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Finding 2025-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not prevent and...
Finding 2025-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not prevent and detect errors. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1. The University will review and strengthen its current enrollment reporting procedures to ensure Program-Level updates are completed consistently, particularly in cases involving unofficial withdrawals. 2. The University will develop a batch reporting process for unofficial withdrawals to facilitate accurate enrollment reporting at both the program and campus level. Additional verification steps will be implemented prior to submission to confirm that both campus-level and program-level enrollment statuses are properly updated. 3. The University will also reinforce staff training related to NSLDS reporting requirements and enhance supervisory review procedures to reduce the risk of similar errors occurring in the future. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2026
Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Ot...
Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion Context: The School Corporation did not obtain the weekly payroll reports certifications from a company that performed renovations to replace HVAC equipment and install windows in the building. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $696,118 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Nathaniel Day Contact Phone Number: 317-462-4434 . Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will comply with Bacon Davis on future projects using federal funds.
Federal Pell Grant Program; Federal Stafford Loans Program; Federal Parents’ Loans Program for Undergraduate Students; Federal Graduated Plus Loan – Assistance Listing No. 84.063; 84.268 Recommendation: We recommend the University evaluate its procedures for sending enrollment information to the NSL...
Federal Pell Grant Program; Federal Stafford Loans Program; Federal Parents’ Loans Program for Undergraduate Students; Federal Graduated Plus Loan – Assistance Listing No. 84.063; 84.268 Recommendation: We recommend the University evaluate its procedures for sending enrollment information to the NSLDS, especially around graduated enrollment information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated its policies and procedures for NSLDS submissions via their third-party servicer to ensure relevant information is being captured and reported timely in accordance with applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Kamla Singh-Ramoutar, University Registrar, (201) 761-6051 Planned completion date for corrective action plan: Completed
Program: AL 21.023 – COVID-19 Emergency Rental Assistance Program – Reporting Corrective Action Plan: The categorization issue was corrected on the ERA2 Closeout report. Contact: Philip Olsen Anticipated Completion Date: January 28, 2026
Program: AL 21.023 – COVID-19 Emergency Rental Assistance Program – Reporting Corrective Action Plan: The categorization issue was corrected on the ERA2 Closeout report. Contact: Philip Olsen Anticipated Completion Date: January 28, 2026
Program: AL 21.023 – COVID-19 Emergency Rental Assistance Program – Allowability & Eligibility Corrective Action Plan: The ERA2 program officially concluded as of September 30, 2025. Because the program ended, there will be no further eligibility determinations to be made and no additional action is...
Program: AL 21.023 – COVID-19 Emergency Rental Assistance Program – Allowability & Eligibility Corrective Action Plan: The ERA2 program officially concluded as of September 30, 2025. Because the program ended, there will be no further eligibility determinations to be made and no additional action is necessary. On all other grant programs for which the Agency is the recipient, eligibility determinations are a shared responsibility of the Agency and the funding entity. Contact: Erv Portis Anticipated Completion Date: Complete
Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.991 – Preventative Health and Health Services Block Grant – Allowability & Subrecipient Monitoring Corrective Action Plan: DHHS has implemented enhanced subrecipient monitoring procedures desi...
Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.991 – Preventative Health and Health Services Block Grant – Allowability & Subrecipient Monitoring Corrective Action Plan: DHHS has implemented enhanced subrecipient monitoring procedures designed to strengthen oversight and documentation requirements. Corrective actions include: - Termination of the subaward agreements with the Karen Society of Nebraska. - Issuance of a formal demand for repayment and initiation of collection actions for disallowed costs. - Implementation of a standardized Subrecipient Monitoring Procedures Manual outlining documentation expectations, desk review requirements, and risk-based monitoring activities. - Strengthened front-end invoice review processes to require sufficient financial source documentation prior to reimbursement. - Increased coordination between program and fiscal staff when a subrecipient receives funding from multiple programs or divisions. - Ongoing monitoring and verification of corrective actions through routine monitoring activities and future audits. Contact: Ryan Daly Anticipated Completion Date: November 20, 2025
Program: AL 93.959 – Block Grants for Prevention and Treatment of Substance Abuse – Level of Effort Corrective Action Plan: DBH will utilize the Women’s Set Aside (WSA) budget subprogram to identify applicable MOE expenditures. Also, DBH will utilize the Electronic Billing System (EBS) to verify if ...
