Corrective Action Plans

Finding 1181295 (2025-004)

Material Weakness 2025

PA

Matching / Level of Effort / Earmarking Reporting

1. Recalculate the three-year MOE average and FFY 2024 qualifying state expenditures and reconcile to the Commonwealth’s accounting records. 2. Submit a corrected MOE Certification to HHS/ACL and formally notify the federal awarding agency of the error. 3. Revisit the existing MOE procedure that def...

1. Recalculate the three-year MOE average and FFY 2024 qualifying state expenditures and reconcile to the Commonwealth’s accounting records. 2. Submit a corrected MOE Certification to HHS/ACL and formally notify the federal awarding agency of the error. 3. Revisit the existing MOE procedure that defines qualifying expenditures, calculation methodology, documentation standards, and retention requirements. 4. Review current multi-level review process. 5. Implement quarterly MOE monitoring and variance analysis comparing projected state expenditures to required MOE levels, with reporting to leadership. 6. Provide mandatory training to fiscal staff on MOE requirements and 45 CFR §1321.9(c)(2)(vi). Anticipated Completion Date: 06/30/2026 Contact Names: Jason Kavulich, Secretary of Aging ; Jennifer Beck, Fiscal Management Specialist & PDOA Audit Liaison

View Audit 392533

Finding 1180989 (2025-003)

Material Weakness 2025

Borden-Henryville School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2025-003 CNC Eligibility Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Patty Kelley Contact Phone Number and Email Address: 812-913-9622 pkelley@bhsc.school Views of Responsible Officials: We concur with the finding Description of Co...

FINDING 2025-003 CNC Eligibility Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Patty Kelley Contact Phone Number and Email Address: 812-913-9622 pkelley@bhsc.school Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Direct Certification downloads will be done once a month by the Cafeteria Director. The Cafeteria Director will sign the report and forward it to the Treasurer for verification and a second signature. The Direct Certification reports will be kept at the central office. Anticipated Completion Date: This process will be in place by the end of the current fiscal year, June 30, 2026.

View Audit 392518

Finding 1180982 (2025-003)

Material Weakness 2025

Bergen Community College

NJ

Special Tests & Provisions Student Financial Aid Significant Deficiency

Views of Responsible Officials: The College acknowledges the audit finding that Return of Title IV (R2T4) calculations were not accurately completed for nine of the sixty students sampled, and that Title IV funds were not returned timely for fifteen of the sixty students sampled. During the audit pe...

Views of Responsible Officials: The College acknowledges the audit finding that Return of Title IV (R2T4) calculations were not accurately completed for nine of the sixty students sampled, and that Title IV funds were not returned timely for fifteen of the sixty students sampled. During the audit period, R2T4 tracking and oversight processes were in transition, which resulted in insufficient monitoring of calculation accuracy and timeliness. In addition, for several end-of-term cases involving unofficial withdrawals, the institution could not initiate R2T4 calculation until final grades were posted and an unofficial withdrawal determination was made based on non-passing (F) grades, in accordance with federal regulations governing unofficial withdrawals. The Fall 2024 semester ended on December 21st. The college was closed for the winter break and reopened January 2, 2025. Therefore, the Date of Determination (DOD) was not two days after the end of the semester but in January with the earliest available processing date being January 2, 2025. Corrective Action: The College has implemented enhanced internal controls to ensure compliance with Return of Title IV (R2T4) requirements. Responsibility for monitoring R2T4 calculations and timeliness has been assigned to the Director of Financial Aid and Compliance. A R2T4 tracking log has been established and is reviewed on a weekly basis to ensure that all official withdrawals are identified and processed within the required regulatory timeframe. For unofficial withdrawals, R2T4 calculations are initiated after the end of term once final grades are posted and an unofficial withdrawal date of determination (DOD) is made based on non-passing (F) grades, consistent with federal regulations. End-of-term R2T4 reviews for the fall semester are conducted upon return from winter break after the New Year to ensure complete and accurate academic records are available. Internal staff have received additional training on R2T4 regulatory requirements, timelines, and documentation standards. To ensure operational continuity, a senior specialist has been trained to manage R2T4 processing in the Director's absence. These corrective actions will strengthen internal controls and ensure accurate and timely processing of R2T4 calculations.

View Audit 392509

Finding 1180978 (2025-002)

Material Weakness 2025

Bergen Community College

NJ

Special Tests & Provisions Student Financial Aid Reporting

Views of Responsible Officials: After consultation with the College’s Information Technology department, management determined that the file was processed and submitted on time. However, the NSLDS discrepancy resulted from a data processing issue during the March 2025 enrollment status download. Spe...

