Corrective Action Plans

Finding 546939 (2024-001)

Significant Deficiency 2024

FL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Embry-Riddle Aeronautical University Corrective Action Plan Single Audit - Fiscal Year Ending 2024 Finding: 2024-001 Federal Program: Federal Direct Student Loans (ALN 84.268) Federal Pell Grant Program (ALN 84.063) Name(s) of the contact person(s) responsible for corrective action: • Julie Ferguson...

Embry-Riddle Aeronautical University Corrective Action Plan Single Audit - Fiscal Year Ending 2024 Finding: 2024-001 Federal Program: Federal Direct Student Loans (ALN 84.268) Federal Pell Grant Program (ALN 84.063) Name(s) of the contact person(s) responsible for corrective action: • Julie Ferguson, University Registrar • Edward Trombley, Registrar, Worldwide Campus • Ria Woods White, Senior Associate Registrar, Residential Campuses • Scott Johnson, Associate Registrar, University Registrar Office View of Responsible Officials: Registrar leadership agree with the audit finding and will implement additional review procedures to ensure that enrollment and graduate records are submitted to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Corrective Action Plan: Action Anticipated Completion Date Institute periodic internal reviews to ensure that the enrollment and graduation reporting process meet required standards. Ongoing Operationalize a duplicative review process for Worldwide enrollment and graduation report submissions. Ongoing

View Audit 351304

Finding 546936 (2024-006)

Material Weakness 2024

Urban College of Boston

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective a deficiency in the submission of enrollment data to the Clearinghouse. In April 2024 after t...

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective a deficiency in the submission of enrollment data to the Clearinghouse. In April 2024 after the 2023 audit, we identified there were issues with how our enrollment reporting was being submitted to the Clearinghouse. Unfortunately, these 2023-2024 findings occurred prior to the implementation of new process and timing of our Enrollment reporting since these results of the 2022-2023 audit. The Registrar updated their process to ensure the reporting date parameters are being reported correctly and that the last date of attendance is pulled into the fields needing to be reported to the National Student Loan Data System (NSLDS) as the Effective Date. Enrollment reporting is being reported more frequently and is submitted at the start of each term, subsequently within the term, and at the end of the term to ensure reporting timelines are met and that the withdrawal date and effective date match for reporting purposes. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Waqas Mirza, Registrar: Waqas.Mirza@urbancollege.edu

View Audit 351293

Finding 546934 (2024-005)

Significant Deficiency 2024

Urban College of Boston

MA

Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determine the errors are reflective of a knowledge gap in the established process for returning unearned funds for a withdrawn stu...

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determine the errors are reflective of a knowledge gap in the established process for returning unearned funds for a withdrawn student. This was a process gap oversight. When Urban College of Boson (UCB) contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year, the R2T4 return process is all done automated through a negative disbursement check register process. However, the funds that required Institutional Returns are a manual process and identified through a Refunds Due Report or as part of the students final Exit Packet Counseling documents. This report was missing as part of the workflow resulting in these students’ refunds being missed. The process has since been updated and the Director of Student Financial Services receives an automated Refunds Due Report (ineligible disbursement) every Monday. If there are students listed in the Refunds Due Report, this report is shared with the Business Office so funds can be returned based on amounts, funding type so they are processed timely. A secondary check point is also built into the process; If Urban has not returned the funds and 45 days from the students’ last date of attendance we will receive an automated notification from the Global Services system alerting us to the number of days we have left to make our returns. Since this issue was discovered the Director of Student Financial Services has gone back through all R2T4 student Exit Counseling packets to confirm that no other Institutional Returns were needed. No other issues were found. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 351293

Finding 546928 (2024-002)

Significant Deficiency 2024

Urban College of Boston

MA

Student Financial Aid Cash Management Reporting

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of a lack of understanding of procedures involved in posting and reporting to COD. In April...

Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of a lack of understanding of procedures involved in posting and reporting to COD. In April 2024 after the 2023 audit, we identified this as a gap in the Business Office process to ensure that dates disbursed matched the COD system. This process was rectified, and the business office staff was coached and trained. Unfortunately, these 2023-2024 findings occurred prior to the implementation and coaching of these new processes. Urban College of Boston (UCB) has contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year. Global FAS provides UCB with a monthly reconciliation report through our shared Secured File Transfer Protocol site (SFTP)and notifies us when one is ready to be reviewed. Once the file is received, the Business Office will conduct a secondary reconciliation using the Global FAS report. The Business Office will review the students ledger/billing and compare information with COD to ensure all disbursement information matches according to regulation. Urban College conducted a full reconstruction of COD dates to Ledger posting dates and ensured that all dates for this auditing period and current funding year disbursements are accurate. Urban College has also moved to a once-a-week disbursement schedule which will structure our reporting from our SIS system to COD and assist in the accuracy of our data review. Global Financial Services has been conducting a quarterly testing of our disbursement records to also ensure the accuracy of data. The Director of Financial Aid and Chief Finance Officer will continue to review procedures and update according to regulation and policy changes so potential gaps are discovered proactively. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 351293

Finding 546924 (2024-001)

Significant Deficiency 2024

San Bernardino Valley Municipal Water District

CA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303 § 200.327

The corrective action plan listed below is response to the San Bernardino Valley Municipal Water District’s single audit report for the fiscal year ending June 30, 2024, prepared by Rogers, Anderson, Malody and Scott, CPA’s 2024-001 - Lack of Internal Controls Over the Reporting Process Significant ...

The corrective action plan listed below is response to the San Bernardino Valley Municipal Water District’s single audit report for the fiscal year ending June 30, 2024, prepared by Rogers, Anderson, Malody and Scott, CPA’s 2024-001 - Lack of Internal Controls Over the Reporting Process Significant Deficiency Reclamation States Emergency Drought Relief Program, AL 15.514 Recommendation: We recommend that the District develop and implement formal policies and procedures to ensure that federal reports are reviewed for accuracy, completeness, and timeliness prior to submission. Management should assign responsibility for report preparation and review, implement checklists or reconciliation processes, and provide training to sta􀆯 involved in federal reporting. Corrective Action: To ensure compliance for future reporting, the District has implemented procedures that prior to submission of grant reporting, the accounting department will approve the report for all grant expenditures. In addition, the District has arranged for sta􀆯 training for employees involved with federal grants and reporting. Person Responsible for Corrective Action: Chief Financial O􀆯icer Senior Accountant Project Managers (Various Departments) Anticipated Completion Date for Corrective Action: Corrective Action is immediately implemented in response to the auditors’ recommendation.

View Audit 351292

Finding 546915 (2024-005)

Material Weakness 2024

The University of Chicago

IL

Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Finding No. 2024-005 Failure to Notify Recipients of Federal Direct Loan and Federal Pell Grant Disbursements ALNs: 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University created an automated process to send financial aid notifications on a regular basis. Comp...

Finding No. 2024-005 Failure to Notify Recipients of Federal Direct Loan and Federal Pell Grant Disbursements ALNs: 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: The University created an automated process to send financial aid notifications on a regular basis. Completed: January 31, 2024 Contact Person: Amanda Fijal

View Audit 351271

Finding 546911 (2024-003)

Material Weakness 2024

The University of Chicago

IL

Questioned Costs Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

Finding No. 2024-003 Failure to Determine Eligibility in Accordance with SFA Regulations ALNs: 84.007, 84.033, 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: Additional training will be provided to staff. Implementation Date: June 30, 2025 Contact Person: Amanda Fija...

Finding No. 2024-003 Failure to Determine Eligibility in Accordance with SFA Regulations ALNs: 84.007, 84.033, 84.063, 84.268 Program: Student Financial Assistance Cluster Corrective Action: Additional training will be provided to staff. Implementation Date: June 30, 2025 Contact Person: Amanda Fijal

View Audit 351271 Questioned Costs: $1

Finding 544788 (2024-002)

Material Weakness 2024

The University of Chicago

IL

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332 § 200.521

Finding No. 2024-002: Untimely Review of Subrecipient Single Audit Reports AL and Program Expenditures: Various ($539,084,567) Program Name: Research and Development (R&D) Cluster Corrective Action: Process Improvements: - The University began the annual review of Subrecipient Single Audit reports ...