Program: AL 93.959 – Block Grants for Prevention and Treatment of Substance Abuse – Level of Effort Corrective Action Plan: DBH will utilize the Women’s Set Aside (WSA) budget subprogram to identify applicable MOE expenditures. Also, DBH will utilize the Electronic Billing System (EBS) to verify if other WSA services have been paid with other sources or business units and, if applicable, will utilize Medicaid State WSA dollars provided by the Division of Medicaid. Contact: Valerie Standeven; Christine Mohlman; Diana Meadors Anticipated Completion Date: August 18, 2026
Program: AL 93.778 – Grants to State for Medicaid – Allowability Corrective Action Plan: This issue arose from an oversight: Optum’s rate sheet listed calendar-year 2022 dates, but the rates corresponded to 2023. As a result of this error in the file received from Optumas, staff mistakenly processed...
Program: AL 93.778 – Grants to State for Medicaid – Allowability Corrective Action Plan: This issue arose from an oversight: Optum’s rate sheet listed calendar-year 2022 dates, but the rates corresponded to 2023. As a result of this error in the file received from Optumas, staff mistakenly processed the 2022 capitation adjustment using the 2023 rates. The overcharged Federal amount will be refunded to CMS. Contact: Snita Soni Anticipated Completion Date: April 30, 2026
Program: AL 93.778 – Grants to States for Medicaid – Allowability & Eligibility Corrective Action Plan: The Agency has standard operating processes and procedures however worker error resulted in these conditions. The Agency will ensure established standard processes are followed. Additionally, user...
Program: AL 93.778 – Grants to States for Medicaid – Allowability & Eligibility Corrective Action Plan: The Agency has standard operating processes and procedures however worker error resulted in these conditions. The Agency will ensure established standard processes are followed. Additionally, user guides and training materials will be reviewed and updated if deemed necessary for clarity. New guidance material will be issued if deemed necessary. Individual staff who made the errors will be followed up with to ensure they understand the policies. Contact: Tiffanie Green Anticipated Completion Date: June 30, 2026
Program: AL 93.659 – Adoption Assistance – Level of Effort & Reporting Corrective Action Plan: The FFR instructions in the workpapers will be revised to include instructions that are in accordance with Level of Effort and Reporting Requirements. In addition, the Adoption Savings Data (for lines 10-1...
Program: AL 93.659 – Adoption Assistance – Level of Effort & Reporting Corrective Action Plan: The FFR instructions in the workpapers will be revised to include instructions that are in accordance with Level of Effort and Reporting Requirements. In addition, the Adoption Savings Data (for lines 10-12) will be revised to only include the federal portion of expenditures in accordance with the Level of Effort and Reporting Requirements. Contact: Ann Murphy; Bryan Gilliland Anticipated Completion Date: June 30, 2026
Program: AL 93.659 – Adoption Assistance – Allowability Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will be completed to identify enha...
Program: AL 93.659 – Adoption Assistance – Allowability Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will be completed to identify enhancements to this area. The Agency will develop a new fraud prevention process for the Resource Development team to enhance controls over attendance, billing, and the auditing of provider claims, and to ensure compliance. A Provider Probation process will be implemented to address identified billing concerns. Contact: Nicole Vint Anticipated Completion Date: September 30, 2026
Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The spreadsheet has been corrected and a journal entry will be completed to correct the amount billed to IV-E. Contact: Bryan Gilliland Anticipated Completion Date: February 28, 2026
Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The spreadsheet has been corrected and a journal entry will be completed to correct the amount billed to IV-E. Contact: Bryan Gilliland Anticipated Completion Date: February 28, 2026
Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will be completed to identify e...
