Corrective Action Plans

Finding 1175757 (2025-005)

Material Weakness 2025

NC

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

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

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

View Audit 389665

Finding 1175753 (2025-001)

Material Weakness 2025

High Point University

NC

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

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

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

View Audit 389665

Finding 1175752 (2025-008)

Material Weakness 2025

University of the Incarnate Word

TX

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303 § 200.430

Finding 2025-008 – Allowable Costs/Cost Principles and Matching, Level of Effort, and Earmarking Contact Person: Susan Rios, Grants Manager Current status: In-Progress Anticipated Completion Date: February 06, 2026 Condition: The University did not have effective internal controls over the timely pr...

Finding 2025-008 – Allowable Costs/Cost Principles and Matching, Level of Effort, and Earmarking Contact Person: Susan Rios, Grants Manager Current status: In-Progress Anticipated Completion Date: February 06, 2026 Condition: The University did not have effective internal controls over the timely preparation and approval of employees’ time and effort certifications. Identification of repeat finding: N/A Resolution: The Time and Effort Reporting form was updated on February 6, 2026, to more accurately reflect the semesters covered by the form submitted by the respective program. The Grants Accounting Office will obtain the completed forms within 90 days of the last day of the performance period. The forms will be completed on a biannual basis and collected from each respective program within 90 days following the end date of the most recent semester.

View Audit 389658

Finding 1175749 (2025-005)

Material Weakness 2025

University of the Incarnate Word

TX

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

Finding 2025-005 – Cash Management Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: February 1, 2026 Condition: The University did not provide evidence that the School Account Statements (SAS) from ED were used to reconcile to the U...

Finding 2025-005 – Cash Management Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: February 1, 2026 Condition: The University did not provide evidence that the School Account Statements (SAS) from ED were used to reconcile to the University’s financial and business records on a monthly basis during the year ended May 31, 2025. Identification of repeat finding: N/A Resolution: We maintain that we did reconcile to the School Account Statements, as evidenced by the reports that have been run against the SAS statements through the Banner job RLRDLRC. However, we did not maintain the individual monthly evidence of the mismatches identified on those reports, and their resolution. We are maintaining this evidence going forward.

View Audit 389658

Finding 1175748 (2025-004)

Material Weakness 2025

University of the Incarnate Word

TX

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2025-004 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Ann Margaret Cervantes, Director of Business Office Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The U...

Finding 2025-004 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Ann Margaret Cervantes, Director of Business Office Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The University was unable to provide evidence that internal controls over the return of credit balances to students were performed. Additionally, student credit balances were not identified and refunded to students within 14 days after the credit balance occurred. Identification of repeat finding: N/A Resolution: Our Outlook email folders have a limit on storage, despite using non-server folders to extend storage space and length of time. During 2024-2025, these folders reached full capacity and we were unable to send or receive any emails. We were instructed to delete older emails to regain functionality, which unfortunately meant that some of the automated emails that we use for our audit processes had to be deleted. Our Information Technology department was able to provide an online archive folder for Outlook emails that does not fill up, get deleted, or cause us to run out of space. Therefore, all emails proving processing will be available for review during next year’s audit. Please note that this control was in place, and was followed, but we are unable to provide the actual email output. In addition to the automated credit balance reports from ARGOS, the Business Office runs internal reports twice weekly to identify and process any pending credit balances.

View Audit 389658

Finding 1175746 (2025-003)

Material Weakness 2025

University of the Incarnate Word

TX

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2025-003 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The University was unable to provide evidence that intern...

Finding 2025-003 – Special Tests and Provisions – Disbursements to or on Behalf of Students Contact Person: Cristen Alicea, Office of Financial Assistance Current status: Resolved Anticipated Completion Date: Completed May 23, 2025 Condition: The University was unable to provide evidence that internal controls were performed in relation to notifications of disbursements, including notification of the amount and type of Title IV funds students are expected to receive, and how and when those disbursements will be made (award letter), and when direct loans are being credited to a student’s account (direct loan notification). Identification of repeat finding: N/A Resolution: Our Outlook email folders have a limit on storage, despite using non-server folders to extend storage space and length of time. During 2024-2025, these folders reached full capacity and we were unable to send or receive any emails. We were instructed to delete older emails to regain functionality, which unfortunately meant that some of the automated emails that we use for our audit processes had to be deleted. Our Information Technology department was able to provide an online archive folder for Outlook emails that does not fill up, get deleted, or cause us to run out of space. Therefore, all emails proving processing will be available for review during next year’s audit. Please note that this control was in place, and was followed, but we are unable to provide the actual email output. There were no instances of non-compliance identified during this audit.