Finding No. 2024-002: Untimely Review of Subrecipient Single Audit Reports AL and Program Expenditures: Various ($539,084,567) Program Name: Research and Development (R&D) Cluster Corrective Action: Process Improvements: - The University began the annual review of Subrecipient Single Audit reports for FY25 and the review schedule is currently on time and up to date. - Implement scheduled calendar appointment reminders to ensure Single Audit Reports are reviewed and completed on time. (Completed 1/6/2025) - Train additional staff member on subrecipient monitoring review process to assist during heavy volume periods. Expected Implementation: April 2025 Contact: Jennifer A. Ponting (Associate Vice President, Research Administration)

View Audit 351271

Finding 544787 (2024-001)

Material Weakness 2024

The University of Chicago

IL

Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303 § 200.313

Finding No. 2024-001: Inaccurate Property Management Records AL Numbers: Various Program Name: Research and Development Cluster Corrective Action: The Central Accounting team will conduct bi-annual equipment training with all departments of the University, scheduling virtual training with all equip...

Finding No. 2024-001: Inaccurate Property Management Records AL Numbers: Various Program Name: Research and Development Cluster Corrective Action: The Central Accounting team will conduct bi-annual equipment training with all departments of the University, scheduling virtual training with all equipment coordinators. Expected Implementation: June 30, 2025 and December 31, 2025 The University is researching equipment tagging software alternatives that will enhance tracking capabilities and enable asset tagging at a more granular level. The Central Accounting team will work with leadership to outline a timeline for a new tagging system. Expected Implementation: September 30, 2025 Contact: Kathy Conrad and Craig Elmore

View Audit 351271

Finding 544783 (2024-005)

Significant Deficiency 2024

Chestnut Hill College

PA

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

2024-005 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants - Assistance Listing No. 84.007, 84.063, 84.268, 84.379 Recommendation: The College should develop and implemen...

2024-005 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants - Assistance Listing No. 84.007, 84.063, 84.268, 84.379 Recommendation: The College should develop and implement an approved written information security program and verify there is a risk management section that describes how the College is identifying, assessing and communicating risks. In addition, there should be a description on the evaluation of safeguard sufficiency in mitigating risks. The information security program should also include the following: • IT Security Policy • Acceptable Use Policy • Incident Response Policy • Data Classification Policies • Vendor Management Policy • Patch Management Policy • Data Disposal Policy • Risk Assessment Policy • Logical Access and User Access Review Policies • Evidence of Review by CIO/CISO and responsibility of program Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will develop and implement an information security program to verify our risk management efforts. This plan will identify how we are identifying, assessing and communicating risk. Name(s) of the contact person(s) responsible for corrective action: Scott Seidman, Director of IT Planned completion date for corrective action plan: June 30, 2025

View Audit 351264

Finding 544781 (2024-004)

Significant Deficiency 2024

Chestnut Hill College

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

2024-004 Federal Pell Grant Program; Federal Direct Student Loans -Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the C...

2024-004 Federal Pell Grant Program; Federal Direct Student Loans -Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the College review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of the Registrar is reviewing its policies and procedures to ensure that all data is captured and reported in a timely manner as required by federal regulations. A software issue that caused inaccurate data to be reported has been identified and resolved by a software update. The Office of the Registrar is working with the Office of Information Technology to test the accuracy of the updated software. Name(s) of the contact person(s) responsible for corrective action: Micheal Reig, Registrar Planned completion date for corrective action plan: June 30, 2025

View Audit 351264

Finding 544777 (2024-003)

Significant Deficiency 2024

Chestnut Hill College

PA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

2024-003 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants- Assistance Listing Nos: 84.007, 84.063, 84.268, 84.379 Recommendation: We recommend the College review the R2T...

2024-003 Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants- Assistance Listing Nos: 84.007, 84.063, 84.268, 84.379 Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure scheduled breaks are properly factored into the R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Financial Aid will work with the Registrar to ensure that we receive the academic calendar in a timely manner. Once received, breaks will be verified by the Assistant Director of Financial Aid and then confirmed by the Director of Financial Aid. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025

View Audit 351264 Questioned Costs: $1

Finding 544776 (2024-002)

Significant Deficiency 2024

Chestnut Hill College

PA

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

2024-002 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding:...