Program: AL 93.658 – Foster Care Title IV-E – Allowability Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will be completed to identify enhancements to this area. The Agency will develop a new fraud prevention process for the Resource Development team to enhance controls over attendance, billing, and the auditing of provider claims, and to ensure compliance. A Provider Probation process will be implemented to address identified billing concerns. Contact: Nicole Vint Anticipated Completion Date: September 30, 2026
Program: AL 93.575 and 93.596 – CCDF Cluster – Allowability & Eligibility & Matching Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will ...
Program: AL 93.575 and 93.596 – CCDF Cluster – Allowability & Eligibility & Matching Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will be completed to identify enhancements to this area. The Agency will develop a new fraud prevention process for the Resource Development team to enhance controls over attendance, billing, and the auditing of provider claims, and to ensure compliance. A Provider Probation process will be implemented to address identified billing concerns. The Agency will evaluate current regulations and requirements surrounding provider rate increases related to the Step Up to Quality provider rate enhancements and develop a process to address concerns with exceeding private pay rates. Contact: Nicole Vint Anticipated Completion Date: September 30, 2026
Program: AL 93.568 – Low-Income Home Energy Assistance – Reporting Corrective Action Plan: The Agency will improve the current process to ensure accurate and timely submission of FFATA reporting. Contact: Heather Arnold Anticipated Completion Date: June 30, 2026
Program: AL 93.568 – Low-Income Home Energy Assistance – Reporting Corrective Action Plan: The Agency will improve the current process to ensure accurate and timely submission of FFATA reporting. Contact: Heather Arnold Anticipated Completion Date: June 30, 2026
Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs – Allowability & Eligibility Corrective Action Plan: The Refugee Resettlement Program has requested eligibility system changes to prevent eligibility errors. In addition, the Refugee Resettlement Pro...
Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs – Allowability & Eligibility Corrective Action Plan: The Refugee Resettlement Program has requested eligibility system changes to prevent eligibility errors. In addition, the Refugee Resettlement Program performs monthly reviews of RMA enrollees and will coordinate case reviews with the RMA team to ensure comprehensive case review. Retraining of eligibility staff will occur as needed. Contact: Sara Bockelman Anticipated Completion Date: April 30, 2026
Program: AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Reporting Corrective Action Plan: The NDE is in the process of reviewing all FFATA rules and regulations. Within the next three months business rul...
Program: AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Reporting Corrective Action Plan: The NDE is in the process of reviewing all FFATA rules and regulations. Within the next three months business rules will be established to ensure all federal regulations are being followed when reporting FFATA on a monthly basis. We will have our FFATA Specialist make the corrections in the SAM.gov system to ensure this subaward is reported. This will occur in the next two weeks. As we continue to establish the FFATA procedures we will continue to implement the double checking of all FFATA entries to ensure all funds are reported in the system. Contact: Dottie Heusman, ESEA Assistant Administrator Anticipated Completion Date: June 30, 2026
Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Reporting Corrective Action Plan: An additional review will be completed by NDE Budget and Grant Management staff to ensure accuracy. Contact: Cathy Callaway Anticipated Completion Date: Completed
Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Reporting Corrective Action Plan: An additional review will be completed by NDE Budget and Grant Management staff to ensure accuracy. Contact: Cathy Callaway Anticipated Completion Date: Completed
FINDING 2025-002 Name of Responsible Individual: Mary Mercer, Director Student Financial Services Corrective Action: Issue: The current refund report used to monitor Title IV refunds has limitations that affected the completeness of data reviewed. Reports rely on manual batch postings, which can del...