View Audit 389658

Finding 1175744 (2025-002)

Material Weakness 2025

University of the Incarnate Word

TX

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2025-002 – Special Tests and Provisions – Return of Title IV Funds Contact Person: Cristen Alicea, Office of Financial Assistance Current status: In-Progress Anticipated Completion Date: May 1, 2026 Condition: The University did not provide evidence of an effective review process to ensure t...

Finding 2025-002 – Special Tests and Provisions – Return of Title IV Funds Contact Person: Cristen Alicea, Office of Financial Assistance Current status: In-Progress Anticipated Completion Date: May 1, 2026 Condition: The University did not provide evidence of an effective review process to ensure the timely calculation and return of Title IV funds to ED. The University did not accurately calculate and return Title IV funds in a timely manner to ED, within 45 days after the date the institution determined that a student withdrew. Identification of repeat finding: Yes – 2024-002, 2023-002 Resolution: The Director of Financial Assistance performed a full review of all withdrawals during 2023-2024, and 2024-2025, to ensure calculations were complete, accurate, and funds returned as required. Documentation will be maintained for review by the auditors and the Department of Education to prove funds were returned correctly, even if not timely. The continuation of this issue was caused by the continued difficulty with recruiting and keeping financial assistance advisors, and the extraordinary disruption caused by the 2024-2025 FAFSA changes. We were unable to fully remediate our staffing issues during the 2024-2025 academic year. We brought on new staff which required extensive training. However, we are now able to spend more time focusing on compliance areas and will be able to fully implement our planned compliance controls during the 2025-2026 aid year. We will not have any returns unprocessed or made outside of 45 days after May 1, 2026. In addition to new staff and training, we will implement a secondary review process for all Return of Title IV transactions whereby an advisor will process the initial calculation and return, and then either the Assistant Director or Director of Financial Assistance will perform a secondary review which evaluates the date of the withdrawal, the date of determination, the eligible disbursed/non-disbursed aid amounts, the returned amounts, and confirms the returned amounts in Banner and COD. This internal review process will be performed upon 100% of Return of Title IV calculations each academic year.

View Audit 389658

Finding 1175742 (2025-001)

Material Weakness 2025

University of the Incarnate Word

TX

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

Finding 2025-001 – Special Tests and Provisions – Enrollment Reporting Contact Person: Marisol M. Scheer, Registrar’s Office Cristen Alicea, Office of Financial Assistance Current status: In-progress Anticipated Completion Date: May 31, 2026 Condition: The University did not provide evidence of an e...

Finding 2025-001 – Special Tests and Provisions – Enrollment Reporting Contact Person: Marisol M. Scheer, Registrar’s Office Cristen Alicea, Office of Financial Assistance Current status: In-progress Anticipated Completion Date: May 31, 2026 Condition: The University did not provide evidence of an effective review process to ensure accurate and timely reporting of student status changes to NSLDS. The University did not report program enrollment effective date or student status to the NSLDS for 1 of 60 students selected for testing. Identification of Repeat Finding: Yes – 2024-001, 2023-001, 2022-001, 2021-001, 2020-001, 2019-002 Resolution: We would again like to reiterate that even though this is considered a repeat finding for enrollment reporting, this particular issue is different than the previous findings. The Registrar's Office has implemented a control whereby a sample of students are reviewed after submission to the National Student Clearinghouse. This student did not appear as part of the sample and was unknown until the audit. We have reviewed all pertinent files for this student and can confirm that all student processing had no errors. In an improvement effort, the Registrar's Office will provide a sample to the Office of Financial Assistance to review for successful data processing. The Registrar's Office has begun researching why the student was not reported but have been able to confirm no procedural errors or delays with the student record that could have caused reporting issues.

