Corrective Action Plans

Finding 547261 (2024-007)

Significant Deficiency 2024

NC

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

Corrective Action Plan: We acknowledge the accuracy of this finding, such that one student’s required return of funds was identified as having been improperly calculated during the R2T4 calculation. The order in which the funds were reduced and returned to the Department was incorrect. Lack of clari...

Corrective Action Plan: We acknowledge the accuracy of this finding, such that one student’s required return of funds was identified as having been improperly calculated during the R2T4 calculation. The order in which the funds were reduced and returned to the Department was incorrect. Lack of clarity about the enrollment level and activity of the student during the term caused the miscalculated award amounts. A lack of system driven calculation and insufficient knowledge of the proper order of funds (and required student authorization of post-withdrawal disbursement) were also contributing factors that resulted in this finding. The University underwent a re-organization the resulted in the creation of a new division, Strategic Enrollment and Retention Management (“SERM”), effective February 2025. The recent organizational restructuring that placed the Registrar’s Office and the Office of Financial Aid under the new division of Strategic Enrollment and Retention Management is a strategic move to enhance the synchronization of essential data between these departments. This alignment is crucial for accurately determining withdrawal dates and understanding the academic calendar, which are essential components of the R2T4 calculation process. Enhanced inter-departmental communication facilitated by this structure will ensure more accurate and timely data sharing, essential for meeting compliance requirements. The ongoing support from FAS in setting up and optimizing Ellucian Colleague for our specific needs will significantly strengthen our capacity to meet and exceed compliance standards, thus preventing future occurrences of similar issues. Starting June 2025, the Financial Aid Office will engage with FSA Partners and utilize NASFAA study materials to conduct comprehensive training for staff responsible for R2T4 calculations. Continuous education will be emphasized to keep staff updated on regulatory changes and best practices. We will utilize the capabilities of Ellucian Colleague to automate R2T4 calculations. This system will be set up to require authorization for post-withdrawal disbursements and ensure that award reductions are calculated in the correct order. We will introduce a secondary review process for all R2T4 calculations, where a seasoned financial aid counselor will verify the accuracy of the initial calculation and authorization documentation. We will standardize the process for documenting the authorization of post-withdrawal disbursements. Develop a standard communication template within Ellucian Colleague that includes explicit requests for student or parent authorization, ensuring compliance with federal regulations. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547259 (2024-006)

Significant Deficiency 2024

Johnson C. Smith University

NC

Student Financial Aid Eligibility Reporting

Corrective Action Plan: A lack of systematic communication between the Registrar’s Office and the Office of Financial Aid, coupled with an absence of an established process flow or calendar to guide quality assurance activities, led to these discrepancies. The University understands that accurate re...

Corrective Action Plan: A lack of systematic communication between the Registrar’s Office and the Office of Financial Aid, coupled with an absence of an established process flow or calendar to guide quality assurance activities, led to these discrepancies. The University understands that accurate reporting of student enrollment status is crucial for managing student eligibility for federal financial aid, including loans and grants; however, in these cases, there were several discrepancies. The University underwent a re-organization the resulted in the creation of a new division, Strategic Enrollment and Retention Management (“SERM”), effective February 2025. SERM aims to address the root causes of this finding by fostering enhanced synergy and communication between the Registrar’s Office and the Office of Financial Aid. This structural change aligns both departments under the governance of the Senior Vice President, ensuring cohesive and compliant operational practices. The alignment will facilitate a unified approach to meet federal reporting requirements more effectively and efficiently, thereby enhancing our administrative capability and compliance with critical federal requirements. This proactive governance restructuring is expected to significantly improve our process accuracy and compliance integrity, safeguarding our students' financial interests and maintaining our standing with federal financial aid programs. In addition, the University will establish audit and verification processes that involve conducting an exhaustive audit of current enrollment reporting processes in collaboration with Financial Aid Services (FAS) to identify and amend discrepancies. We will implement comprehensive, quarterly training for all staff involved in enrollment reporting starting August 2025 to ensure adherence to federal regulations. The Registrar’s Office will establish bi-weekly reporting schedules to the National Student Clearinghouse (NSC), including during summer terms, to ensure timely updates in NSLDS. There will also be regular review sessions to evaluate the effectiveness of the new reporting protocols and make necessary adjustments. Anticipated Completion Date: August 31, 2025

