Corrective Action Plans

Finding 1218549 (2025-032)

Material Weakness 2025

State of Michigan

MI

Matching / Level of Effort / Earmarking § 200.516

Finding 2025-032 CCDF Cluster, ALN 93.575 and 93.596 - Client Eligibility Management Views MiLEAP and MDHHS agree with the finding. Planned Corrective Action MiLEAP and MDHHS ESA will continue to work together to help ensure compliance with client eligibility requirements by providing guidance on up...

Finding 2025-032 CCDF Cluster, ALN 93.575 and 93.596 - Client Eligibility Management Views MiLEAP and MDHHS agree with the finding. Planned Corrective Action MiLEAP and MDHHS ESA will continue to work together to help ensure compliance with client eligibility requirements by providing guidance on updated policies, processes and noted trends to local office and BSC staff. To increase subject-matter proficiency and improve consistency in eligibility determinations, MDHHS plans to begin implementing a Child Development and Care specialized staffing model within the Universal Case Load system statewide in July 2026. MDHHS Child Development and Care specialized staff will continue to utilize the Child Development and Care eligibility checklist for applications and redeterminations, and MDHHS will begin implementing a statewide review process based on identified errors by July 2026. MDHHS, in collaboration with MiLEAP, will continue to meet weekly to review common errors and root causes, address trends and questions received through the Child Development and Care Policy mailbox, and identify improvement and adjustment strategies. Anticipated Completion Date Ongoing Responsible Individual(s) Lisa Brewer-Walraven, MiLEAP Mariah Schaefer, MDHHS Gayle Vail, MDHHS

View Audit 404775

Finding 1218520 (2025-060)

Material Weakness 2025

State of Michigan

MI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding 2025-060 Coronavirus Capital Projects Fund, ALN 21.029 Management Views LEO agrees with the finding. Planned Corrective Action The LEO Finance Division and the LEO Grants Division have identified the deficiencies that led to the audit finding. LEO will correct the internal FFATA reporting pr...

Finding 2025-060 Coronavirus Capital Projects Fund, ALN 21.029 Management Views LEO agrees with the finding. Planned Corrective Action The LEO Finance Division and the LEO Grants Division have identified the deficiencies that led to the audit finding. LEO will correct the internal FFATA reporting process to ensure that new and amended subaward contract information is received by the LEO Finance Division in a timely manner and in accordance with FFATA requirements. LEO will utilize the EGrAMS vendor to update software functionality that will generate an email notification to the LEO Finance Division when a grant agreement is finalized or amended. This notification will ensure communication with the LEO Finance Division occurs in a timely manner and in accordance with FFATA requirements. Anticipated Completion Date June 30, 2026 Responsible Individual(s) Jennifer Duffey, LEO Heidi Parker, LEO

View Audit 404775

Finding 1218503 (2025-058)

Material Weakness 2025

State of Michigan

MI

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.326

Finding 2025-058 Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs, ALN 20.106 Management Views MDOT agrees that it did not ensure weekly certified payrolls were obtained from contractors. Planned Corrective Action MDOT will provide training...

Finding 2025-058 Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and COVID-19 Airports Programs, ALN 20.106 Management Views MDOT agrees that it did not ensure weekly certified payrolls were obtained from contractors. Planned Corrective Action MDOT will provide training and guidance to pertinent staff to help ensure contract compliance and that weekly certified payrolls are obtained from contractors. In addition, MDOT will review existing procedures to assess whether updates are needed. Anticipated Completion Date September 30, 2026 Responsible Individual(s) Bryan Budds, MDOT

View Audit 404775

Finding 1218486 (2025-056)

Material Weakness 2025

State of Michigan

MI

Reporting Matching / Level of Effort / Earmarking § 200.303

Finding 2025-056 WIOA Cluster, ALN 17.258, 17.259, and 17.278 Management Views LEO agrees with the finding. LEO management recognizes the importance of timely and accurate FFATA reporting and acknowledges that internal processes can be strengthened to better support reporting consistency, particular...