2024-002 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the College review its policies and procedures around sending exit counseling information to students to ensure students are receiving proper counseling. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While the Office of Financial Aid has revamped how it manages exit notices and has made an improvement, our report has failed to pick up students that went from undergraduate to graduate in consecutive semesters. We will develop and implement a new report to ensure that this population is picked and exit notices are sent in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Jossie Johnson, Director of Financial Aid, and Micheal Reig, Registrar Planned completion date for corrective action plan: June 30, 2025

View Audit 351264

Finding 544747 (2024-004)

Material Weakness 2024

Zane Trace Local School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management

The District will work with the contractors to make sure the proper reports are submitted to meet the prevailing wage requirements agreed upon in the contract.

View Audit 351247

Finding 544746 (2024-001)

Material Weakness 2024

School Food and Nutrition Services of New Orleans, Inc.

LA

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring

For the unallowable loans from the School Food Service (SFS) account, we will execute a repayment agreement with terms and interest per the original agreement and annually submit proof of repayment and an assurance statement to the State Agency. To prevent recurrence, we will adopt policies prohibit...

For the unallowable loans from the School Food Service (SFS) account, we will execute a repayment agreement with terms and interest per the original agreement and annually submit proof of repayment and an assurance statement to the State Agency. To prevent recurrence, we will adopt policies prohibiting loans from the SFS account and train staff on fund restrictions under Uniform Guidance. We will also enhance review processes to ensure timely recording of interest receivable and proper structuring of amortization schedules. Policies for periodic reconciliation and agreement validation will be implemented, supported by financial software and accounting expertise, to ensure compliance with GAAP.

View Audit 351246 Questioned Costs: $1

Finding 544739 (2024-001)

Material Weakness 2024

Antioch College Corporation

OH

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Condition Found The College has borrowed from its endowment funds for campus renovations and to cover certain operating expenses of the College prior to and following its accreditation and approval to participate in federal student financial aid programs. As such, the fair value of assets associated...

Condition Found The College has borrowed from its endowment funds for campus renovations and to cover certain operating expenses of the College prior to and following its accreditation and approval to participate in federal student financial aid programs. As such, the fair value of assets associated with the donor-restricted endowment funds has fallen below the level that the donor or UPMIFA requires the College to retain as a fund of perpetual duration. Corrective Action Plan The College obtained guidance from legal counsel regarding the appropriateness of borrowing from the endowment fund under Ohio UPMIFA. The College has developed long-term plans for maintaining and sustaining its financial stability, including restoration of the endowment, through the following strategies outlined in the board-approved Social Enterprise and Enrollment Plan: ● Grow advancement-derived revenue ● Implement core college footprint ● Align student-derived revenue ● Activate learning hubs ● Explore potential game changers, such as the College’s recent Federal Work College designation ● Assess non-payroll cost reduction strategies ● Invest in additional capacity incrementally ● Monitor performance, evaluate results, and course-correct as needed Responsible Person for Corrective Action Plan Jane Fernandes, President

View Audit 351233

Finding 544736 (2024-007)

Material Weakness 2024

Liberty-Perry Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

Finding 2024-007 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: The Corporation Treasurer will review the Financial repo...

Finding 2024-007 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: The Corporation Treasurer will review the Financial report more closely and make sure that internal controls are in place to ensure compliance. Anticipated Completion Date: March 2025

View Audit 351229

Finding 544730 (2024-005)

Material Weakness 2024

Liberty-Perry Community School Corporation

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

Finding 2024-005 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: We will implement internal controls that will correct th...