View Audit 389658

Finding 1175727 (2025-001)

Material Weakness 2025

Saint Mary's University of Minnesota

MN

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

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

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

View Audit 389644

Finding 1175718 (2025-001)

Material Weakness 2025

Montana Cancer Consortium

MT

Allowable Costs / Cost Principles Cash Management Matching / Level of Effort / Earmarking § 200.302 § 200.305 § 200.313 § 200.430

Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporti...

Finding 2025-001: U.S. Department of Health and Human Service, National Institutes for Health Research and Development Cluster, Cancer Control, Assistance Listing #93.399; Lack of Required Written Policies Corrective Action: We agree with the recommendation. We do currently require complete supporting documentation for all expenditures. Montana Cancer Consortium (MCC) has updated the Financial Process Procedure to include language related to receipt management, allowable and disallowed grant expenses, and timing of payment requests. Timeline: This was implemented on December 1, 2025. Responsible Parties: MCC Director, Principal Investigators

View Audit 389640

Finding 1175705 (2025-002)

Material Weakness 2025

Marymount University

VA

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

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

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

View Audit 389607

Finding 1175619 (2025-001)

Material Weakness 2025

National University

CA

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

Recommendation: We recommend the University review the R2T4 requirements and implement adequate procedures to make sure that students that withdrew have a calculation performed. We also recommend the University to evaluate the R2T4 review process to ensure Title IV funds are returned timely. Explana...

Recommendation: We recommend the University review the R2T4 requirements and implement adequate procedures to make sure that students that withdrew have a calculation performed. We also recommend the University to evaluate the R2T4 review process to ensure Title IV funds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University agrees with the importance of ensuring that the return of Title IV funds (R2T4) calculation is performed both timely and accurately. The University has taken significant steps to improve its compliance with R2T4 requirements. These efforts have yielded improved results with the late return error rate decreasing year over year from 13% to 7%. The University will continue to monitor staffing levels and workload to ensure that staffing aligns with timeline requirements. The University’s Processing team will lead focused R2T4 training on topics related to areas of noncompliance. Additional topics will be identified throughout the year as trends are identified in the Quality Assurance Audit process. The following steps will be taken immediately to address finding 2025-001. - The Processing team will continue to conduct subject matter training monthly, prioritized as follows: o Post Withdrawal Disbursements (PWD) identification o Post Withdrawal Disbursement timeline requirements - A new weekly review will be implemented by quality assurance outside of the review completed by R2T4 leadership to test if processing specialists are accurately determining if an R2T4 is required and if a refund is needed for a withdrawn student. Results will be used to coach staff members as needed. The University’s Quality Assurance team will continue to conduct weekly R2T4 reviews to test the R2T4 calculation for accuracy, timeliness of funds returned, and verifying that all internal and external system inputs are completed correctly. Findings from the internal audits will inform ongoing training and remediation steps throughout the year. Name(s) of the contact person(s) responsible for corrective action: - Rob Conlon, AVP Financial Aid Compliance - Alan Coddington, AVP Student Financial Services - John Okel, Director of Operations, Financial Aid Processing Planned completion date for corrective action plan: January 2026

View Audit 389454

Finding 1175606 (2025-002)

Material Weakness 2025

La Salle University

PA

Reporting Student Financial Aid Material Weakness

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordan...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes 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: La Salle contractually relies on the National Student Clearinghouse (NSC) to conduct its enrollment reporting to NSLDS. While there has been closer adherence to the overall transmission schedule established with the NSC, and this covers enrollment reporting for the vast majority of our registered students, such was not always the case in prior semesters, and selected exceptional registration transactions are not directly reported when they actually occur, resulting in delays, until the next regularly scheduled transmission. Going forward, upon encountering these exceptional transactions, we will take steps to ensure reporting of individual enrollments to the NSC within 1-2 business days following the transaction’s occurrence. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Spring 2026 (Fall 2025 is already complete as of this writing)

View Audit 389443

Finding 1175602 (2025-001)

Material Weakness 2025

La Salle University

PA

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing COD reporting to ensure timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit...

Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing COD reporting to ensure timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: La Salle University has developed a report that enables weekly auditing of the Pell-eligible student population to ensure accurate identification and timely submission for evaluation. This report will be monitored on an ongoing weekly basis to promptly detect and address any errors related to Pell eligibility. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President for Student Financial Services Planned completion date for corrective action plan: Corrected as of Spring 2026 (Fall 2025 is already complete as of this writing)

View Audit 389443

Finding 1175546 (2025-002)

Material Weakness 2025

Floyd County Community Action Agency, Inc.

IN

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

Management acknowledges that the Agency did not meet the required 20 percent non-federal share for the budget period ended May 31, 2025, and that the waiver request was submitted after the close of the budget period. While allowable in-kind contributions were tracked throughout the year, communicati...

Management acknowledges that the Agency did not meet the required 20 percent non-federal share for the budget period ended May 31, 2025, and that the waiver request was submitted after the close of the budget period. While allowable in-kind contributions were tracked throughout the year, communication from OHS provided differing guidance regarding the timing of submission for a Non-Federal Share waiver, which contributed to the delay. To address this matter, the Agency has implemented the following corrective actions: 1. A formal monthly Non-Federal Share Monitoring Report has been implemented and is reviewed by the Director and CFO. This report calculates the required match based on cumulative federal expenditures and compares it to documented in-kind contributions to ensure ongoing compliance. 2. Quarterly match projections are now prepared to identify potential shortfalls in advance of the budget period end. If projections indicate a deficit, corrective measures will be initiated immediately, including intensified in-kind collection efforts or submission of a waiver request prior to the end of the budget period. 3. The Governing Board and Policy Council will receive quarterly updates on non-federal share status to strengthen governance oversight and ensure transparency. 4. Written internal procedures for in-kind documentation, valuation, and monitoring have been formalized and incorporated into the Agency's fiscal policies and procedures manual. 5. The CFO has received additional training regarding federal matching requirements under 45 CFR §75 and Head Start Program Performance Standards to reinforce compliance expectations and ensure timely action in future budget periods. Management believes these corrective actions will strengthen internal controls, improve monitoring, and prevent recurrence in future budget periods.

View Audit 389340

Finding 1175539 (2025-001)

Material Weakness 2025

Southwestern University

TX

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Student Financial Aid Corrective Action Plan Institution Name: Southwestern University Audit/Review Period: FY 2024-2025 Date of Plan: Feb 4, 2026 Finding: 2025-001 Effect: The University did not report withdraw changes to the NSLDS timely. Recommendation: The University should put in place a proces...

Student Financial Aid Corrective Action Plan Institution Name: Southwestern University Audit/Review Period: FY 2024-2025 Date of Plan: Feb 4, 2026 Finding: 2025-001 Effect: The University did not report withdraw changes to the NSLDS timely. Recommendation: The University should put in place a process to timely capture student status changes so that they can be reported to the NSLDS. Management Response: The University concurs with this finding. University Corrective Action Plan: Every 30 days, the University reports updated student enrollment activity, encompassing attendance levels, graduation status, withdrawals, dropouts, and enrollment changes, to the National Student Loan Database System via the National Student Clearinghouse. Regrettably, during the 2024-25 academic year, an unforeseen error from the Clearinghouse resulted in the dissemination of incorrect enrollment statuses for a subset of our students. This oversight was beyond the Registrar's Office's knowledge, leading to an unintended delay in rectifying the reported statuses. We believe this Clearinghouse error was an isolated incident, having never occurred in any preceding academic year. The issue has been effectively resolved and should not recur in the future. Nevertheless, as a proactive measure, commencing with the 2025-26 academic year, the Financial Aid Office will collaborate with the Registrar's Office to review a representative sample of at least 10% of student records transmitted to the Clearinghouse. This review process will serve as an additional safeguard, ensuring the accuracy and timeliness of our reporting requirements.

View Audit 389325

Finding 1175528 (2025-004)

Material Weakness 2025

Bay City Independent School District

TX

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personne...

Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personnel will meet regularly to identify any potential issues for noncompliance with maintenance of effort and develop a plan accordingly to ensure compliance is met. Staff training and utilization of the calculation tools provided by TEA will be provided to ensure all involved gain the necessary understanding. Responsible Contact Person: Farrah Jernigan, Chief Financial Officer Anticipated Completion Date: June 30, 2026

View Audit 389296

Finding 1175527 (2025-003)

Material Weakness 2025

Bay City Independent School District

TX

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personne...

Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personnel will meet regularly to identify any potential issues for noncompliance with maintenance of effort and develop a plan accordingly to ensure compliance is met. Staff training and utilization of the calculation tools provided by TEA will be provided to ensure all involved gain the necessary understanding. Responsible Contact Person: Farrah Jernigan, Chief Financial Officer Anticipated Completion Date: June 30, 2026

View Audit 389296

Finding 1175512 (2025-003)

Material Weakness 2025

Region III Workforce Investment Board of Kanawha County, Inc.

WV

Matching / Level of Effort / Earmarking § 200.303

2025-003 EARMARKING U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of Earmarking requirements for Youth Activities, we noted that approximately 13 percent of Youth activity finds allocated to the local area, except for the local area expenditure...

2025-003 EARMARKING U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of Earmarking requirements for Youth Activities, we noted that approximately 13 percent of Youth activity finds allocated to the local area, except for the local area expenditures for administration, was used to provide paid and unpaid work experience, which is not in compliance with the provisions stated in the Uniform Grant Guidance under the WIOA Cluster for Youth Activities. Recommendation: We recommend that the Board regularly review the grant expenditures for each of its programs and activities to ensure that all requirements for earmarking within the Uniform Grant Guidance are met. Region 3 Action: the Board will conduct formal monthly reviews of all WIOA grant expenditures by program and funding stream. These reviews will compare actual expenditure to budget allocations and earmarking requirements to ensure compliance with Uniform Grant Guidance and WIOA statutory requirements. Financial staff will prepare monthly expenditure reports, which will then be reviewed and approved by the Executive Director and presented quarterly to the Finance Committee of the Board. The Finance Committee will document its review in meeting minutes. The Board believes these corrective measures strengthen internal controls and ensure ongoing compliance with federal grant requirements. We are committed to maintaining sound fiscal oversight and full adherence to all applicable WIOA and Uniform Grant Guidance requirements.

View Audit 389289

Finding 1175511 (2025-002)

Material Weakness 2025

Region III Workforce Investment Board of Kanawha County, Inc.

WV

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

2025-002 Eligibility- WIOA intake applications were not signed properly U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of WIOA participants, it was noted that for one of the six youth participants selected for testing the WIOA intake application...

2025-002 Eligibility- WIOA intake applications were not signed properly U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of WIOA participants, it was noted that for one of the six youth participants selected for testing the WIOA intake application was not signed by the case manager. Recommendation: We recommend that the Board thoroughly review all applications for Youth Activities to ensure that all required eligibility documentation is completed and properly approved. Region 3 Action:ln direct response to this finding, the Board developed and implemented a comprehensive Youth Eligibility Policy, effective February 25, 2025. This policy establishes clear and enforceable procedures to ensure that all youth participants are properly vetted prior to receiving WIDA-funded services.Specifically, the policy includes a dedicated "Eligibility Verification" and "Documents for Verifying WIOA Eligibility" section which requires that service providers confirm each individual meets all applicable WIOA eligibility requirements including age, selective service registration and citizenship status at the time of registration. The policy further requires that each participant file contain a completed application along with supporting documentation confirming general WIOA eligibility and all applicable Youth eligibility data elements. Additionally, all questions on the intake form must be fully answered and both the applicant and the intake staff member are required to sign the intake forms prior to the delivery of services. Primary Eligibility Review is the Local Board's program staff's responsibility to ensure all registration paperwork is complete and accurate before WIOA enrollment.The Board is confident that these policy requirements provide the necessary framework and controls to ensure consistent, documented eligibility verification across all service providers administering youth activities under WIOA. The Board will continue to monitor compliance with this policy through its oversight activities to ensure the controls remain effective on an ongoing basis.

View Audit 389289

Finding 1175510 (2025-001)

Material Weakness 2025

Region III Workforce Investment Board of Kanawha County, Inc.

WV

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

2025-001 REPORTING-MACC reports did not contain evidence of supervisory approval Condition: For all MACC reports selected for testing, management was unable to provide adequate support that the reports were properly reviewed and approved prior to being submitted. Recommendation: We recommend that th...