Finding 2025-056 WIOA Cluster, ALN 17.258, 17.259, and 17.278 Management Views LEO agrees with the finding. LEO management recognizes the importance of timely and accurate FFATA reporting and acknowledges that internal processes can be strengthened to better support reporting consistency, particularly during high-volume periods such as quarter-end. LEO remains committed to compliance and continuous improvement. Planned Corrective Action LEO will improve existing FFATA reporting processes by reinforcing internal timelines, clarifying staff responsibilities, and implementing an additional review step prior to submission to help ensure subaward information is reported timely and accurately. Management will train appropriate staff responsible for FFATA reporting to strengthen understanding of reporting requirements, deadlines, and review expectations. These improvements are intended to enhance process consistency, improve communication, and reduce the likelihood of future timing or minor reporting discrepancies. LEO will enhance documented procedures that outline specific FFATA reporting processes related to the Workforce Innovation and Opportunity Act (WIOA). Anticipated Completion Date September 30, 2026 Responsible Individual(s) Arica Johnson, LEO

View Audit 404775

Finding 1218466 (2025-001)

Material Weakness 2025

EAGLE LAKE WATER & SEWER DISTRICT

ME

Questioned Costs Procurement, Suspension & Debarment Significant Deficiency § 200.318

CORRECTIVE ACTION PLAN Concerning Finding 2025-001 - Procurement Contact Person Responsible for Corrective Action: Darcy K. Labbe, Superintendent Corrective Action: The Eagle Lake Sewer District will take the following actions to address finding 2025-001. A procurement policy was drawn up and implem...

CORRECTIVE ACTION PLAN Concerning Finding 2025-001 - Procurement Contact Person Responsible for Corrective Action: Darcy K. Labbe, Superintendent Corrective Action: The Eagle Lake Sewer District will take the following actions to address finding 2025-001. A procurement policy was drawn up and implemented on February 23, 2026. Anticipated Completion Date: A procurement policy was signed by the Board of Trustees and implemented on February 23, 2026.

View Audit 404756

Finding 1218419 (2025-003)

Material Weakness 2025

Minnesota Prairie County Alliance

MN

Questioned Costs Eligibility Significant Deficiency

ELIGIBILITY DETERMINATION Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Grants to States for Medicaid (Medicaid Cluster) Assistance Listing Number: 93. 778 Federal Award Identification Numbers and Year: 2505MN5MAP and 2505MN5ADM, 2025 Pass-Through Agency: Minneso...

ELIGIBILITY DETERMINATION Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Grants to States for Medicaid (Medicaid Cluster) Assistance Listing Number: 93. 778 Federal Award Identification Numbers and Year: 2505MN5MAP and 2505MN5ADM, 2025 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 2505MN5MAP and 2505MN5ADM Compliance Requirement Affected: Eligibility Award Period: Year-Ended December 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Recommendation: It is recommended the Agency implement procedures to ensure the citizenship, asset, and income verification documentation in the casefiles be retained and that it matches the METS eligibility system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Agency will review procedures and show staff proper documentation and entry into METS and staff will be reminded to perform reviews. Name of the contact person responsible for corrective action plan: Waylon Welvaert, Finance Manager Planned completion date for corrective action plan: December 31, 2026

View Audit 404688

Finding 1218412 (2025-002)

Material Weakness 2025

Evangeline Booth Residence, Inc., A Florida Corporation

FL

Questioned Costs Special Tests & Provisions HUD Housing Programs

Project Legal Name: Evangeline Booth Residence, Inc., A Florida Corporation HUD Project No.: 063-EE011-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/24-9/30/25 Corrective Action Plan prepared by: Name: Philip Gesner Position: Financial Project Manager, USA Southern Territory Fina...

