Corrective Action Plans

Finding 1175788 (2025-009)

Material Weakness 2025

Albright College

PA

Student Financial Aid Reporting Internal Control / Segregation of Duties

Name of Responsible Individual: Ransom Prestridge, Registrar; Jennifer Wegman, Assistant Registrar; Kai Howard, Institutional Research; Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the findings related to the timeliness and accuracy of enrollment reporting to th...

Name of Responsible Individual: Ransom Prestridge, Registrar; Jennifer Wegman, Assistant Registrar; Kai Howard, Institutional Research; Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the findings related to the timeliness and accuracy of enrollment reporting to the National Student Loan Data System (NSLDS). The identified exceptions were the result of insufficient administrative oversight and internal controls related to enrollment status reporting at both the campus and program levels. As this is a repeat finding, the College is committed to implementing enhanced and sustainable corrective measures. To address this finding, the College will strengthen internal controls and oversight of enrollment reporting by implementing the following corrective actions: • Establish a documented review and monitoring process to ensure all enrollment status changes, including graduation, withdrawal, attendance level changes, and second majors, are accurately and timely reported to NSLDS at both the campus and program levels. • Implement a standardized tracking and reconciliation process between the Registrar’s Office, the Student Information System, and NSLDS to ensure data consistency and completeness. • Develop and implement written policies and procedures that clearly define roles, responsibilities, timelines, and escalation protocols for enrollment reporting. • Enhance oversight of any third-party servicer, including periodic validation of submitted records to ensure accuracy and timeliness. • Provide comprehensive training to staff responsible for enrollment reporting on federal regulatory requirements and institutional procedures. • Conduct periodic internal quality assurance reviews and monitoring of enrollment reporting to identify and correct discrepancies in a timely manner. • Establish formal communication protocols between the Financial Aid and Registrar’s Offices to ensure timely notification of all enrollment changes. Anticipated Completion Date: May 31, 2026

View Audit 389689

Finding 1175786 (2025-008)

Material Weakness 2025

Albright College

PA

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

Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the exceptions identified related to the timeliness of Return of Title IV (R2T4) calculations and the return of unearned federal funds. The errors were the result of insufficient admini...

Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the exceptions identified related to the timeliness of Return of Title IV (R2T4) calculations and the return of unearned federal funds. The errors were the result of insufficient administrative oversight and internal controls over the withdrawal and R2T4 process. To address this finding, the College will strengthen internal controls and oversight to ensure compliance with federal regulations. The corrective actions include: • Implementing a documented secondary review process for all R2T4 calculations prior to finalization to ensure accuracy and compliance with regulatory requirements. • Enhancing procedures to ensure timely identification of withdrawn students and prompt initiation of the R2T4 calculation process. • Establishing standardized monitoring to ensure all required returns of Title IV funds are processed within the regulatory timeframe. • Developing and implementing a tracking system to monitor withdrawal dates, calculation completion, and return deadlines. • Providing additional training to Financial Aid staff on federal R2T4 regulations and institutional procedures. • Conducting periodic internal quality assurance reviews of R2T4 calculations and returned funds to ensure ongoing compliance. Anticipated Completion Date: May 31, 2026

View Audit 389689

Finding 1175783 (2025-007)

Material Weakness 2025

Albright College

PA

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

Name of Responsible Individual: Larry Bomback, Interim CFO / DeMornai Blackwell, Controller Corrective Action: Management acknowledges the instances in which Title IV credit balances were not refunded within the required regulatory timeframe under 34 CFR §668.164(c). Although no questioned costs wer...

Name of Responsible Individual: Larry Bomback, Interim CFO / DeMornai Blackwell, Controller Corrective Action: Management acknowledges the instances in which Title IV credit balances were not refunded within the required regulatory timeframe under 34 CFR §668.164(c). Although no questioned costs were identified, the College recognizes the need to strengthen internal controls to ensure full compliance. To address this finding, the College will: • Implement a formal Title IV credit balance monitoring procedure requiring weekly review of student accounts with credit balances • Establish an automated report identifying all Title IV–generated credit balances and tracking the 14-day refund deadline • Strengthen coordination between the Business Office, Financial Aid Office, and Registrar to ensure enrollment status and disbursement timing are properly reflected prior to refund processing • Continued documented supervisory review of credit balance aging reports These corrective measures are designed to ensure timely refunds, improve monitoring controls, and maintain compliance with federal Title IV requirements. Anticipated Completion Date: May 31, 2026