View Audit 351580

Finding 547255 (2024-005)

Significant Deficiency 2024

Johnson C. Smith University

NC

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

Corrective Action Plan: The University acknowledges shortcomings in our institutional processes for managing and communicating the details of Tier One and Tier Two financial arrangements. This has been due to a combination of factors, including outdated website management practices, a lack of clear ...

Corrective Action Plan: The University acknowledges shortcomings in our institutional processes for managing and communicating the details of Tier One and Tier Two financial arrangements. This has been due to a combination of factors, including outdated website management practices, a lack of clear guidelines on compliance responsibilities for web content, and insufficient inter-departmental communication regarding changes in federal regulations and their implications for our disclosure practices. The University is establishing a continuous feedback loop between Financial Aid, the Business Office, and University Communications and Marketing departments to ensure that our contractual disclosures are not only compliant but also clear and accessible to our stakeholders. Enhanced communication and collaboration across these departments are pivotal for maintaining ongoing compliance and ensuring that all disclosures are managed efficiently and transparently. This proactive approach is aimed at fostering a culture of compliance and transparency throughout the University. The University will improve the accessibility and visibility of contractual disclosures on its website to ensure compliance with federal requirements. The updated URLs will be provided to the Department of Education for publication of the contract in a centralized, accessible database. In addition, in partnership with Financial Aid Services (FAS), the University will conduct comprehensive interdepartmental training sessions by August 2025 for all relevant staff, emphasizing the critical nature of compliance with federal disclosure requirements. Anticipated Completion Date: August 31, 2025

View Audit 351580

Finding 547254 (2024-004)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring

Corrective Action Plan: The University relied on third-party technology to notify students of their disbursements without monitoring if their process was being executed. The failure stemmed from inadequate oversight of the notification process, leading to non-compliance with federal requirements for...

Corrective Action Plan: The University relied on third-party technology to notify students of their disbursements without monitoring if their process was being executed. The failure stemmed from inadequate oversight of the notification process, leading to non-compliance with federal requirements for the timely and accurate notification of loan disbursements. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition to Ellucian Colleague for financial aid management. University officials are committed to rectifying this deficiency through significant enhancements to our notification processes and technological infrastructure. The systematic integration of notification with the actual disbursement function via Ellucian Colleague represents a robust solution to ensure compliance. By handling this process internally, we ensure greater control, reliability, and compliance with federal regulations. Regular audits of the disbursement and notification process will be implemented to guarantee that our procedures remain in alignment with federal requirements and best practices. This proactive approach ensures that all loan disbursements are properly managed and communicated, safeguarding both our students' financial interests and the university's compliance status. The university has already begun to amend procedures to ensure that all loan disbursements are accompanied by timely and accurate notifications. The Office of Financial Aid will maintain detailed records showing compliance with these notifications. The integration of Ellucian Colleague will automate the notification process. This system ensures that notifications are sent immediately upon disbursement processing, using various modalities such as email, text messages, or direct updates to the student portal. We will enhance our enhance record-keeping through the utilization of Ellucian Colleague by logging all communications sent, ensuring that there is traceable evidence of compliance. This system integration addresses previous dependencies on third-party technologies and brings control of this crucial compliance aspect in-house. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547250 (2024-003)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Student Financial Aid Reporting

Corrective Action Plan: The verification for one student was improperly conducted, leading to financial aid awards and disbursements based on unverified or incorrectly verified financial data, specifically regarding untaxed IRA distributions and pensions. The verification failure was due to an overs...