Views of Responsible Officials: After consultation with the College’s Information Technology department, management determined that the file was processed and submitted on time. However, the NSLDS discrepancy resulted from a data processing issue during the March 2025 enrollment status download. Specifically, while the NSLDS file was being generated, staff from another office were simultaneously accessing the same student records. These concurrent activities caused the affected students’ enrollment statuses to default to data from a prior download, resulting in incorrect reporting for the two records of the sixty examined. Corrective action: The College has revised its NSLDS data reporting process to prevent a recurrence of concurrent access. A static, saved population list is now used to generate NSLDS enrollment status downloads, eliminating conflicts caused by concurrent system access. This change ensures that enrollment status data is not impacted and remains consistent at the time of submission. Management believes this corrective action adequately addresses the identified issue, strengthens controls, mitigate this issue for future status change reports, and allows for accurate submission within the required 60-day timeframe.

View Audit 392509

Finding 1180974 (2025-003)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Corrective action plan: The CAPPS Financials team uses Pathlock to monitor and log privileged user activities. Pathlock maintains documentation of approvals and business justifications. Documentation of recurring privileged access reviews will be maintained as appropriate across all dedicated CAPPS ...

Corrective action plan: The CAPPS Financials team uses Pathlock to monitor and log privileged user activities. Pathlock maintains documentation of approvals and business justifications. Documentation of recurring privileged access reviews will be maintained as appropriate across all dedicated CAPPS Financial modules. IAM team will establish a documented process through which it will coordinate with the CAPPS Financial team to perform quarterly reviews of accounts and audit logs to strengthen privileged access provisioning. The review process will include documented approval, business justification, and periodic revalidation for all elevated roles in CAPPS Financial. Pathlock software is being used to manage single sign-on for granting privileged access to allowed users. With this software, the IAM team can grant access to a user, who would then login as themselves and then switch to the appropriate privileged role. Once the user switches to a privileged role, the Pathlock software maintains the audit log of user activity. Implementation date: February 27, 2026 Responsible persons: Daniel Kellogg, Deputy Chier Information Officer (DCIO), Infrastructure Services Leatha Marr, DCIO & Chief Product Officer, System Applications

View Audit 392506

Finding 1180945 (2025-006)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking § 200.303

Corrective action plan: The Office of Area Agencies on Aging (OAAA) will update the General Revenue allocation procedures and workbook to allocate general revenue to Area Agencies on Aging (AAAs) in proportion to the associated federal awards to ensure they are not supplanting non-federal funds rela...

Corrective action plan: The Office of Area Agencies on Aging (OAAA) will update the General Revenue allocation procedures and workbook to allocate general revenue to Area Agencies on Aging (AAAs) in proportion to the associated federal awards to ensure they are not supplanting non-federal funds related to supportive services and senior centers. OAAA will provide in-service training for the OAAA Budget Analyst and Financial Analysts on the revised procedures and workbook. OAAA will provide training for AAAs on the revised procedures and workbook for managing Older Americans Act funds, General Revenue, and associated regulations. Implementation date: September 30, 2026 Responsible person: Lori Conner, Manager, OAAA Fiscal and Contract Oversight

View Audit 392506

Finding 1180922 (2025-005)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking

Corrective action plan: HHSC will discuss and make a decision on submitting a waiver request for the 10% setaside requirement. Implementation date: September 1, 2026 Responsible person: Roderick Swan, Associate Commissioner, Behavioral Health Services Operations

View Audit 392506

Finding 1180919 (2025-004)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Cash Management § 200.303

Corrective action plan: HHSC will run quarterly expenditure reports for this grant to monitor administrative earmarking thresholds. Implementation date: July 31, 2026 Responsible person: Roderick Swan, Associate Commissioner, Behavioral Health Services Operations

View Audit 392506

Finding 1180880 (2025-019)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Corrective action plan: THECB ITS will: • Develop and implement a standardized process for all user access reviews, including a required template which documents review date, reviewer identity, scope, results, and remediation actions. • Maintain all documentation in a centralized location on our ITS...