View Audit 389689

Finding 1175780 (2025-006)

Material Weakness 2025

Albright College

PA

Reporting Internal Control / Segregation of Duties § 200.510

Management acknowledges the deficiency in the preparation and oversight of the Schedule of Expenditures of Federal Awards (SEFA) for the year ended May 31, 2025. To address this finding, the College will: • Implement a formal SEFA preparation policy aligned with 2 CFR §200.510(b) • Develop and maint...

Management acknowledges the deficiency in the preparation and oversight of the Schedule of Expenditures of Federal Awards (SEFA) for the year ended May 31, 2025. To address this finding, the College will: • Implement a formal SEFA preparation policy aligned with 2 CFR §200.510(b) • Develop and maintain a centralized federal awards tracking log identifying: o Federal agency o Program name o Assistance Listing Number (ALN) o Award number o Pass-through entity (if applicable) o Expenditures by fiscal year • Establish quarterly reconciliations between the general ledger and the federal awards tracking log • Require structured cross-departmental communication between the Business Office, Financial Aid Office, Grants Administration, and program departments to ensure all federal awards received and expended are identified timely • Implement documented management review and approval of the SEFA prior to submission to auditors These corrective measures will strengthen internal controls over federal award tracking, improve the accuracy and completeness of the SEFA, and ensure compliance with Uniform Guidance requirements. Anticipated Completion Date: May 31, 2026

View Audit 389689

Finding 1175774 (2025-005)

Material Weakness 2025

Albright College

PA

Student Financial Aid Internal Control / Segregation of Duties Period of Performance

Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the reporting errors identified in certain student origination records submitted to the Common Origination and Disbursement (COD) System, specifically related to cost of attendance and ...

Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the reporting errors identified in certain student origination records submitted to the Common Origination and Disbursement (COD) System, specifically related to cost of attendance and academic end date data elements. To address this finding, the College will enhance internal controls and oversight over federal aid reporting by implementing the following corrective actions: • Establish a documented secondary review process for all origination records prior to submission to COD, with verification of key data elements including cost of attendance, academic start and end dates, enrollment status, and award amounts. • Implement a standardized review checklist to ensure accuracy and completeness of required data fields. • Strengthen reconciliation procedures between the student information system and COD to identify and resolve discrepancies timely. • Conduct periodic internal quality assurance reviews of origination and disbursement records. • Provide additional staff training on federal reporting requirements. Anticipated Completion Date: This process has already been implemented.

View Audit 389689

Finding 1175772 (2025-004)

Material Weakness 2025

Albright College

PA

Cash Management Student Financial Aid Internal Control / Segregation of Duties

Name of Responsible Individual: Larry Bomback, Interim CFO ; Justin Roy, VP of Enrollment ; Irene Langran, VP of Academic Affairs Corrective Action: Management acknowledges the instance in which Title IV funds were held beyond the allowable timeframe under 34 CFR §668.166. Although the amount was wi...

Name of Responsible Individual: Larry Bomback, Interim CFO ; Justin Roy, VP of Enrollment ; Irene Langran, VP of Academic Affairs Corrective Action: Management acknowledges the instance in which Title IV funds were held beyond the allowable timeframe under 34 CFR §668.166. Although the amount was within allowable tolerance thresholds and no questioned costs were identified, the College recognizes the need to strengthen internal controls over cash management compliance. To address this finding, the College will: • Implement a formal Title IV drawdown and disbursement monitoring procedure requiring review no later than the third business day following receipt of funds • Establish a standardized reconciliation process between the Business Office, Financial Aid Office, and Registrar to ensure timely identification of: o Students who have withdrawn o Enrollment status changes o Required returns of Title IV (R2T4) calculations • Develop a documented weekly reconciliation of federal drawdowns to disbursements and student account activity • Assign clear responsibility for monitoring excess cash thresholds and ensuring timely return of funds to the U.S. Department of Education when required • Provide cross-functional training to reinforce compliance requirements under federal cash management regulations These measures are intended to ensure timely disbursement of Title IV funds, proper reconciliation of enrollment changes, and full compliance with federal cash management requirements. Anticipated Completion Date: May 31, 2026

View Audit 389689

Finding 1175771 (2025-007)

Material Weakness 2025

Big Springs Medical Association D/b/a Missouri Highlands Health Care

MO

Eligibility Internal Control / Segregation of Duties

2025-007: Medication assistance was provided to a patient who was not eligible to receive assistance on the date of service due to active insurance coverage for the prescription. The Organization’s eligibility procedures were not supported by a formal policy or consistently followed as written. Addi...