Finding 2024-005 Contact Person Responsible for Corrective Action: Cindy Skinner, Corporation Treasurer Contact Phone Number: 765-282-5615 View of Responsible Official: We Concur with the Findings Description of Corrective Action Plan: We will implement internal controls that will correct the Allowable Activities and Costs procedures for Federal Grants. Anticipated Completion Date: March 2025

View Audit 351229

Finding 544724 (2024-004)

Material Weakness 2024

Liberty-Perry Community School Corporation

IN

School Nutrition Programs Eligibility Cash Management § 200.303

Finding 2024-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 We concur with the finding. Corrective Action plan: As of SY 24/25 when the High School Treasurer checks the 10% of the paper applications, she will make a...

Finding 2024-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 We concur with the finding. Corrective Action plan: As of SY 24/25 when the High School Treasurer checks the 10% of the paper applications, she will make a list of the ones she checked and it will be located in the application binder. As of March 1st, 2025 The Food Service Director will run a copy of Direct Certs that Titan has in their file, she will then cross check it with the list that is send from IDOE. She will keep both list together in a file after initialing it. Anticipated completion Date: March 2025

View Audit 351229

Finding 544713 (2024-003)

Significant Deficiency 2024

Puerto Rico Highways and Transportation Authority

PR

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.326

Finding Reference 2024-03 Corrective Action Plan: All personnel involved in the administration of programs that expend federal funds, including contractors and subcontractors, will receive adequate training on Davis-Bacon Act requirements and payroll certification processes. Responsible: Eng. Maria ...

Finding Reference 2024-03 Corrective Action Plan: All personnel involved in the administration of programs that expend federal funds, including contractors and subcontractors, will receive adequate training on Davis-Bacon Act requirements and payroll certification processes. Responsible: Eng. Maria Ayala Rivera, Construction Office Director Planned Implementation Date: In process. Expected to be completed on or before June 30, 2025.

View Audit 351216

Finding 544712 (2024-002)

Significant Deficiency 2024

Puerto Rico Highways and Transportation Authority

PR

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

Finding Reference 2024-02 Corrective Action Plan: The Authority has performed an internal review of the toll credits usage in the Excel spreadsheet and reconciled all credits used by projects with a start date of FY 2023 and forward against the latest version of the Federal-Aid Project Agreement app...

Finding Reference 2024-02 Corrective Action Plan: The Authority has performed an internal review of the toll credits usage in the Excel spreadsheet and reconciled all credits used by projects with a start date of FY 2023 and forward against the latest version of the Federal-Aid Project Agreement approved by the Federal Highway Administration (FHWA). In addition, credits are sent to the Executive Staff for the approval process on a quarterly basis. For fiscal year 2024, the manual process of reconciling toll credits for new projects with a start date of January 2024 or forward was changed to an automated process using the PMIS Program, as agreed with Section II of the Memorandum of Understanding (MOU) signed in February 2016 between FHWA and the Authority. Also, current toll credits tracking, reconciliation, and approval processes are reviewed by the FHWA. For projects with a start date before January 2024, the Authority will perform an internal review of the tolls credit usage against the later version of the Federal-Aid Project Agreement approved by FHWA. Additionally, the Authority is developing a Standard Operating Procedure (SOP) with FHWA for the use of Toll Credits in PMIS along with a new version of the Excel spreadsheet. Responsible: Mr. Enrique J. Rosa Torres, Executive Director of Administration and Finance Planned Implementation Date: In process. Expected to be completed on or before December 31, 2025.

View Audit 351216 Questioned Costs: $1

Finding 544706 (2024-002)

Significant Deficiency 2024

Tabor College, Inc.

KS

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Criteria or Specific Requirement - The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the chang...

Criteria or Specific Requirement - The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Condition - We noted discrepancies in the data reported in NSLDS compared to the data in the College’s records. Cause - The College’s processes and controls did not ensure that the effective dates were properly reported to NSLDS. Effect or potential effect - The NSLDS system is not updated with the correct student information which can cause a student to not properly enter the repayment period. Questioned costs - None Context - During our testing, we noted for three out of eleven students tested, the program begin date per the institution did not match the student's effective date reported to NSLDS. In addition, we noted for one out of eleven students tested the notification was not made within 60 days. Sampling was not a statistically valid sample. Identification as a repeat finding, if applicable - 2023-003 Recommendation - We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Views of responsible officials and planned corrective actions - Management concurs with the findings and recommendations. See separate report for planned corrective actions. Views of Responsible Officials and Corrective Action Plan – Management concurs with the findings and recommendation. Responsible personnel will review current guidance available from the Department of Education website and develop internal procedures to ensure timely compliance. This plan will include personnel and responsibility redundancy to account for employee absences or turnover, and a continuous review of available guidance to ensure the College stays current with any changes to this guidance. Additionally, monthly reconciliations have been added to the College’s procedures to ensure any errors are caught in a timely manner. Individual Responsible – Caleb Loss, Vice President for Business and Finance Anticipated Completion Date – April 2025