Corrective action plan: THECB ITS will: • Develop and implement a standardized process for all user access reviews, including a required template which documents review date, reviewer identity, scope, results, and remediation actions. • Maintain all documentation in a centralized location on our ITS SharePoint site. • Implement regular monitoring to ensure reviews are performed time, and the proper documentation is retained. • We will seek to automate processes where possible. Implementation date: July 1, 2026 Responsible person: Layla Young, Brian Nolte, Joel Anguiano

View Audit 392506

Finding 1180873 (2025-014)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Corrective action plan: A formalized process will be implemented, utilizing Standard Operating Procedures, to cover changes of hardware or software in relationship with network and infrastructure components. A change management tracking and approval system is under development that will be utilized ...

Corrective action plan: A formalized process will be implemented, utilizing Standard Operating Procedures, to cover changes of hardware or software in relationship with network and infrastructure components. A change management tracking and approval system is under development that will be utilized to track and provide audit logs of all network and infrastructure changes. Implementation date: August 31, 2026 Responsible person: Lars Hjaltman, CIO

View Audit 392506

Finding 1180826 (2025-002)

Material Weakness 2025

La Roche University

PA

Student Financial Aid HUD Housing Programs Matching / Level of Effort / Earmarking

Condition The federal aid disbursed resulted in a credit balance for one of the 25 students tested were not returned within 14 days of the date the credit balance occurred. Corrective Action Plan La Roche University concurs with the finding. The University’s procedures did not allow for timely payme...

Condition The federal aid disbursed resulted in a credit balance for one of the 25 students tested were not returned within 14 days of the date the credit balance occurred. Corrective Action Plan La Roche University concurs with the finding. The University’s procedures did not allow for timely payment of the funds to the student due to holidays that occurred. The Office of Student Accounts has implemented enhanced controls to ensure that credit balances are reviewed and issued refunds in a timely manner. Name(s) of Contact Person(s) Responsible for Corrective Action • Frank Corona, Controller • Dayna Tinkey, Director of Student Accounts Anticipated Completion Date All corrective actions were implemented as of February 12, 2026.

View Audit 392486

Finding 1180820 (2025-004)

Material Weakness 2025

Illinois State University

IL

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

Management Response: The University agrees with the finding. The identified issue was isolated and only impacted fall graduates. This issue was fully addressed when the university filed its fall 2025 enrollment reporting. The university has conducted an internal audit to identify students that were ...

Management Response: The University agrees with the finding. The identified issue was isolated and only impacted fall graduates. This issue was fully addressed when the university filed its fall 2025 enrollment reporting. The university has conducted an internal audit to identify students that were reported incorrectly and has manually updated files to ensure dates were properly reflected. At current state, internal monitoring and manual edits are made if discrepancies appear. The university has been in contact with PeopleSoft software related to the issue. Should the software issue not be resolved, the university plans to continue with manual edits to ensure proper reporting. Contact Person: Stacy Ramsey, University Registrar srramse@ilstu.edu Completion Date: December 2025

View Audit 392475

Finding 1180817 (2025-005)

Material Weakness 2025

Benton Community School Corporation

IN

Matching / Level of Effort / Earmarking § 200.207 § 200.303

Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Ot...

Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 23611-047-PN01, 22619-047-PN01, 22619-047-ARP, 23619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Significant Deficiency, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 22611-047-PN01, 22611-047-ARP, 23611-047-PN01, 22619-047-PN01, 22619-047-ARP, and 23619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $27,189, $5,074, $26,124, $1,171, $453, and $1,929, respectively. There were not sufficient non-public school expenditures incurred to meet the non-public proportionate share requirement for any of the six grants. The non-public school expenditures fell short of the minimum requirement by $11,679, $3,176, $16,405, $1,171, $4, and $1,929, respectively. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The cooperative has developed a written procedure for documenting expenditures related to the proportionate share earmarking requirement at the School Corporation level to address this issue going forward. The School Corporation will maintain the proper documentation to support the Non-Public Proportionate Share earmarking requirement and validate the earmarking requirement is met at the end of the grant’s period of performance or once fully expended. Responsible Party and Timeline for Completion: The corrective action plan has been put into place for the 2025-26 school year. Tracy Albertson, Director of Finance, and Sarah Claton, Director of Cooperative School Services, will oversee the corrective action plan.

View Audit 392466

Finding 1180811 (2025-004)

Material Weakness 2025

Benton Community School Corporation

IN

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.309 § 200.461

Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal ...

Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Period of Performance compliance requirements. Context: During fiscal year 2023-24, the School Corporation was a member of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01 and 22619-047-ARP grant awards, two exceptions were identified in the sample of five transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the two identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. This issue was isolated to fiscal year 2024. No costs incurred outside of the period of performance were identified in fiscal year 2025. Views of Responsible Officials and Corrective Action Plan: Management disagrees with part of the finding. The term “obligate” can be interpreted in various ways within our context. While we have a purchase order that was completed by September 30, we do agree that we changed vendors after September 30 and paid the non-public school directly. We agree with the finding that direct payment to a non-public school is not allowable. The purchase order is an internal written commitment to acquire the items/supplies, but it is not a binding written agreement to acquire “property” when we are purchasing supplies until it is provided to the vendor. The purchase order is authorization and approval to purchase the items/supplies. Once the purchase order is provided to the vendor, it is committed and is the binding written agreement. The invoice is an order to pay the obligation. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Sarah Claton, Cooperative School Services director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the cooperative on an ongoing basis.

View Audit 392466

Finding 1180724 (2025-001)

Material Weakness 2025

Mid-Ohio Foodbank

OH

Eligibility Reporting Procurement, Suspension & Debarment § 200.303 § 200.328

Finding Reference: 2025-001 – Reporting Condition: During testing of reporting compliance for major federal programs, we selected three of twelve monthly OAF reports submitted during the fiscal year. For each month tested, reported amounts did not reconcile to MOFC’s internal Poundage Distribution r...

Finding Reference: 2025-001 – Reporting Condition: During testing of reporting compliance for major federal programs, we selected three of twelve monthly OAF reports submitted during the fiscal year. For each month tested, reported amounts did not reconcile to MOFC’s internal Poundage Distribution reports and Product Code – Agencies by County reports. Specifically, we identified material variances between the OAF reports and internal distribution records, including: October 2024: ACP distributions were omitted from the OAF report, resulting in a variance of approximately 821,528 pounds (projected dollar impact of $262,889). January 2025: VA/Holiday Purchase distributions were omitted from the OAF report, resulting in a variance of approximately 310,898 pounds (projected dollar impact of $155,449). June 2025: Donated distributions, primarily Direct Retail Pickup (DRP) quantities, were omitted from the OAF report, resulting in a variance of approximately 933,505 pounds (projected dollar impact of $1,764,324). Additional differences were noted in purchased distributions of 40,399 pounds (projected dollar impact of $16,968). Although management provided explanations indicating that certain distributions were omitted in error or excluded due to differences in reporting scope, MOFC did not maintain documented reconciliations supporting the reported amounts. Evidence of review and approval demonstrating that differences were identified, investigated, and resolved prior to report submission was not provided. Views of Responsible Officials Items 1 & 2 are both failures of a report in our former ERP to include exception components and needed to be added manually when reporting. This is a result of human error. Item 3 is a result of a WIP component currently being installed into the new ERP to add in programmatic data for agency pickups. This is currently added manually for reporting purposes – also human error. Planned Corrective Action: Implementation of the Direct Retail Pickup poundage integrations into the current ERP will negate the necessity to manually enter the numbers. While this install is occurring, we will continue to manually update. Anticipated Completion Date: Initial discussions have occurred with an anticipated solution provided, tested and approved before the end of FY26 timeframe.

View Audit 392395

Finding 1180721 (2025-001)

Material Weakness 2025

City of Willows

CA

Special Tests & Provisions Subrecipient Monitoring Matching / Level of Effort / Earmarking

We recommend that the City develop and maintain policies and procedures regarding loan monitoring and ensure that all documentation of loan monitoring be maintained on an annual basis. Management's Response: The City concurs with the finding. Responsible Individual: Marti Brown, City Manager, and Jo...

We recommend that the City develop and maintain policies and procedures regarding loan monitoring and ensure that all documentation of loan monitoring be maintained on an annual basis. Management's Response: The City concurs with the finding. Responsible Individual: Marti Brown, City Manager, and Joei Harrison, Finance Director. Corrective Action Plan: The City will complete all required compliance reporting for CDBG activities in the futures. Anticipated Completion Date: July 2025

View Audit 392389

Finding 1180704 (2025-002)

Material Weakness 2025

Wauseon Exempted Village School District

OH

Allowable Costs / Cost Principles Cash Management Matching / Level of Effort / Earmarking § 200.303

Management is aware and understands the importance of compliance with the federal requirements and will ensure the meal counts will be properly reported in the future.