Project Legal Name: Evangeline Booth Residence, Inc., A Florida Corporation HUD Project No.: 063-EE011-WAH Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/24-9/30/25 Corrective Action Plan prepared by: Name: Philip Gesner Position: Financial Project Manager, USA Southern Territory Finance Department Telephone Number: 470-816-5977 2. Finding 2025-002 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the recommendation to review the project budget to determine if nonessential costs can be cut (or request a loan from the owner) to ensure that the replacement reserve is funded in accordance with the terms of the regulatory agreement and the recommendation to obtain from HUD a waiver for the missing replacement reserve deposits if possible, or fund the missing deposits. b. Action(s) Taken or Planned on the Finding Due to significant delays in receipt of PRAC funds for over a year, management suspended making the deposits to the reserve until PRAC funding was replenished. Management also borrowed funds from the replacement reserve in 2024 which funds were repaid during the year ended September 30, 2024 once past-due PRAC funds were received. Due to ongoing issues with PRAC funding, management continues to be behind on making the monthly deposits during the year ended September 30, 2025.

View Audit 404683

Finding 1218383 (2025-004)

Material Weakness 2025

Catherine Booth Friendship House Residence Inc., A Texas Corporation

TX

Questioned Costs Special Tests & Provisions Cash Management

4. Finding 2025-004 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the recommendation to reimburse the amount due to the project and establish procedures to ensure reimbursement for shared costs and related receivables are made timely ...

4. Finding 2025-004 a. Comments on the Finding and Each Recommendation The auditee agrees with the finding. The auditee agrees with the recommendation to reimburse the amount due to the project and establish procedures to ensure reimbursement for shared costs and related receivables are made timely in accordance with established policy. b. Action(s) Taken or Planned on the Finding We will implement procedures to ensure shared costs are reimbursed on a consistent and regular basis.

View Audit 404677

Finding 1218352 (2025-001)

Material Weakness 2025

Fairview Health Services

MN

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

Finding 2025-001 Federal Grantor: United States Department of Health and Human Services Planned Corrective Actions: Responsible Official – Dawn Ksepka, VP of Finance and System Controller Anticipated completion date – June 30, 2026 Management agrees with the finding. Remediation: Fairview has correc...

Finding 2025-001 Federal Grantor: United States Department of Health and Human Services Planned Corrective Actions: Responsible Official – Dawn Ksepka, VP of Finance and System Controller Anticipated completion date – June 30, 2026 Management agrees with the finding. Remediation: Fairview has corrected the payroll reimbursement request for the inaccurate payroll charges identified in the finding. To prevent recurrence, Fairview will enhance controls over payroll review processes to ensure accuracy prior to submission. These enhancements include reinforcing review expectations with project directors and including detailed review procedures for validating pay rate and wage calculations prior to reimbursement submissions. Management believes these actions will improve the accuracy of payroll charges and ensure compliance with federal program requirements.

View Audit 404614

Finding 1218293 (2025-005)

Material Weakness 2025

Resilience: Advocates for Ending Violence

MI

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Finding 2025-005: Crime Victim Assistance Documented Review and Approval Procedures Type of Finding: Control U.S. Department of Justice Pass-through Entity: Michigan Department of Health and Human Services Assistance Listing Number: 16.575 Award Numbers: E20253442-00, E20252994-00, E20254307-00, and...

Finding 2025-005: Crime Victim Assistance Documented Review and Approval Procedures Type of Finding: Control U.S. Department of Justice Pass-through Entity: Michigan Department of Health and Human Services Assistance Listing Number: 16.575 Award Numbers: E20253442-00, E20252994-00, E20254307-00, and E20252103-00 Award Year End: September 30, 2025 Recommendation: The Organization should expand its financial reporting review procedures to require the documented review and approval of all performance reports by an individual with adequate skills, knowledge, and experience prior to submission. Action Taken: During the fiscal year, the Organization properly implemented procedures that require the documented review of the monthly financial reports, including the corresponding indirect cost calculations. The Organization will expand these policies and procedures to require the documented review and approval of all performance reports on a monthly basis prior to submission with documented approval. Responsible Person and Anticipated Completion Date: The Executive Director will oversee the implementation of this plan by June 30, 2026. If the U.S. Department of Justice has questions regarding this plan, please call Megan Hennessey at (616) 494-1724.

View Audit 404531

Finding 1218292 (2025-004)

Material Weakness 2025

Resilience: Advocates for Ending Violence

MI

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2025-004: MATERIAL WEAKNESS—Uniform Guidance Written Internal Control Procedures Type of Finding: Control U.S. Department of Justice Pass-through Entity: Michigan Department of Health and Human Services Assistance Listing Number: 16.575 Award Numbers: E20253442-00, E20252994-00, E20254307-00...

