controls to prevent future errors. We...

Despite the high overall accuracy rate, the District is taking immediate steps to address identified compensation and documentation issues. We have corrected pay scale deficiencies to ensure employees receive proper compensation and implemented additional review controls to prevent future errors. We have also strengthened our account coding procedures to ensure compensation charges are applied to the appropriate funding sources. Additionally, we have updated our digital time-tracking approval workflow to require contemporaneous authorization and improve documentation retention for all supplemental and retrospective compensation. Estimated Completion Date: March 31, 2026 Contact Person: Byron Schueneman, Chief Financial Officer

View Audit 395301

Corrective Action Plans

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