View Audit 392349

Finding 1180679 (2025-001)

Material Weakness 2025

Los Angeles Community College District

CA

Special Tests & Provisions Student Financial Aid Reporting

The District’s Educational Programs & Institutional Effectiveness (EPIE) and Information Technology (IT) divisions will continue reviewing the current programming, analyzing test cases, and studying the more complex system changes required to address the misalignment between the student status effec...

The District’s Educational Programs & Institutional Effectiveness (EPIE) and Information Technology (IT) divisions will continue reviewing the current programming, analyzing test cases, and studying the more complex system changes required to address the misalignment between the student status effective date reported to the NSC and the date recorded in the PeopleSoft enrollment reporting system. Because the necessary programming updates are more intricate than initially anticipated, additional analysis and testing will be needed before implementing a long-term solution. EPIE will continue to monitor post-submission errors and warning reports to assess the effectiveness of the programming changes. Personnel Responsible for Implementation: Mily Kudo, Andrew Alvarez, Stan Levin Position of Responsible Personnel: Associate Vice Chancellor, IT Business Analyst, Research Analyst Expected Date of Implementation: March 2026

View Audit 392342

Finding 1180561 (2025-018)

Material Weakness 2025

Nevada System of Higher Education

NV

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.306

Matching, Level of Effort, and Earmarking Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN Office of Grants and Contracts Post-Award Management received...

Matching, Level of Effort, and Earmarking Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN Office of Grants and Contracts Post-Award Management received approval from the award sponsor to perform a budget revision to remove office space usage from the cost share. The Office of Grants and Contracts Post-Award Management also advised the Office of Sponsored Projects to avoid using unallowable cost share expenses in award applications. ● How compliance and performance will be measured and documented for future audit, management and performance review. CSN Office of Grants and Contracts Post-Award Management will continue to monitor award budgets to avoid using unallowable cost share expenses. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Office of Grants and Contracts Post-Award manager is accountable for exercising oversight and responsibility. GBC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o GBC will standardize a cost share calculation workflow between the Grants and Business Operations departments to ensure proper calculation and review against payroll records. o GBC also will formalize written internal procedures for cost share calculation and documentation and distribute to relevant staff. o All corrective actions were implemented immediately upon identification of the finding and will be fully in place within 30 days of notification. The revised procedures are now standard practice for all grants requiring cost share. ● How compliance and performance will be measured and documented for future audit, management and performance review. o A cost share verification checklist will accompany each cost share transaction and will be retained in each year’s grant file. This internal review will confirm: (1) use of current salary data; (2) mathematical accuracy; and, (3) proper documentation support. o Grant financial reports will include documented evidence of secondary review prior to submission. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and the Director of Business Operations are responsible for oversight of grant compliance. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP has enforced a required cost share form to be completed, and will require that documentation be attached and verified before submission to the sponsor. For effort identified as cost share, a new process is currently being tested to capture it in the financial system. The cost share policy will be updated before the end of spring semester and disseminated to the campus community for immediate implementation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Verifiable documentation will be required upon review/submission to be uploaded with the financial report in Workday. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the Principal Investigator’s documentation. UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management will implement quarterly review of all gift accounts used for cost share to ensure that they are properly established and correctly linked to the award through a GR cost share line, which will generate the required effort certification process. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through a review and confirmation that all cost share transactions are accurately recorded, supported, and associated with the appropriate worktags.  ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; WNC will continue its FY26 adopted internal control processes by implementing a two-step review process for all invoicing, including match verification and reporting. The assistant controller creates the invoice packet and submits it to the grant administrator for review and approval. The packet then has a secondary and final review and approval by the vice president of finance and administration. The sampled transaction occurred before internal controls were in place. Internal controls were implemented in October 2025. ● How compliance and performance will be measured and documented for future audit, management and performance review. The grant administrator maintains records of monthly invoicing reviews, including time-stamped email receipts, internal tracking spreadsheets, and Workday transactions. Workday transactions provide actuals for each invoice period, which are compared to the internal tracking spreadsheet to determine the totals to be invoiced/reported. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Final responsibility and accountability fall on the grants administrator. SA – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The spreadsheet that System Administration uses to track in-kind cost share was not correctly updated when the fringe rate changed at the beginning of the fiscal year. The Post-Award Manager will update the spreadsheet each July when the fringe rate is confirmed and run effort reports using the current salary and fringe rates. ● How compliance and performance will be measured and documented for future audit, management and performance review. The Office of Sponsored Programs will document that the fringe rate for the new fiscal year has been reviewed, and that the in-kind cost share spreadsheet was updated each July. Documentation will be included in the cost share file. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The System Administration Office of Sponsored Programs Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 392299

Finding 1180527 (2025-017)

Material Weakness 2025

Nevada System of Higher Education

NV

Cash Management Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Cash Management Responses WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of du...