Finding 2025-004: MATERIAL WEAKNESS—Uniform Guidance Written Internal Control Procedures Type of Finding: Control U.S. Department of Justice Pass-through Entity: Michigan Department of Health and Human Services Assistance Listing Number: 16.575 Award Numbers: E20253442-00, E20252994-00, E20254307-00, and E20252103-00 Award Year End: September 30, 2025 Recommendation: The Organization should establish and maintain written internal control procedures that cover the required five components of internal control for each area of compliance for each of its federal programs. The Organization should educate all employees working with federal programs of the Organization’s procedures and monitor compliance with them. Action Taken: The Organization will establish the necessary policies and procedures for managing its federal awards in compliance with federal requirements. Responsible Person and Anticipated Completion Date: The Executive Director will oversee the implementation of this plan by June 30, 2026. If the U.S. Department of Justice has questions regarding this plan, please call Megan Hennessey at (616) 494-1724.

View Audit 404531

Finding 1218216 (2025-002)

Material Weakness 2025

Town of Castle Rock, Colorado

CO

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.328 § 200.329

Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds FFALN # 21.027 Finding Summary: Eide Bailly LLP prepared our single audit for Federal Coronavirus State and Local Fiscal Recovery Funds where the Town is a subrecipient t...

Finding 2025-002 Federal Agency Name: U.S. Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds FFALN # 21.027 Finding Summary: Eide Bailly LLP prepared our single audit for Federal Coronavirus State and Local Fiscal Recovery Funds where the Town is a subrecipient to Douglas County who is the recipient of the funds. Eide Bailly LLP identified that the Town did not have documented or consistently applied internal controls to ensure compliance with the County’s subrecipient guidance requiring the submission of formal special reports for ALN 21.027. Responsible Individuals: Mark Henderson, Assistant Director of Castle Rock Water Corrective Action Plan: Staff will complete quarterly reports including project progress and estimated project infrastructure costs. The reports will be reviewed by management prior to submission to the recipient of the Federal Funds (Douglas County). Anticipated Completion Date: Ongoing during the period that the Town is a subrecipient of these funds for the project.

View Audit 404489

Finding 1218202 (2025-001)

Material Weakness 2025

Kennebec Montessori School

ME

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

Management has established processes and procedures for documenting approvals for ACH transactions.

View Audit 404450

Finding 1218188 (2025-002)

Material Weakness 2025

La Familia Medical Center

NM

Cash Management Internal Control / Segregation of Duties Questioned Costs § 200.303

Federal Program: Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommend the Organization to review internal controls in regards to the approval of federal fund drawdown requests. Explanation of disagreement with audit finding: There is no disa...

Federal Program: Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommend the Organization to review internal controls in regards to the approval of federal fund drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization is in agreement with finding. The control issue was due to turnover in finance staff during fiscal year 2025. Under the direction of the Organization’s new CFO, the following revised procedures for cash management have been implemented for fiscal year 2026: • Payroll Documentation: A staff accountant or the controller will compile payroll expense details along with supporting documentation for each drawdown. • Review and Approval: This documentation is submitted to the CFO for review prior to any fund transfer. • Drawdown Execution: Upon approval, the CFO will initiate the drawdown from PMS. • Frequency: Drawdowns are processed on a biweekly basis and reflect expenses from the preceding payroll cycle. Upon completion of the drawdown, the CFO will save a copy of the drawdown request to the internal drive. • This drawdown receipt is reviewed by a second staff member, either the controller or senior accountant. • Drawdowns are also reviewed during monthly bank reconciliations.

View Audit 404425

Finding 1218179 (2025-001)

Material Weakness 2025

Lake Pepin Plaza LLC

MN

Questioned Costs Eligibility Significant Deficiency § 200.208

Contact Person Patricia Heraty, Accountant Corrective Action Plan Management plans to review its internal control procedures to ensure a quality control review is performed to verify all required documentation and calculations are maintained in the tenant files. Planned Completion Date for CAP Immed...