2025-007: Medication assistance was provided to a patient who was not eligible to receive assistance on the date of service due to active insurance coverage for the prescription. The Organization’s eligibility procedures were not supported by a formal policy or consistently followed as written. Additionally, the Procedure for Medication Financial Assistance provides Community Health Workers and other staff significant discretion in making eligibility determinations. This flexibility and subjective process, while intended to reduce barriers to patients obtaining opioid use disorder treatments, increases the risk for inconsistent and inappropriate eligibility determinations. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: May 2026 Views of responsible officials and planned corrective actions: Issues identified during the audit were indicative of an overall lack of controls and processes by grant directors and Finance Department staff. The Organization has reviewed the processes and has developed a formalized policy for medication assistance eligibility determinations, clearly identifying grant requirements for eligibility. Additionally, the procedure associated with the policy identifies the need for secondary review of eligibility determinations and clear communication to the Finance Department along with adequate record keeping. The Organization’s CEO, a former CFO of the organization, will continue to provide oversight for the Finance Department to ensure controls and processes are implemented.

View Audit 389688

Finding 1175769 (2025-005)

Material Weakness 2025

Big Springs Medical Association D/b/a Missouri Highlands Health Care

MO

Cash Management Internal Control / Segregation of Duties Program Income

2025-005: Funds available from program income were not disbursed before the Organization requested additional drawdowns. The Organization was not appropriately with tracking and utilizing program income. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief ...

2025-005: Funds available from program income were not disbursed before the Organization requested additional drawdowns. The Organization was not appropriately with tracking and utilizing program income. Responsible Persons: Karen R. White, CPA, Chief Executive Officer and Matthew Derryberry, Chief Financial Officer Completion Date: August 2025 Views of responsible officials and planned corrective actions: Issues identified during the audit were indicative of an overall lack of controls and processes due to the change in Finance department staff and loss of knowledge. As of August 2025, program income is no longer being generated by the grant. The new CFO and Finance staff have also implemented processes and controls to ensure proper tracking and utilization of program income related to grants. The CEO will provide ongoing oversight to ensure processes and controls are being adhered to by the Finance Department.

View Audit 389688

Finding 1175761 (2025-003)

Material Weakness 2025

Webster University

MO

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

The University had one R2T4 finding that resulted from a unique situation. The Financial Aid Office will conduct a detailed review of the process and incorporate this specific circumstance into its internal audit procedures. By strengthening internal controls within the R2T4 process and enhancing in...

The University had one R2T4 finding that resulted from a unique situation. The Financial Aid Office will conduct a detailed review of the process and incorporate this specific circumstance into its internal audit procedures. By strengthening internal controls within the R2T4 process and enhancing internal audit protocols, the University will further improve overall compliance in this area and maintain its high standard of regulatory compliance.

View Audit 389673

Finding 1175757 (2025-005)

Material Weakness 2025

High Point University

NC

Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Finding 2025-005 Program: SFA Cluster Assistance Listing No.: Various Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of 2 CFR Part 200, Subpart F, Part 3, the auditor is required to test internal controls related to major p...