Corrective Action Plan: The verification for one student was improperly conducted, leading to financial aid awards and disbursements based on unverified or incorrectly verified financial data, specifically regarding untaxed IRA distributions and pensions. The verification failure was due to an oversight by the aid administrator who incorrectly verified the untaxed IRA distribution and pension as zero, despite contradictory evidence or a lack of supporting documentation. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. Resulting from the work of FAS, the verification policies will be thoroughly reviewed, and revised, to ensure comprehensive coverage as mandated by federal regulations. The University will also establish a robust quality control system to regularly review verification practices and compliance, ensuring adherence to updated policies. We will update and maintain a verification checklist that includes all data elements required for verification. This checklist will be used in all verifications, with a secondary review and sign-off by another trained administrator to ensure accuracy and completeness. In addition, we will bolster training for all financial aid staff, utilizing resources from FAS and the National Association of Student Financial Aid Administrators (NASFAA) to deepen understanding and expertise in verification processes. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547248 (2024-002)

Significant Deficiency 2024

Johnson C. Smith University

NC

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

Corrective Action Plan: The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS syste...

Corrective Action Plan: The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS systems contributed to erroneous COA budgets. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition from the use of PowerFaids to Ellucian Colleague for financial aid management. Resulting from the work of FAS, the University will institute a systematic monthly reconciliation process to ensure consistency across all systems (COD, PowerFAIDS, Jenzabar and Colleague). This includes matching COA and disbursement records to ensure accuracy. To optimize workflow, we will establish a comprehensive calendar of disbursement and reporting deadlines, with routine internal audits every 30 days, starting April 2025. This measure will enforce accountability and timeliness in reporting. We will enhance integration between financial systems (Jenzabar and PowerFAIDS) to prevent data mismatches and streamline the reporting process. In addition, we will leverage our partnership with FAS to conduct regular training sessions for staff across the Financial Aid, Registrar, and Finance Offices to ensure everyone is aware of compliance requirements and system functionalities. These training sessions will start May 2025. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547245 (2024-001)

Significant Deficiency 2024

Johnson C. Smith University

NC

Questioned Costs Student Financial Aid Subrecipient Monitoring

Corrective Action Plan: The University did not appropriately review eligibility documentation resulting in over awards. The error arose due to the manual processing of student loans by a single financial counselor without adequate checks, leading to non-compliance with specific fund restrictions rel...

Corrective Action Plan: The University did not appropriately review eligibility documentation resulting in over awards. The error arose due to the manual processing of student loans by a single financial counselor without adequate checks, leading to non-compliance with specific fund restrictions related to the student’s year in school and dependency status. A significant contributing factor was the absence of structured, periodic quality assurance reviews. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will transition from the use of PowerFaids to Ellucian Colleague for financial aid management, which was driven by the need for more robust, systematic controls that can accurately adjust and calculate Cost of Attendance (COA) on a per-student basis. This system change is expected to automate many of the processes that were previously prone to human error, ensuring compliance with regulatory requirements. The University’s Financial Aid counselors will continue to monitor students' credit hours and make necessary adjustments to aid awards, thereby maintaining compliance and addressing any discrepancies proactively. This plan reflects our commitment to upholding the highest standards of financial aid management and ensuring that our processes are transparent, compliant, and responsive to the needs of our students. The University will integrate automated processes in our financial aid packaging to reduce human error. The adoption of the Ellucian Colleague system by JCSU will allow for automatic enforcement of packaging and transmittal rules, tailored to specific funds. Additionally, we will utilize exception reports from Ellucian Colleague to identify and correct discrepancies in real-time. We will establish a routine monitoring system to regularly check the accuracy of financial aid awards against eligibility criteria. Anticipated Completion Date: September 30, 2025

View Audit 351580 Questioned Costs: $1

Finding 547230 (2024-001)

Significant Deficiency 2024

Puerto Rico Safe Drinking Water Treatment Revolving Loan Fund

PR

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

Finding No. 2024-001 -Allowable Activities-Loans repayments Condition Found Principal and interest have not been collected from the Revolving Fund on projects that were completed since before the execution of the loan agreement, which are included as part of the financial agreement dated September 2...