FINDING 2025-002 Name of Responsible Individual: Mary Mercer, Director Student Financial Services Corrective Action: Issue: The current refund report used to monitor Title IV refunds has limitations that affected the completeness of data reviewed. Reports rely on manual batch postings, which can delay or omit certain transactions at the time of report generation. This created gaps in monitoring and potential human error. Action Step Responsible Party Timeline Transition to new system – Implement refund reporting to reduce manual errors and improve completeness. Student Financial Services & IT (if needed) Full adoption by Academic Year 2026–2027 Staff training – Provide comprehensive training to Student Financial Services staff on new system processes, reporting, and controls for Title-IV refunding. Ellucian Consultant & Student Financial Services When training session is scheduled through first report in 2026-2027 Interim verification controls – Conduct weekly reconciliation of batch postings and verifications that all Title IV refunds are captured until the new system is fully operational. Student Financial Services & Controller’s Office Immediate until system adoption Validation & reconciliation process – Establish a formal process within the new system to ensure all refunds are accurately captured and reported. Student Financial Services By first full report in 2026–2027
Finding 2025-004 a. Program Name: Head Start and Early Head Start b. Criteria or Specific Requirement: Failure to comply with the grant agreement’s terms and applicable regulations: The Organization did not comply with grant compliance requirements such as timeliness of submitting reports to funding...
Finding 2025-004 a. Program Name: Head Start and Early Head Start b. Criteria or Specific Requirement: Failure to comply with the grant agreement’s terms and applicable regulations: The Organization did not comply with grant compliance requirements such as timeliness of submitting reports to funding agencies and meeting matching requirements. c. Condition: The Organization had inconsistent performance on the submission of periodic grant reports in a timely matter. This submission pattern conflicts with grant timelines outlined in the Notice of Awards. Specifically, it was noted for one of Organization’s major programs, Head Start and Early Head Start, that reports were submitted outside of defined due dates. The Form SF-429 was not filed for the 2025 fiscal year. Further, Head Start and Early Head Start experienced 2 delayed reports. Management informed us that the delays in reporting were attributable to submission issues on the federal reporting platform, which temporarily prevented timely filling despite management’s attempts to complete the report. Once access to submission was granted, management promptly submitted the required report. d. Response: Turnover in the personnel responsible for submitting reports lead to the initial late submission. The management will ensure all the reports to be submitted within the defined due dates. In terms of matching, the Organization has made a waiver request and believes in the success of obtaining the waiver.
Finding: 2025-003 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number(s): 93.493 Program Name: Community Project Funding Finding Summary: Uniform Guidance at 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over f...
Finding: 2025-003 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number(s): 93.493 Program Name: Community Project Funding Finding Summary: Uniform Guidance at 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing federal awards in compliance with applicable laws, regulations, and the terms and conditions of the award. Effective internal control includes appropriate independent review of reports to ensure accuracy prior to submission. During our testing over the report submissions for the fiscal year, we noted there was not an independent review completed over the quarterly expenditure report. Responsible Individuals: Michael Pollock, CFO and Debbie Dice, Director, Financial Reporting, Audit/Compliance Corrective Action Plan: There was transition in several of the key roles during the fiscal year, causing the review not to be completed over the quarterly submissions that will be rectified during 2025-26. Internal controls will be updated with the following steps: 1) Quarterly federal expenditure reports will be prepared by the an assigned Accountant II member and reviewed by a the Director of Financial Reporting, Audit and Compliance prior to submission to the granting agency; 2) Obtain evidence of the independent review, including reviewer sign-off and date of review, will be documented and retained with the report submission records; 3) The College will update written internal control procedures governing federal grant reporting to formally incorporate the independent review requirement; and 4) The Director of Financial Reporting, Audit and Compliance will monitor adherence to the review process and ensure that documentation is maintained for audit purposes. Anticipated Completion Date: June 2026
Finding: 2025-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033 Program Name: Student Financial Assistance Cluster Finding Summary: Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(...