Cash Management Responses WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 392299

Finding 1180523 (2025-016)

Material Weakness 2025

Nevada System of Higher Education

NV

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

Allowable Costs/Cost Principles Responses GBC accepts the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o GBC maintains evidence of review and approval of the payroll expenses in questi...

Allowable Costs/Cost Principles Responses GBC accepts the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o GBC maintains evidence of review and approval of the payroll expenses in question. GBC is very willing to enhance internal controls to provide for documented review and approval for terminated employees charged to the grant program. o GBC has strengthened internal controls over payroll expenditures charged to federal grants to ensure documented review and segregation of duties, particularly for terminated employees. o Documented evidence of review and approval will be retained within the payroll/grants file to ensure a clear audit trail. o Human Resources and Grants Accounting staff have been reminded of federal documentation requirements specific to grant-funded payroll expenditures. ● How compliance and performance will be measured and documented for future audit, management and performance review. o Quarterly internal reviews of payroll expenditures charged to federal grants, with specific review of terminated employees. o Retention of documented approval evidence in electronic grant files. o Review during annual fiscal year-end grant reconciliations. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and Director of Business Operations are responsible for oversight of grant compliance. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 392299

Finding 1180487 (2025-014)

Material Weakness 2025

Nevada System of Higher Education

NV

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management Staff, independent of preparer, will review each subaward report required. The review ...

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management Staff, independent of preparer, will review each subaward report required. The review process will include verifying that all subaward information required by FFATA is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify the information in each report is accurate. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Pre Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 392299

Finding 1180482 (2025-010)

Material Weakness 2025

Nevada System of Higher Education

NV

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.306

Matching, Level of Effort, and Earmarking Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP has mandated a required cost share form to be comple...

Matching, Level of Effort, and Earmarking Responses UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; The UNLV OSP has mandated a required cost share form to be completed and will require that the documentation be attached and verified before submission to the sponsor. For effort identified as cost share, a new process is currently being tested to capture it in the financial system. The cost share policy will be updated before the end of spring semester and disseminated to the campus community for immediate implementation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Verifiable documentation will be required upon review/submission to be uploaded with the financial report in Workday. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with Principal Investigator’s documentation. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

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Finding 1180477 (2025-003)

Material Weakness 2025

Nevada System of Higher Education

NV

Cash Management Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

Cash Management Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Controls were implemented beginning on April 14, 2025, to require secondary approvals on al...

Cash Management Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Controls were implemented beginning on April 14, 2025, to require secondary approvals on all sponsored invoice transactions. NSHE’s accounting system was reconfigured to require a review step for all invoice business processes. An individual other than the preparer must now review and approve all transactions. ● How compliance and performance will be measured and documented for future audit, management and performance review. Documentation for all sponsor invoice transactions occurs through the business process history in the accounting system. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV Office of Sponsored Programs (OSP) has an internal control that requires a reconciliation form to be completed with each invoice submission. With any manual control, human error may occur, as in this case; however, the reconciliation form is used every time and is reviewed by the originator and approving authority. ● How compliance and performance will be measured and documented for future audit, management, and performance review. Reinforcement of cross-checking of the reconciliation form is enforced and will be used as documentation for review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 392299

Finding 1179944 (2025-005)

Material Weakness 2025

Northern Illinois University

IL

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

Finding 2025-005 Errors in Verification Reporting Condition: Northern Illinois University (University) did not properly code the verification status in the Common Origination and Disbursement (COD) System for students who were disbursed Pell Grant funds and later selected for verification and the in...

Finding 2025-005 Errors in Verification Reporting Condition: Northern Illinois University (University) did not properly code the verification status in the Common Origination and Disbursement (COD) System for students who were disbursed Pell Grant funds and later selected for verification and the internal controls in place did not prevent and detect the exceptions. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) University procedures have been updated to ensure verification status updates are properly transmitted to the Common Origination and Disbursement (COD) system upon completion of verification. Relevant staff have been trained on the revised procedures. 2) University has implemented a process to periodically review records and confirm that verification statuses are accurately reflected in COD. All affected student records have been reviewed and corrected. It has been confirmed in the National Student Loan Data System (NSLDS) that none of the mis-reported statuses resulted in an overpayment. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2026

View Audit 392281

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