Finding No. 2024-001 -Allowable Activities-Loans repayments Condition Found Principal and interest have not been collected from the Revolving Fund on projects that were completed since before the execution of the loan agreement, which are included as part of the financial agreement dated September 2, 2022. Therefore, repayment of principal and payment of interest should have begun on their respective dates, as set forth in the loan agreement and notes payable executed thereto. Views of Responsible Officials and Corrective Action Plan Once the final inspection of a construction project is performed, DOH will submit notifications to PRASA requesting the Notice of Substantial Completion letter from PRASA concurring that the project is acceptable of the operation. Such letter will be an attachment to the formal notification that DOH will send to PRASA and PRIFA. DOH’s letter will specify the starting operating date and the useful life of the project. Therefore, PRIFA will be in position to collect principal and interest for the project according to federal regulations and as established in the loan agreement. Name (s) of the Contact Person (s) Responsible for Corrective Action Ángel Pantoja Rodríguez, Secretary of the Treasury Department, Eduardo Rivera Cruz, Executive Director Puerto Rico Infrastructure Financing Authority and Victor Ramos, Secretary of the Puerto Rico Department of Health. Anticipated Completion Date Immediately

View Audit 351563

Finding 547227 (2024-002)

Significant Deficiency 2024

Roswell Independent School District No.4

NM

Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency

Auditor’s Recommendation - The auditor recommends the District select a methodology and implement, or update the current methodology to what is being done on the Documentation of Compliance and to ensure finance and title I program manager/personnel are in communication with each other. Views of Res...

Auditor’s Recommendation - The auditor recommends the District select a methodology and implement, or update the current methodology to what is being done on the Documentation of Compliance and to ensure finance and title I program manager/personnel are in communication with each other. Views of Responsible Officials of Auditee: The District acknowledges that the methodology used was not properly described in the signed compliance document; however, the District affirms that Title I allocations were compliant with Title I guidelines. Moving forward, the District will ensure that the wording in documentation accurately reflects the procedures used at the school level. Responsible Party: Glenda Leonard, Educator Sustainability and School Support, Jennifer Cole, Assistant Superintendent of Curriculum and Instruction, Micheal Sexton, Assistant Superintendent for Finance & Operations, and Brian Luck, Superintendent Anticipated Completion Date: June 30, 2025

View Audit 351551

Finding 547223 (2024-014)

Material Weakness 2024

Huntington County Community School Corporation

IN

Matching / Level of Effort / Earmarking Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

FINDING 2024-014 Finding Subject: COVID 19-Education Stabilization Fund-Special Tests and Provisions-Wage Rate Requirements Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12...

FINDING 2024-014 Finding Subject: COVID 19-Education Stabilization Fund-Special Tests and Provisions-Wage Rate Requirements Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Huntington County Community School Corporation will establish an Internal Control Standards manual by July 1, 2025, along with the Segregation of Duties chart by August 1, 2025. These standards will include items that detail the procedures and processes along with the checks and balances needed to ensure proper oversight, prevention, detection, correction, or errors. Our process will also ensure reporting compliance is followed. The Internal Control Standards manual will include special tests and provisions and construction wage rate requirements. To ensure accuracy and efficiency, future reporting will be prepared by the grant administrator, reviewed by the Grants Specialist then approved by the Corporation Treasurer or Chief Operating Officer before submission. The Grant Specialist will ensure future projects with construction contracts will have a prevailing wage clause while also monitoring payroll to verify compliance. To ensure that the construction wage rate is complied with, the contractor will submit the certified payrolls to the Grant Specialist who will then provide to the Corporation Treasurer for review, initial and file with the construction pay application. Anticipated Completion Date: Huntington County Community School Corporation will establish the Internal Control Standards by July 1, 2025, and train administration and staff in August 2025.