Finding 2025-005 Program: SFA Cluster Assistance Listing No.: Various Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of 2 CFR Part 200, Subpart F, Part 3, the auditor is required to test internal controls related to major programs. The specific procedures to test internal control on a caseby-case basis considering factors such as the non-federal entity’s internal controls, the compliance requirements, the audit objectives for compliance, the auditor’s assessment of control risk, and the audit requirement to test internal controls. University’s Response: University management recognizes the finding and has addressed the issue. The Cost of Attendance calculation error affected a single student and resulted in an overaward of $400, which has been corrected and refunded to the Department of Education. Management believes the issue was isolated in nature and does not indicate a systemic weakness in the University’s awarding or billing processes. Corrective Action Plan The University reviewed the circumstances related to this finding and determined that the Cost of Attendance (COA) calculation error was limited in scope and affected a single student. The overaward of $400 has been corrected, and the required refund has been processed to the Department of Education. Management believes the condition was isolated in nature and does not indicate a systemic issue within the University’s awarding or billing processes. The University will continue to rely on its existing awarding and billing procedures, which are designed to support compliance with federal financial aid requirements. No additional corrective action is planned at this time. Existing procedures remain in effect. Name of the responsible person: Megan Inch, Associate Vice President of Student Financial Planning; Brad Calloway, Senior Vice President for Business Affairs Anticipated completion date: Resolved

View Audit 389665

Finding 1175756 (2025-004)

Material Weakness 2025

High Point University

NC

Internal Control / Segregation of Duties

Finding 2025-004 Program: SFA Cluster Assistance Listing No.: Various Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of 2 CFR Part 668, Subpart B, Part 16, the University is required to identify and resolve discrepancies in...

Finding 2025-004 Program: SFA Cluster Assistance Listing No.: Various Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of 2 CFR Part 668, Subpart B, Part 16, the University is required to identify and resolve discrepancies in the information received from different sources with respect to each student’s financial aid. University’s Response: The University identified that certain ISIR comment codes (including ISIR “C” flags) were not properly mapped within the student information system. As a result, those comment codes were not displayed or identified for review within the system workflow. At the time financial aid was disbursed, there were no unresolved C‑flags visible in the system requiring resolution prior to disbursement. The University self‑identified this system configuration issue and disclosed it to its auditors. Upon identification, the ISIR comment code mapping was corrected, and the University performed a review of affected records to ensure all required eligibility issues were identified and resolved. As a result of this issue, financial aid was disbursed to three students who were later determined to require additional eligibility review. The University refunded $160,789 to the Department of Education related to these students. Additionally, one student was determined to have been ineligible for aid in a prior award year, resulting in an additional refund obligation of $31,571, which remains payable to the Department of Education at the time of report issuance. Corrective Action Plan: The ISIR comment code mapping issue has been corrected, and all identified affected records have been reviewed and resolved. Management believes the condition resulted from a specific system configuration issue and was isolated in nature. No additional corrective action is planned at this time. The University believes the corrective actions already taken have addressed the root cause of the issue and that existing processes are operating as intended. Name of the responsible person: Megan Inch, Associate Vice President of Student Financial Planning; Brad Calloway, Senior Vice President for Business Affairs Anticipated completion date: Resolved

View Audit 389665

Finding 1175755 (2025-003)

Material Weakness 2025

High Point University

NC

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting § 200.514

Finding 2025-003 Program: Grants to States for Medicaid Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of the subaward agreement, the University is required to submit comp...

Finding 2025-003 Program: Grants to States for Medicaid Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of the subaward agreement, the University is required to submit compliance reporting to the grantor annually beginning in the year the funds were received. University’s Response: The University was not provided with the required compliance reporting templates at the time the subaward was issued. As a result, the University was unable to submit the required reports during the applicable reporting period. The grantor did not request submission of the reports during this time. Upon becoming aware of the reporting requirement during the Single Audit process, the University requested the appropriate templates and reporting guidance from the grantor. The templates were subsequently provided, and the University is continuing to work with the grantor to ensure accurate completion and submission of the required compliance reporting. The University confirms that grant funds were used in accordance with the terms and allowable activities of the subaward agreement. Corrective Action Plan: The University will continue to seek clarification and guidance from the grantor regarding required compliance reporting and the appropriate format for submission. If sufficient guidance is not provided, the University will submit the required compliance reporting to the best of its ability based on available information, understanding that the submission may be subject to review or revision by the grantor. No additional corrective action is planned at this time. The University will continue to work with the grantor to address reporting requirements as information becomes available. Name of the responsible person: Brian Shollenberger, Vice President for Financial Affairs and University Development Anticipated completion date: May 31, 2026

View Audit 389665

Finding 1175754 (2025-002)

Material Weakness 2025

High Point University

NC

Special Tests & Provisions Internal Control / Segregation of Duties

Finding 2025-002 Program: Federal Work Study Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify all amounts paid are appropriately earned. University’s Respon...