2025-001 REPORTING-MACC reports did not contain evidence of supervisory approval Condition: For all MACC reports selected for testing, management was unable to provide adequate support that the reports were properly reviewed and approved prior to being submitted. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately in a timely fashion, with proper review and approval prior to submission. Region 3 action: Although Region 3 has established a monthly checklist that is reviewed and signed off by Brenda Hunt CPA, it is a work in progress and ad ustments will be made to reflect an additional review and approval prior to submission.

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Finding 1175480 (2025-003)

Material Weakness 2025

Knox College

IL

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

Identifying Number: 2025-003 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA: • The College has performed a risk assessment utilizing internal reso...

Identifying Number: 2025-003 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA: • The College has performed a risk assessment utilizing internal resources but has not fully integrated the information security program on the results of this assessment, nor has the College included all required elements of internal and external risks to the security, confidentiality or integrity of customer information. The College’s risk assessment is in the process of implementing an inventory of IT systems that process and store customer information and the compliance with information security elements related to multifactor authentication, access control, change management, logging and alerting and encryption. • The College has not identified, designed or implemented safeguards for all of the risks identified in the risk assessment. The safeguards do not include the identification of security events the detection and response capabilities to support incident response is still being developed. • The College has not been able to test safeguards because safeguards have not been fully designed or implemented in response to the risk assessment. • The College has not developed written policies and procedures to ensure that personnel are able to enact the information security program. There is a lack of evidence of leadership being required to report to the board or an appropriate supervisory council to ensure those charged with governance are informed on the current state of the information security program. Corrective Actions Taken or Planned: 1. Integration of Risk Assessment Results • Corrective Actions Taken or Planned: Complete a new risk assessment for our new information systems and fully integrate the results including safeguards into the College’s information security program. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 2. Provide Training for Written Policies and Procedures • Corrective Actions Taken or Planned: Distribute written policies and procedures to ensure personnel can enact the information security program. Provide training to all relevant staff. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 3. Testing of Safeguards • Corrective Actions Taken or Planned: Conduct regular testing of implemented safeguards to ensure effectiveness. Document results and make improvements as needed. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 4. Comprehensive Inventory of IT Systems • Corrective Actions Taken or Planned: Update and maintain our inventory of all IT systems that process and store customer information. Ensure compliance with multifactor authentication, access control, change management, logging, alerting, and encryption requirements. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 5. Governance and Reporting • Corrective Actions Taken or Planned: Establish a formal process requiring leadership to report on the state of the information security program to the Board of Trustees and include in our security policies. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: 6/30/2026 6. GLBA Policy Enhancement • Corrective Actions Taken or Planned: Review and revise the information security policy to ensure all GLBA-required elements are included, referencing current regulatory guidance. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: 6/30/2026

View Audit 389269

Finding 1175470 (2025-001)

Material Weakness 2025

Knox College

IL

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

Identifying Number: 2025-001 Finding: Error in Reporting for National Student Loan Data System (NSLDS) The College did not properly report the student enrollment change for students who received federal student aid to the NSLDS. The College did not timely report three students’ Program-Level or Camp...

Identifying Number: 2025-001 Finding: Error in Reporting for National Student Loan Data System (NSLDS) The College did not properly report the student enrollment change for students who received federal student aid to the NSLDS. The College did not timely report three students’ Program-Level or Campus-Level enrollment status change to NSLDS. Out of the 25 students tested, we noted 3 students (12%) whose status change at the Program-Level and Campus-Level was not timely reported to NSLDS. The College did not have adequate controls related to the process of enrollment reporting, which is required under Uniform Grant Guidance. Corrective Actions Taken or Planned: Knox College will add a third report submission to the end of the term. This will ensure that we report any students that made end of term withdrawals within the time window we are required to report. Any students who withdraw between terms will be captured in the first report submitted after our two week census. Person Responsible: Patrick Hathaway, Registrar, phathaway@knox.edu Anticipated Completion Date: December 31, 2025

View Audit 389269

Finding 1175465 (2025-003)

Material Weakness 2025

Thaddeus Stevens College of Technology

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding 2025-003: Late Student Status Change Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: 34 CFR 668.32 requires that an organization reports student status changes within 60 days of graduation, withdrawal, or other roster status chan...