View Audit 351544

Finding 547217 (2024-013)

Material Weakness 2024

Huntington County Community School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2024-013 Finding Subject: COVID 19-Education Stabilization Fund-Reporting Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We ...

FINDING 2024-013 Finding Subject: COVID 19-Education Stabilization Fund-Reporting Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Huntington County Community School Corporation will establish an Internal Control Standards manual by July 1, 2025, along with the Segregation of Duties chart by August 1, 2025. These standards will include items that detail the procedures and processes along with the checks and balances needed to ensure proper oversight, prevention, detection, correction, or errors. Our process will also ensure reporting compliance is followed. The Internal Control Standards manual will include special tests and provisions. To ensure accuracy and efficiency, future reporting will be prepared by the grant administrator, reviewed by the Grants Specialist then approved by the Corporation Treasurer or Chief Operating Officer before submission. Anticipated Completion Date: Huntington County Community School Corporation will establish the Internal Control Standards by July 1, 2025, and train administration and staff in August 2025.

View Audit 351544

Finding 547206 (2024-011)

Material Weakness 2024

Huntington County Community School Corporation

IN

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

FINDING 2024-011 Finding Subject: Subject: Special Education Cluster (IDEA) - Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listing Numbers: 84.027, 84.027X Federal Aw...

FINDING 2024-011 Finding Subject: Subject: Special Education Cluster (IDEA) - Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States Assistance Listing Numbers: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): 21611-027-PN01, 22611-027-PN01, 22611-027-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Corporation Treasurer and Grant Specialist will prepare the grant financial data bi-annually for the Form 9. The information will be reviewed by the Director of Special Education prior to final submission. Anticipated Completion Date: July 30, 2025

View Audit 351544

Finding 547197 (2024-009)

Material Weakness 2024

Huntington County Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-009 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions – Participation of Private School Children Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Num...

FINDING 2024-009 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions – Participation of Private School Children Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Participation of Private School Children Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Monthly meetings will be held between the Title 1 Director, administrative assistant, and member of the business office to ensure all non-public schools receive and expend monies and documentation will be signed off on by two people and kept with reimbursement forms. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547195 (2024-008)

Material Weakness 2024

Huntington County Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-008 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions – Assessment System Security Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Numbers and Years...

FINDING 2024-008 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions – Assessment System Security Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Assessment System Security Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Each building will create a list of staff that are required to complete the testing security training for Assessments. Staff will sign off on completion of training. The Director of Curriculum and/or the Director of Title 1 will review and sign off after ensuring that all required staff have completed the training. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547193 (2024-007)

Material Weakness 2024

Huntington County Community School Corporation

IN

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303

FINDING 2024-007 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Supplement Not Supplant Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Numbers and Years (o...

FINDING 2024-007 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Supplement Not Supplant Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Supplement Not Supplant Audit Finding: Material Weakness Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Monthly meetings will be held between Title 1 Director, administrative assistant, and member of the business office to ensure all Title 1 schools receive and expend monies and documentation will be signed off on by two people and kept with reimbursement forms. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547191 (2024-006)

Material Weakness 2024

Huntington County Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions § 200.303 § 200.334

FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Othe...

FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: All withdrawals will have the proper documentation (transcript request or withdrawal form) attached to the student record and the form will be dated within two weeks of the student enrollment end date. The forms must be signed by the parent and the principal. Title 1 Director will review for accuracy and completion of forms. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547189 (2024-005)

Material Weakness 2024

Huntington County Community School Corporation

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2024-005 Subject: Title I Grants to Local Educational Agencies - Level of Effort, Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers)...