Finding 2025-002 Program: Federal Work Study Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2024 – 2025 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify all amounts paid are appropriately earned. University’s Response: The University uses Workday HCM as the official system of record for student employee time reporting. Student workers record time directly in Workday, and supervisors review and approve time entries each pay period prior to payroll processing. The time punches in question were reviewed and approved in Workday in accordance with standard procedures at the time of payment. Because the audit occurred six to eighteen months after the work was performed by the students, supervisors were unable to independently recall specific hours worked beyond the documentation maintained in Workday. However, system records indicate that the hours were reviewed and approved, and the University confirmed that any questioned amounts were offset by subsequent allowable hours worked. As noted by the auditors, questioned costs of $508 were identified; however, no return of Federal Work‑Study funds was required based on allowable offsetting hours. Corrective Action Plan: The University will continue to rely on its existing Federal Work‑Study timekeeping and payroll procedures, which require that student wages be based on hours worked in allowable positions. Management believes the condition identified was isolated in nature and not indicative of a systemic issue within the Federal Work‑Study program. No additional corrective action is planned at this time. Existing procedures remain in effect. Repeat Finding Explanation This finding is reported as a repeat due to similar conditions noted in the prior year related to Federal Work‑Study payroll documentation. However, the current‑year finding reflects a reduced scope, a lower number of students, and a significantly reduced questioned cost amount compared to the prior year. Management believes the issue is not systemic. Name of the responsible person: Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs; Sandra Fantauzzi, Student Employment Program Manager; Megan Inch, Associate Vice President of Student Financial Planning

View Audit 389665

Finding 1175753 (2025-001)

Material Weakness 2025

High Point University

NC

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

Finding 2025-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely mann...

Finding 2025-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. University’s Response: The excess cash balance relates to prior award years and is not part of the currently audited period. The University has maintained these funds in a segregated federal funds account and safeguarded them from expenditure while performing reconciliation. The University is actively coordinating with the Department of Education to determine the appropriate process for returning the excess cash and will follow their guidance once received. The University has continued to ensure these funds are not comingled and has protected them from spending. Because of the discrepancies identified, each student’s loan history had to be reviewed and compared between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation have proven to be a tedious but necessary process to identify the funds never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: The University, working with an external financial aid consulting firm with experience in reconciling FFEL loan programs, has finished researching all related accounts against the National Student Loan Database System (NSLDS) records. The University continues to work with the Department of Education to determine how to return funds in instances where the last lender used is no longer available to process student loan funds, and lastly, book the appropriate entries for any funds determined to belong to the University that were not moved to the University operating accounts properly at the time of the transactions. Name of the responsible person: Brad Calloway, Senior Vice President for Business Affairs Anticipated completion date: Unknown

View Audit 389665

Finding 1175735 (2025-002)

Material Weakness 2025

Rebuilding Together Metro Chicago

IL

Reporting Significant Deficiency Internal Control / Segregation of Duties

Action To Be Taken: To ensure federal compliance for the Corona virus Relief Fund (ALN 21.019), the organization will implement a secondary review process. After the Executive Director prepares the federal financial reports, a designated member of the Board Finance Committee will review the supporti...

Action To Be Taken: To ensure federal compliance for the Corona virus Relief Fund (ALN 21.019), the organization will implement a secondary review process. After the Executive Director prepares the federal financial reports, a designated member of the Board Finance Committee will review the supporting documentation (General Ledger and invoices) for accuracy before the report is submitted to the granting agency.•Responsible Party: Executive Director and Board Finance Committee. Anticipated Completion Date: February 28, 2026.

View Audit 389648

Finding 1175727 (2025-001)

Material Weakness 2025

Saint Mary's University of Minnesota

MN

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-001 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Addit...