Finding 2025-003: Late Student Status Change Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: 34 CFR 668.32 requires that an organization reports student status changes within 60 days of graduation, withdrawal, or other roster status changes. Condition: The change in status for 4 of 40 students tested was not reported to the National Student Loan Data System (NSLDS) within 60 days of the change. Cause: Staffing changes during the year impacting the College’s internal control structure resulted in an administrative delay in reporting the changes to NSLDS. Effect: The effect of the condition described above was that the College was not in compliance with NSLDS reporting requirements. Repeat Finding: This is not a repeat finding. Questioned costs: There are no known questioned costs to report. Recommendation: We recommend that the College ensures sufficient staffing is available to report NSLDS requirements timely. View of Responsible Officials and Planned Corrective Action Corrective Action Plan: There is no disagreement with this audit finding. During the fall of 2024 the Registrar’s Office was downsized. This resulted in the delayed processing of the error report following the 10.25.2024 report. This resolution required contacting NSC for assistance in clearing two of the errors, which increased the processing time. Moving forward, the Registrar’s Office will continue to report to NSC on the predetermined schedule, process errors timely, and additionally, a quality control check will be implemented for the Financial Aid Office to compare NSLDS records following the NSC transmissions. Name(s) of the contact person(s) responsible for corrective action: Dr. Melissa Wisniewski, Dean of Enrollment Services at 717-391-7234. Planned completion date for corrective action plan: February 2026 If the Department of Education has questions regarding this plan, please call the Vice President of Finance and Administration, Mr. George Longridge at 717-391-6947.

View Audit 389259

Finding 1175461 (2025-002)

Material Weakness 2025

Thaddeus Stevens College of Technology

PA

Student Financial Aid Allowable Costs / Cost Principles Eligibility

Finding 2025-002: Student Financial Aid Cluster – Allowable Costs and Allowable Activities and Eligibility Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: The College is required to have controls in place to ensure students receive the proper amou...

Finding 2025-002: Student Financial Aid Cluster – Allowable Costs and Allowable Activities and Eligibility Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: The College is required to have controls in place to ensure students receive the proper amount of student financial assistance they are entitled to based on financial need. Condition: Our financial aid sample of 40 items tested yielded 31 students who received Direct Loan Funding. Of the 31 students who received Direct loan funding, we noted 1 instance where the student received the incorrect amount of Unsubsidized funding. Based on the students Student Aid Index, the student should have received $1,750 in Unsubsidized funding; however, they received $2,227 in Unsubsidized Direct Loan funding, resulting in an overpayment of Direct Loan funding of $477. Cause: The controls in place did not detect that the student had incorrectly been awarded assistance based on more than 30 credits when they actually had 25 credits. The additional 5 credits needed for the amount of the award were not earned until the following semester. Effect: Internal controls related to student financial assistance were not operating properly. Repeat Finding: This is not a repeat finding. Questioned costs: $477 Recommendation: We recommend Thaddeus develop systems that would detect credits posted but not earned to ensure proper student assistance is awarded. View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan. Corrective Action Plan: There is no disagreement with the audit finding. After reviewing the policy for Grade-Level Advancement for Direct Loan Consideration, it was determined that the student referenced in the funding did not meet the qualifications needed to be considered a sophomore level student for the Fall 2024 semester. The student became eligible for the increased loan amount in the Spring 2025 semester. The $500 that was incorrectly awarded to the student for the Fall 2024 semester has been corrected and reallocated to Spring 2025. The Office of Financial Aid has created a procedure to check student loan amounts during fall and spring semester to ensure accuracy. Additionally, an Assistant Director of Financial Aid was hired in February 2025 to strengthen financial aid administration within the department. Name(s) of the contact person(s) responsible for corrective action: Melissa Wisniewski, Dean of Enrollment Services at 717-391-7234. Planned completion date for corrective action plan: January 2026. If the Department of Education has questions regarding this plan, please call the Vice President of Finance and Administration, George Longridge at 717-391-6947.

View Audit 389259

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