FINDING 2024-005 Subject: Title I Grants to Local Educational Agencies - Level of Effort, Earmarking Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers):S010A210014, S010A220014, S010A230015 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Unused homeless reservation set aside funds will be carried over and added to the set aside amount for the new grant application. The Form 9 will be reviewed and signed off on by the Title 1 Director and a member of the business office. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547187 (2024-004)

Material Weakness 2024

Huntington County Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

FINDING 2024-004 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers):S010A21...

FINDING 2024-004 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers):S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Beth Husband/Alexandria Eckert Contact Phone Number 260-356-8312 Email Address: bhusband@hccsc.k12.in.us/aeckert@hccsc.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Title 1 Director and a member of the business office will check to ensure the enrollment counts provided in the Title 1 application are accurate and that the nonpublic school enrollment, addresses, and socioeconomic status of students are accurate before submitting the information on the Title 1 application. Anticipated Completion Date: December 31, 2025

View Audit 351544

Finding 547186 (2024-003)

Material Weakness 2024

Huntington County Community School Corporation

IN

Internal Control / Segregation of Duties Equipment & Real Property Management Special Tests & Provisions § 200.303

FINDING 2024- 003 Finding Subject: Covid 19-Emergency Connectivity Fund Program-Special Tests and Provisions-Restricted Purpose Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc...

FINDING 2024- 003 Finding Subject: Covid 19-Emergency Connectivity Fund Program-Special Tests and Provisions-Restricted Purpose Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Huntington County Community School Corporation will establish an Internal Control Standards manual by July 1, 2025, along with the Segregation of Duties chart by August 1, 2025. These standards will include items that detail the procedures and processes along with the checks and balances needed to ensure proper oversight, prevention, detection, correction, or errors. Our process will also ensure reporting compliance is followed. The Internal Control Standards manual will include special tests and provisions for restricted purposes. This provision will detail asset inventory for purchased equipment by equipment invoices by the Information Technology department. Details will be outlined on how student devices are assigned to students and tracked. Anticipated Completion Date: Huntington County Community School Corporation will establish the Internal Control Standards by July 1, 2025, and train administration and staff in August 2025.

View Audit 351544

Finding 547176 (2024-003)

Material Weakness 2024

Area 20/21 Workforce Development Board

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles

Procedures were put in place in October 2024 to monitor CCMEP spending.

View Audit 351543

Finding 547169 (2024-001)

Material Weakness 2024

Washington and Lee University

VA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan to Finding 2024‐001: Contact person for corrective action: Melissa Neal, Registrar Correction Action Plan: The University plans to implement the following: During the 2024‐2025 academic year, the Registrar Office will implement the following mechanisms to ensure that all statu...

Corrective Action Plan to Finding 2024‐001: Contact person for corrective action: Melissa Neal, Registrar Correction Action Plan: The University plans to implement the following: During the 2024‐2025 academic year, the Registrar Office will implement the following mechanisms to ensure that all status change records are reported to NLSDS accurately.  Reinforce training of individuals in the compliance and control ownership roles to ensure controls are operating as designed.  Ensure that individuals in compliance and control ownership roles within the Registrar’s office validated that enrollment files submitted were processed in the correct sequence.

View Audit 351524

Finding 547168 (2024-001)

Significant Deficiency 2024

Fort Thomas Unified School District No.7

AZ

Special Tests & Provisions Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

2024-001: PROVISIONS OF THE DAVIS-BACON ACT Program: Federal Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), Significant Deficiency in internal control Compliance Requirement: N. ...