Saint Mary's University of Minnesota Corrective Action Plan For the Year Ended May 31, 2025 Finding 2025-001 Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the Title IV program within 45 days after a student withdraws. Additionally, The U.S. Department of Education (ED) requires that an institution must ensure that its administrative procedures for the FSA programs include an adequate system of internal controls or checks and balances to ensure compliance with FSA laws and regulations including the return of Title IV funds. Condition/Context: The federal aid refunds for 1 out of 8 of the students tested was not calculated correctly and subsequently, not returned within 45 days from the withdrawal date. The sample was not statistically valid. Also, the auditor noted that the University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Cause: The University's review procedures for the return of Title IV funds were not followed and the system was not programmed to ensure the correct withdrawal date was used in the calculation of the return of Title IV funds. Effect: The University was in possession of funds belonging to the federal government longer than allowed and could have incorrect return of Title IV calculations and return incorrect amounts to students and/or the ED. Questioned Costs: Not applicable. Recommendation: The University should adhere to its procedures for refunding awards and implement a more formal documented review process/control to ensure refunds are calculated correctly and timely and any returns are made within the required timeframe. Management Response: The University agrees with this finding. The JFA R2T4 calculation incorrectly populated the wrong date used to perform the calculation, thus causing the error. The error was corrected and the director performs the R2T4 and is working to have a back-up employee trained. Staffing levels will have to be brought up to allow for new financial aid staff to complete this task. Corrective Action Plan Corrective Action Planned: To ensure accuracy, the withdrawal date generated in the JFA calculation will be cross-referenced against the J1 SIS record. Once verified, this date will be documented alongside the R2T4 calculation. This process guarantees that the student's period of attendance is calculated using the correct data. Name(s) of Contact Person(s) Responsible for Corrective Action: Holly Weberg, Director of Financial Aid and new hire designee. Anticipated Completion Date: The director is still fulfilling the R2T4 duties until a new hire candidate is hired and trained.

View Audit 389644

Finding 1175719 (2025-002)

Material Weakness 2025

Montana Cancer Consortium

MT

Internal Control / Segregation of Duties § 200.303

Finding 2025-002: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack Inadequate Documentation and Lack of Independent Review of Expenditures Corrective Action: We agree with the recommendation...

Finding 2025-002: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack Inadequate Documentation and Lack of Independent Review of Expenditures Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. MCC has updated the Financial Process Procedure to include language related to receipt management, and allowable and disallowed grant expenses. MCC has created a Travel Reimbursement Procedure that addresses approval of Director expenses. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators

View Audit 389640

Finding 1175710 (2025-003)

Material Weakness 2025

Marymount University

VA

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that Key Line Items are reviewed and accurately reported to Department of Education as required by regulations. ...

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its reporting procedures to ensure that Key Line Items are reviewed and accurately reported to Department of Education as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding resulted from inaccuracies introduced through enhancements made to a Workday-delivered report, which ultimately did not produce correct information. Going forward, we will review and validate the Workday report to ensure it aligns with Student Accounts’ reports and accurately reflects tuition and fees for the academic year. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Planned completion date for corrective action plan: June 2026 If the U.S. Department of Education have questions regarding this plan, please contact the individual(s) noted above.

View Audit 389607

Finding 1175705 (2025-002)

Material Weakness 2025

Marymount University

VA

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Explanation of dis...

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend the University review its return of Title IV fund procedures to ensure that calculations are performed with correct inputs as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was driven by incorrect MSMS program start and end dates configured in the University’s new Student Information System (Workday). When processing Return of Title IV (R2T4) calculations, Workday relies on the program start and end dates stored in the system. Due to these dates being incorrect, the R2T4 process calculated an inaccurate number of days enrolled, which resulted in an incorrect earned percentage of Title IV aid and, consequently, an incorrect amount of aid the student was eligible to retain. To address this issue, the University has implemented internal controls to review and verify the start and end dates of each academic year in Workday prior to the start of each semester. In addition, an internal control has been added to ensure the start and end dates of each academic year are reviewed and validated as part of the Return of Title IV processing. Name(s) of the contact person(s) responsible for corrective action: Jacob Witt, AVP of Financial Aid, 703-284-1532 Courtney Carey, University Registrar, 703-284-1523 Planned completion date for corrective action plan: Completed December 2025.

View Audit 389607

Finding 1175672 (2025-001)

Material Weakness 2025

Margaret B. MacK Supportive Housing Corporation Hud Proj. #017-Hd038

CT

Internal Control / Segregation of Duties Significant Deficiency

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Recommendation: We recommend that management review the rates used to calculate management fees to ensure that they agree to the agreed upon percentages outlined in the agreem...