Finding: 2025-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.063, 84.007, 84.268, 84.033 Program Name: Student Financial Assistance Cluster Finding Summary: Institutions that implement an affirmative confirmation process (as described in 34 CFR 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan. Institutions that do not implement an affirmative confirmation process must notify a student no earlier than 30 days before, but no later than seven days after, crediting the student’s account and must give the student 30 days (instead of 14) to cancel all or part of the loan. Responsible Individuals: Frankie Everett, Director, Financial Aid Corrective Action Plan: The College implemented a new ERP system in the current year that caused delays in notifying students of their loan disbursements. PowerFAIDS allows documenting the email sent to students in the Communication Log, but a box has to be checked when the email batch is sent. This step was inadvertently missed in several batches so we cannot confirm the email was sent. The Department is working to automate the emails with a college-hired consultant. In the meantime, the Financial Aid Operations Coordinator (Jessica Jones) is double-checking that disbursement emails are going out each week. Anticipated Completion Date: June 2026
FINDING 2025-002 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: I...
FINDING 2025-002 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Wage Rate Requirements Audit Finding: Material Weakness 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 Special Tests and Provisions – Wage Rate Requirements compliance requirements. Context: The School Corporation had one project for a bus garage addition that which was funded with ESSER III (84.425U) grant awards. The School Corporation did not execute a formal contract with the vendor as the transaction was under the simplified acquisition threshold of $150,000. As such, there was no internal controls to communicate required prevailing wage rate requirements to the vendor prior to entering into the transaction. The School Corporation did obtain the weekly wage reports from the vendor. The total project cost disbursed during the audit period was $88,727, which included materials and labor. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. We did not have a formal contract for this project. It was below a threshold that we had used before that necessitated a formal contract. We now understand that we should have gotten a formal contract in place because this is federal funding. We used the quotes that were provided, and the school board approved the expenditures at a school board meeting. In the future, we will secure a formal contract for all federal funds. Responsible Party and Timeline for Completion: Tara Bishop, Superintendent. Completed 3/1/24.
Material Weakness in Internal Control over Compliance and Compliance 2025-002 Special Tests and Provisions. Criteria The District is required to maintain records that support the removal of a student from the adjusted cohort, such as documentation to transfer to another diploma granting program, emi...
Material Weakness in Internal Control over Compliance and Compliance 2025-002 Special Tests and Provisions. Criteria The District is required to maintain records that support the removal of a student from the adjusted cohort, such as documentation to transfer to another diploma granting program, emigration, consistent with federal reporting requirements. Statement of Condition We identified instances in which the District had students removed from the adjusted cohort, but did not maintain sufficient written documentation to support the removal. Statement of Cause The District did not have adequate procedures to ensure that the documentation supporting adjusted cohort removals was obtained, reviewed, and retained. Possible Asserted Effect Without appropriate documentation supporting removal of students from the adjusted cohort, the District is unable to demonstrate compliance with federal record keeping requirements. Questioned Costs None noted. Context A sample of 25 students that had withdrawn was selected and 3 student files were not able to be provided. Repeat Finding: This is not a repeat finding. Recommendation We recommend that a process be implemented to ensure appropriate written documentation is maintained for all student withdraws. Views of responsible officials and planned corrective action To ensure compliance with this standard in the future, we have created a specific folder within our Student Information System for uploading and maintaining all withdrawal paperwork. All staff responsible for processing withdrawals have received instructions for this updated procedure via email and the guidance has also been added to the Secretary’s Manual.
Finding 2025-004 Supplanting Controls – Significant Deficiency Condition: Lack of controls to prevent supplanting in the Student Support and Academic Enrichment program; presumption of supplanting rebutted but controls not in place. Corrective Action Plan: Implement pre-award and annual budget revie...
Finding 2025-004 Supplanting Controls – Significant Deficiency Condition: Lack of controls to prevent supplanting in the Student Support and Academic Enrichment program; presumption of supplanting rebutted but controls not in place. Corrective Action Plan: Implement pre-award and annual budget review procedures to document that state/local funds are not used for activities proposed for federal funding and document any rebuttals in grant and budget records. Responsible Official: Holly Langan, Managing Officer for Financial Services Timeline: Implementation completed by June 30, 2026. 113
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