2024-001: PROVISIONS OF THE DAVIS-BACON ACT Program: Federal Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), Significant Deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Repeat Finding: No. Condition/Context: During our testing on one of 1 contractor, we noted the District did not have adequate internal controls designed to ensure contractors were in compliance with applicable Davis-Bacon Wage Rate requirements. The District did not retain documentation supporting indication of certified payrolls being submitted in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by Impact Aid. In addition, contracts or purchase orders were not documented to support the need for compliance under Davis Bacon. Corrective Action: The District will establish internal control procedures during the purchasing process to ensure that all required vendors adhere to the provisions of the Davis Bacon Act and will obtain certified payroll reports to ensure compliance with those provisions. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Derrick Bryce, Business Manager

View Audit 351521

Finding 547165 (2024-006)

Significant Deficiency 2024

Georgetown College

KY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Perkins Loan Program, 84.038 Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work Study Program, 84.033 Criteria: The College is required to comply with 34 CFR Section 674.19, 34 CFR 675....

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Perkins Loan Program, 84.038 Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work Study Program, 84.033 Criteria: The College is required to comply with 34 CFR Section 674.19, 34 CFR 675.19 and 34 CFR 676.19. Condition: During our testing of the Fiscal Operations Report and Application to Participate (FISAP), we noted that Part II (Application), Section E, Line 22: total tuition and fees for the award year July 1, 2023 to June 30, 2024 did not agree or reconcile to the statement of activities. Cause: The College did not have controls in place to ensure FISAP reporting was accurate. Effect: The College did not follow federal regulations regarding FISAP reporting accuracy. The provisions of 34 CFR Section 674.19, 34 CFR 675.19 and 34 CFR 676.19 were not followed and thus the total tuition and fees for the award year July 1, 2023 to June 30, 2024 reported on the FISAP were greater than the tuition and fees on the statement of activities by $368,034. Questioned Costs: There are no questioned costs associated with this finding. Recommendation: We recommend that the College implement a control to ensure FISAP reporting is accurate. Corrective Actions Taken or Planned: The College concurs with the finding. A system of controls will be implemented to ensure accurate data is reported on all required reporting. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: August 2025

View Audit 351511

Finding 547163 (2024-004)

Significant Deficiency 2024

Georgetown College

KY

Student Financial Aid Eligibility Reporting

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a)(2). Condition: During our testing of eligibility, we selected 40 samples and noted three instances wher...

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a)(2). Condition: During our testing of eligibility, we selected 40 samples and noted three instances where the loan disbursement date on the student's leger did not agree to the disbursement date on Common Origination and Disbursement (COD). Cause: The College did not have controls in place to properly review COD disbursement dates to verify all students had proper reporting to COD. Effect: The College did not follow federal regulations regarding reporting to COD. The provisions of 34 CFR Section 685.301(a)(2) were not followed and thus three students loans were improperly reported to COD. Questioned Costs: There are no questioned costs associated with this finding. Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date and amount matches the student ledger. Corrective Action Taken or Planned: The College concurs with the finding. Controls have already been implemented to ensure accurate and timely reporting to COD. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: November 2024

View Audit 351511

Finding 547162 (2024-003)

Significant Deficiency 2024

Georgetown College

KY

Questioned Costs Student Financial Aid Eligibility

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a). Condition: During our testing of eligibility, we selected 40 samples and noted two instances where a s...

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a). Condition: During our testing of eligibility, we selected 40 samples and noted two instances where a student was disbursed a direct loan prior to entrance counseling being completed. Cause: The College did not have controls in place to ensure entrance counseling was completed prior to a loan disbursement. Effect: The College did not follow federal regulations regarding loan disbursements. The provisions of 34 CFR Section 385.304(a) were not followed and thus two students were improperly disbursed a direct loan. Questioned Costs: There are a total of $9,250 of questioned costs associated with this finding. $5,192j related to subsidized loans and $4,058 related to unsubsidized loans. Recommendation: We recommend that the College implement a control to ensure loans are not disbursed to students until entrance counseling has been completed by the student. Corrective Action Taken or Planned: The College agrees with the finding. Controls have already been implemented to ensure that compliance with all federal and state requirements are met before aid is disbursed. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: November 2024

View Audit 351511 Questioned Costs: $1

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