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Recommendation: We recommend that management review the rates used to calculate management fees to ensure that they agree to the agreed upon percentages outlined in the agreement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will ensure that calculated management fees match the agreed upon rates. Name of the contact person responsible for corrective action: Angela Westwood, CFO Planned completion date for corrective action plan: Completed on January 31, 2026.

View Audit 389507

Finding 1175670 (2025-002)

Material Weakness 2025

Continuum of Care, Inc. and Affiliates

CT

Internal Control / Segregation of Duties Significant Deficiency

Supportive Housing for Persons With Disabilities Assistance Listing No. 14.181 Criteria or Specific Requirement: Department of Housing and Urban Development requires any surplus funds in the project funds account at the end of the fiscal year to be deposited in a federally insured account within 6...

Supportive Housing for Persons With Disabilities Assistance Listing No. 14.181 Criteria or Specific Requirement: Department of Housing and Urban Development requires any surplus funds in the project funds account at the end of the fiscal year to be deposited in a federally insured account within 60 days following the end of the fiscal year. Condition: As of June 30, 2024, Continuum Supportive Housing of West Hartford, Inc. has a surplus cash of $50,759. The required deposit into a residual receipt account was not made within 60 days following the end of the fiscal year. Questioned costs: None Context: We reviewed the surplus cash calculation noting that the Project has a surplus cash of $50,759 at the end of the fiscal year 24. Surplus cash should have been deposited within 60 days following the end of the fiscal year. Cause: This was an oversight by management. Effect: The required deposit was not made as required by the Department of Housing and Urban Development. Repeat Finding: Yes Recommendation: We recommend management to ensure that required deposits are made 60 days following the fiscal year-end. Views of Responsible Officials: There is no disagreement with the audit finding. Action taken in response to finding: Required deposit made by March 31, 2025. Name of the contact person responsible for corrective action: Angela Westwood, CFO Planned completion date for corrective action plan: January 31, 2026.

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Finding 1175668 (2025-001)

Material Weakness 2025

Continuum of Care, Inc. and Affiliates

CT

Significant Deficiency Internal Control / Segregation of Duties

Supportive Housing for Persons With Disabilities Assistance Listing No. 14.181 Criteria or Specific Requirement: According to the client's internal control over payroll disbursements, hourly employees must maintain timesheets which are approved and signed by the property manager. Condition: Upon p...

Supportive Housing for Persons With Disabilities Assistance Listing No. 14.181 Criteria or Specific Requirement: According to the client's internal control over payroll disbursements, hourly employees must maintain timesheets which are approved and signed by the property manager. Condition: Upon performing testing over payroll disbursements, we noted that there was no approval of the timesheets for the payroll disbursements tested. Questioned costs: None Context: The timesheet for 1 out of 5 payroll disbursements tested was not properly approved by the property manager. Cause: Turnover of property manager at the property management company and weaknesses in internal controls over payroll disbursements. Effect: There is no evidence of proper approval of payroll disbursement. Repeat Finding: Yes Recommendation: We recommend that management strengthen controls over review of payroll. Views of Responsible Officials: There is no disagreement with the audit finding. Action taken in response to finding: Although other controls assist to safeguard and mitigate compensation errors, the property manager will ensure that all time sheets are properly approved prior to payment, and if necessary the VP of Operations or the President of the managing agent will provide further assurance of internal controls through reviews. Name of the contact person responsible for corrective action: Angela Westwood, CFO Planned completion date for corrective action plan: January 31, 2026.

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Finding 1175652 (2025-005)

Material Weakness 2025

City of Syracuse, New York

NY

Special Tests & Provisions Internal Control / Segregation of Duties

The City remains committed to complying with Uniform Guidance requirements and acknowledges the importance of strengthening internal controls related to the inspection process. To support this effort, a centralized tracking system will be implemented to monitor inspection deadlines for all HOME-assi...

The City remains committed to complying with Uniform Guidance requirements and acknowledges the importance of strengthening internal controls related to the inspection process. To support this effort, a centralized tracking system will be implemented to monitor inspection deadlines for all HOME-assisted rental units. The City will also enhance its policies and procedures to clearly define staff responsibilities, inspection scheduling protocols, documentation standards, and required follow-up actions for units found to be out of compliance. Expected Completion: June 30, 2026 Responsible Contact Person: Michael Cannizzaro, Commissioner of Finance, 315-448-8323

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Finding 1175632 (2025-004)

Material Weakness 2025

National University

CA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend that the University establish procedures to ensure that FISAP is accurately presented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: National University (NU) agrees with the importanc...