Contact Person Patricia Heraty, Accountant Corrective Action Plan Management plans to review its internal control procedures to ensure a quality control review is performed to verify all required documentation and calculations are maintained in the tenant files. Planned Completion Date for CAP Immediately.

View Audit 404385

Finding 1218159 (2025-006)

Material Weakness 2025

Methodist Manor Retirement Community

IA

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

Criteria: The Organization is responsible for sending the following reports to the USDA: FYE 12-31-2024 Audit, FY 2026 Budget, Quarterly reports for 3/30/2026, 6/30/2 025, and 9/30/2025, and Certification of Insurance. Condition: During our review of compliance with the Community Facilities Loans & ...

Criteria: The Organization is responsible for sending the following reports to the USDA: FYE 12-31-2024 Audit, FY 2026 Budget, Quarterly reports for 3/30/2026, 6/30/2 025, and 9/30/2025, and Certification of Insurance. Condition: During our review of compliance with the Community Facilities Loans & Grants, we identified that the required reports were not sent to the USDA. Cause: The requirement was not met due to an oversight by management. Effect: As a result the agency reserves the right to withdraw Agency funding. Recommendation: The Organization should create a checklist to track/remind management to send the required reports to the USDA as well create a monthly electronic calendar reminder Client Response: The facility has submitted the required reports and added items to their monthly checklist and calendar for future reporting periods. Conclusion: Response accepted.

View Audit 404349

Finding 1218158 (2025-005)

Material Weakness 2025

Methodist Manor Retirement Community

IA

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

Criteria: The Organization is responsible for depositing $10,343 into a separate general ledger account every month to fund the restricted debt service reserve and they must obtain permission before using the funds. Condition: During our review of compliance with the Community Facilities Loans & Gra...

Criteria: The Organization is responsible for depositing $10,343 into a separate general ledger account every month to fund the restricted debt service reserve and they must obtain permission before using the funds. Condition: During our review of compliance with the Community Facilities Loans & Grants, we identified that the funds were not deposited for several of the required months and the funds were not in a separate general ledger account. Cause: The requirement was not met due to an oversight by management. Effect: As a result the agency reserves the right to withdraw Agency funding. Recommendation: The Organization should setup a separate general ledger account to separate the required funds, and have a review process to verify that the deposits were made properly. Client Response: The Organization has automated a reoccurring ACH that deposits $10,343 into the reserve account every month and funded the balance to the required amount. The bookkeeping company and management have added a reserve account review to their monthly checklist. Conclusion: Response accepted.

View Audit 404349

Finding 1218157 (2025-004)

Material Weakness 2025

Methodist Manor Retirement Community

IA

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

Criteria: The Organization is responsible for sending the following reports to the USDA: FYE 12-31-2024 Audit, FY 2026 Budget, Quarterly reports for 3/30/2025, 6/30/2025, and 9/30/2025, and Certification of Insurance. Condition: During our review of compliance with the Community Facilities Loans & G...

Criteria: The Organization is responsible for sending the following reports to the USDA: FYE 12-31-2024 Audit, FY 2026 Budget, Quarterly reports for 3/30/2025, 6/30/2025, and 9/30/2025, and Certification of Insurance. Condition: During our review of compliance with the Community Facilities Loans & Grants, we identified that the required reports were not sent to the USDA. Cause: The requirement was not met due to an oversight by management. Effect: As a result the agency reserves the right to withdraw Agency funding. Recommendation: The Organization should create a checklist to track/remind management to send the required reports to the USDA as well create a monthly electronic calendar reminder Client Response: The facility has submitted the required reports and added items to their monthly checklist and calendar for future reporting periods. Conclusion: Response accepted.

View Audit 404349

Finding 1218156 (2025-003)

Material Weakness 2025

Methodist Manor Retirement Community

IA

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

Criteria: The Organization is responsible for depositing $10,343 into a separate general ledger account every month to fund the restricted debt service reserve and they must obtain permission before using the funds. Condition: During our review of compliance with the Community Facilities Loans & Gra...