View Audit 351214

Finding 544698 (2024-001)

Significant Deficiency 2024

The Education Alliance-Business and Community for Public Schools, Inc.

WV

Questioned Costs Matching / Level of Effort / Earmarking § 200.430

Management has historically maintained robust timekeeping procedures to ensure time is allocated as accurately as possible based on projected activities. However, we recognize the need for a more timely process for making adjustments from estimated to actual time worked. To address this, the new pro...

Management has historically maintained robust timekeeping procedures to ensure time is allocated as accurately as possible based on projected activities. However, we recognize the need for a more timely process for making adjustments from estimated to actual time worked. To address this, the new program director scheduled quarerly meetings with our external accountant, beginning in April 2025, to review and update time allocations based on actual activity> We have also requested that fringe benefits be allocated in a manner consistent with how salalries are charged to the federal grant and will review to verify. These steps will ensure that both time and fringe benefit allocations more closely reflect actual effort and remain in alignment with federal grant requirements.

View Audit 351204 Questioned Costs: $1

Finding 544689 (2024-005)

Significant Deficiency 2024

Tusculum University

TN

Student Financial Aid Reporting Significant Deficiency

2024-005 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001 and 2023-003) Name of Contact Person Casey Reagan, Registrar, an...

2024-005 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001 and 2023-003) Name of Contact Person Casey Reagan, Registrar, and Melissa White, Director of Financial Aid, are responsible for enrollment reporting. Casey Regan for the data and Melissa White for uploading the report to clearinghouse. Corrective Action Planned During the audit, it was noted that Due to lapses in communication between departments, in certain instances, the University failed to provide NSLDS with accurate updates to student enrollment statuses, resulting in misrepresentation within the NSLDS system. While the university did implement changes from the prior year, including randomly sampling students, after this finding and looking into the issue that was occurring, we found three more issues with our clearinghouse data. The first issue was our graduation file that was sent to clearinghouse was not being processed and being rejected. We were unaware of the rejection of the records. We have worked with a clearinghouse representative and created a new way of pulling the graduate students report to ensure that their status is properly reported and sent to NSLDS. The second issue was that some student files were individually being rejected and thus not processing fully through. To correct this issue, we are watching the rejected clearinghouse files for individual students and are manually reporting their statuses if we cannot get the file to accept. The final and third issue was that students who were unofficially or administratively withdrawn were pulling the wrong date and thus the status was showing the wrong dates for the occurrence. To fix this, financial aid and the registrar are working in tandem to ensure that the correct date that the actual unofficial withdrawal or administrative withdrawal is correct. If necessary, we will manually certify these students as well. Anticipated Completion Date 03/01/2025

View Audit 351195

Finding 544680 (2024-002)

Material Weakness 2024

Whitley County Consolidated Schools

IN

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management § 200.303

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260...

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness Contact Person Responsible for Corrective Action: Todd Fleetwood, Director of Business and Operations Contact Phone Number: 260-244-5771 fleetwoodta@wccsonline.com Views of Responsible Official: Whitley County Consolidated Schools Todd Fleetwood Director of Business and Operations INDIANA STATE BOARD OF ACCOUNTS 21 107 North Walnut Street  Columbia City, Indiana 46725 Phone (260) 244-5771  Fax (260) 244-4590  Website http://wccsonline.com The School Corporation concurs with the finding. Description of Corrective Action Plan: The business office inadvertently omitted the reviewer’s sign-off on one of the grant reimbursement forms. This oversight will be promptly corrected. Anticipated Completion Date: 04/01/2025

View Audit 351189

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