Recommendation: We recommend that the University establish procedures to ensure that FISAP is accurately presented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: National University (NU) agrees with the importance of ensuring the accuracy of its data reported in the FISAP. The University will take the following steps to resolve the issue. NU identified a knowledge gap for the tuition and fees reporting required on the FISAP. Training will be conducted to review the requirements for reporting tuition and fees at the Undergraduate and Graduate levels, which are fully reconciled to the audited financial statements. In addition to the training, the University has implemented a secondary review of the calculation, which will be completed by the University controller prior to submission. Name(s) of the contact person(s) responsible for corrective action: - Robert Conlon, AVP Financial Aid Compliance - Christina Nowacki, Controller Planned completion date for corrective action plan: December 2025

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Finding 1175626 (2025-003)

Material Weakness 2025

National University

CA

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency

Recommendation: We recommend that the University establish procedures to ensure that at least 7% of Federal Work Study allocation is used for community service jobs, including a reading tutor, or successfully receive a waiver. Explanation of disagreement with audit finding: There is no disagreement ...

Recommendation: We recommend that the University establish procedures to ensure that at least 7% of Federal Work Study allocation is used for community service jobs, including a reading tutor, or successfully receive a waiver. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: National University (NU) agrees with the importance of ensuring compliance with FWS community service requirements. The University implemented additional internal controls and policy changes to how it administers the FWS program and completes FISAP reporting to resolve this issue. During NU’s annual FISAP reporting process, it discovered that it had not met its FWS community service obligation. The University submitted a waiver, but it was denied. The University took immediate action to determine the cause of not meeting its FWS community service obligations. Community Partnership Management: National University previously had a partnership with Barrio Logan College Institute (BLCI) located in San Diego, CA. This partnership changed during the pandemic when all schools received a waiver for the community service requirement. In August 2024, Elyse Joiner, Director of Financial Aid Processing, again reached out to BLCI to reestablish a partnership. At that time, National was informed that the previous point of contact was no longer employed with BLCI, but the institute was still interested in partnering with National to meet the community service requirement for Federal Work Study. Ms. Joiner had several communications with BLCI to implement and finalize the setup of the reading and math tutors, with the only outstanding item related to the need for a virtual option. Unfortunately, communication between National University and BLCI ceased in April 2025 when National stopped receiving responses from BLCI to its inquiries. To establish another partnership, Ms. Joiner reached out to United Way of San Diego County to explore the possibility of establishing a reading or math tutor program with them but did not receive a response. Program Administration Change: Federal Work Study funds were budgeted to meet the University’s community service requirement; however, due to unforeseen circumstances and the efforts noted above, the University was unable to meet the 7% community service requirement. The University did have tutors available to the University community, but this did not fulfill the community service requirement. National University has since rectified this for the current aid year. The positions have been posted (R 2025 3051), and the University will have multiple FWS students at the Nest at Spectrum, offering tutoring services to both NU students and the public. The YMCA next to Spectrum will also be informed about the services to promote additional awareness within the local community. Additional opportunities are being actively explored within the Student Disability Services team and the Schools of Law & Public Service and Education. Steps taken to improve transparency and tracking: The University conducted a holistic review of the current FWS policies and procedures and has or will take the following steps: o Comprehensive training for administering the FWS program and Campus-Based Funding programs o Develop and implement an internal control plan that monitors FWS spending activity, allowing for the proactive identification of when the University should reallocate funds between campus-based programs. o Implemented quarterly calibration meetings between FWS/Operations leaders and HR to ensure its FWS program is on track to meet the FWS community service, literacy, and tutoring regulatory requirements. o Explore the expansion of community service relationships and opportunities within the Federal Work Study Program. Name(s) of the contact person(s) responsible for corrective action: - Alan Coddington, AVP Student Financial Services - Elyse Joiner, Director of Operations, Financial Aid Processing and Technical Solutions - Rob Conlon, AVP Financial Aid Compliance Planned completion date for corrective action plan: February 2026

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