Criteria: The Organization is responsible for depositing $10,343 into a separate general ledger account every month to fund the restricted debt service reserve and they must obtain permission before using the funds. Condition: During our review of compliance with the Community Facilities Loans & Grants, we identified that the funds were not deposited for several of the required months and the funds were not in a separate general ledger account. Cause: The requirement was not met due to an oversight by management. Effect: As a result the agency reserves the right to withdraw Agency funding. Recommendation: The Organization should setup a separate general ledger account to separate the required funds, and have a review process to verify that the deposits were made properly. Client Response: The Organization has automated a reoccurring ACH that deposits $10,343 into the reserve account every month and funded the balance to the required amount. The bookkeeping company and management have added a reserve account review to their monthly checklist. Conclusion: Response accepted.

View Audit 404349

Finding 1218147 (2025-006)

Material Weakness 2025

Columbia Gorge Community College

OR

Questioned Costs Procurement, Suspension & Debarment Student Financial Aid § 200.303

Recommendation: We recommend that the college review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institution’s SAP policy. Explanation of...

Recommendation: We recommend that the college review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institution’s SAP policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since December 2025, the College has worked with the SIS Managed Services team (Anthology now Ellucian) to update its SAP policy and ensure compliance with federal regulations. The new SAP policy was fully implemented effective during the Winter 2026 term. As an internal control, at the end of each term when SAP is evaluated, the results are pre-screened by the Coordinator of Financial Aid with oversight from the Director of Financial Aid to ensure accuracy before results are posted live in the system. Additionally, the College has clarified its understanding of Anthology’s treatment of students who are newly enrolled at the College or who have changed into a different program version. These students are designated with a not-calculated SAP which represents a blank or null status until the conclusion of the term when the students receive a passing or failing grade and can be evaluated by the SAP standards. Steps also have been taken to ensure that prior enrollments are linked to ensure integrity of the application of SAP standards based on the cumulative pace, GPA and maximum timeframe. As a further measure to ensure the integrity of awarding Title IV funds only to eligible students, the College has placed students with prior ineligible SAP statuses in a hold group within the SIS and identified these students as not meeting Disbursement Approval Criteria (DAC) thus causing any attempt to disburse funds to them to fail. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218146 (2025-005)

Material Weakness 2025

Columbia Gorge Community College

OR

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

Recommendation: We recommend the College changes its process and controls to ensure exit counseling emails are sent to graduate/withdrawn students throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding...

Recommendation: We recommend the College changes its process and controls to ensure exit counseling emails are sent to graduate/withdrawn students throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since August 2025, the College has taken steps in conjunction with its SIS Managed Services team (Anthology) to establish an automated process to notify graduate/withdrawn students to complete the Exit Counseling requirement. Since then the Director of Financial Aid has been spot-checking the notifications to ensure that the exit counseling notification is being triggered for withdrawn students. Going forward, the Financial Aid Office will use the Task Function in Anthology to confirm that the notification has been sent and close the task which will be timestamped with the name of the reviewer. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218145 (2025-004)

Material Weakness 2025

Columbia Gorge Community College

OR

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

Recommendation: We recommend the college review its process and procedures for R2T4 calculations to ensure they are in line with Dept. of Education requirements. We also recommend the college maintain evidence of the formal review process that ensures Return of Title IV calculations are being perfor...

Recommendation: We recommend the college review its process and procedures for R2T4 calculations to ensure they are in line with Dept. of Education requirements. We also recommend the college maintain evidence of the formal review process that ensures Return of Title IV calculations are being performed timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will ensure that all Financial Aid policies and procedures are up-to-date; reviewed annually; and revised, as needed. Documentation will also be made for any procedures that are currently being performed by their third-party-servicer, Global including Return to Title IV (R2T4) calculations. As an internal control, the Financial Aid Office will retain records of the Return to Title IV calculations performed by Global; sign-off on the appropriate reports with the date reviewed; include the initials of the Coordinator of Financial Aid and co-signed by the Director of Financial Aid. The Coordinator of Financial Aid will notify Global of funds to be returned by the institution and/or student by completing the established process (GARP) to ensure that the funds are returned to the Department of Education within 45 days of the Date of Determination. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218144 (2025-003)

Material Weakness 2025

Columbia Gorge Community College

OR

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

Recommendation: We recommend the College review internal control reports and implement review controls for work performed by third-party servicers. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Currently, CGCC re...

Recommendation: We recommend the College review internal control reports and implement review controls for work performed by third-party servicers. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Currently, CGCC reviews several weekly reports from its third-party servicer, Global Financial Aid Services which indicates the actions which could not be completed by Global due to missing information, etc. These reports are discussed during the weekly call between Global and CGCC at which time steps are taken to resolve outstanding issues. CGCC also has access to other Financial Aid (FA) Reports in the Global Administration portal including verification, resolution of C-Flags and Unusual/Special Circumstances reviews which are conducted by Global. Going forward, the Financial Aid Office will review these reports monthly to ensure that the students are awarded and their funds disbursed in a timely fashion. As an internal control, documentation of the review of the FA reports will be retained, signed and dated by the Coordinator of Financial Aid and co-signed by the Director of Financial Aid. To further ensure integrity in the administration and awarding of Title IV funds, CGCC will annually request an SSAE 18 Report from Global in October of each year and subsequently, where applicable, a Bridge Letter to cover the intervening period between reports. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218143 (2025-001)

Material Weakness 2025

Columbia Gorge Community College

OR

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

Recommendation: We recommend the college review current processes and procedures for NSLDS enrollment reporting and retain evidence of an internal control that ensures timely and accurate reporting being performed. Explanation of disagreement with audit finding: There is no disagreement with the aud...

Recommendation: We recommend the college review current processes and procedures for NSLDS enrollment reporting and retain evidence of an internal control that ensures timely and accurate reporting being performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the past year, the College (CGCC) has worked vigorously to bring NSLDS enrollment reporting up-to-date. The College currently reports enrollment data to NSLDS through the National Student Clearinghouse. The Registrar annually establishes the Clearinghouse reporting schedule based on CGCC’s quarter system, including term start, midterm, and end dates. The schedule is posted in the Clearinghouse system, and Clearinghouse sends email reminders before scheduled reporting dates. The Registrar completes the scheduled reporting process, reviews posting results and error reports when received, and resolves any identified errors promptly to allow the enrollment file to be processed and reported. Going forward, the internal control will be to add secondary review by providing the retained report to the Vice President of Student Services. The report will include the date reviewed/submitted and the Registrar’s initials, and the Vice President will also initial the report as evidence of review. This provides documentation of completion and accountability to help ensure enrollment reporting is completed in a timely fashion. Name(s) of the contact person(s) responsible for corrective action: Catherine Graham. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218138 (2025-002)

Material Weakness 2025

Columbia Gorge Community College

OR

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid § 200.303

Recommendation: We recommend the college review the requirements and implement an internal process and control to specifically monitor the outstanding Title IV funded checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to ...

Recommendation: We recommend the college review the requirements and implement an internal process and control to specifically monitor the outstanding Title IV funded checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On a monthly basis, as part of the bank reconciliation process, the Business Office generates a report of outstanding student refund checks and reviews it for uncashed items. Uncashed Title IV checks are recorded on a tracking log noting check number, issue date, and amount. When a check remains uncashed for 120 days, the Business Office contacts the student to confirm receipt or determine whether a reissue is needed, and the outreach is documented on the log. The monthly review and log are signed and dated by the preparer; co-signed by the Vice President of Administrative Services, and documentation is retained including months in which no exceptions are noted. At the conclusion of the monthly review process, an email with subject line: Uncashed Refund Checks is forwarded to the Financial Aid Office which includes a spreadsheet listing the students with uncashed refund checks or a note that there were no records for that particular month. Any Title IV check that remains uncashed is canceled by the Business Office. Within 5 - 7 business days of receiving the notification from the Business Office, the Financial Aid Office will notify the third-party servicer, Global Financial Aid Services (herein after referred to as Global) through their established reporting mechanism (GARP) to ensure the funds are returned to the Department of Education no later than 240 days after the date of issuance, as required by 34 CFR 668.164(h). Name(s) of the contact person(s) responsible for corrective action: Sam Draper and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

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