Corrective Action Plans

Finding 1171506 (2025-013)

Material Weakness 2025

MD

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

Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengt...

Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengthen internal controls, MOED will establish separate grant worktags for all parts of the grant award to ensure the grant reference number is unique within the Workday award setup. UEI Subaward Validation: As a corrective action, Contracts Specialist training has been updated to require verification and documentation of the sub-recipient’s Unique Entity Identifier (UEI) through SAM.Gov as part of the subaward setup process. MOED will require grant staff to familiarize themselves with Administrative Manual policy 413- 21 Federal Grant Registration and Unique Entity Identifier, which requires UEI verification and identification in the City’s financial system of record for all subrecipients. Subrecipient Monitoring: MOED does maintain a standardized sub-recipient monitoring checklist designed to ensure subawards are administered in compliance with applicable federal statutes, regulations, and the terms and conditions of the subaward as well as relevant supporting documentation. FY2025 subrecipient monitoring was not scheduled in accordance with the monitoring timeframes outlined in the terms and conditions of the grant award. Management acknowledges this oversight and will ensure that all subrecipient monitoring is scheduled and conducted timely in accordance with the monitoring timeframes outlined in the award. Review of Subrecipient Single Audit Report: MOED performs a review of subrecipient Single Audit reports during the technical proposal evaluation and confirms the subrecipient’s inclusion on the State of Maryland’s Eligible Training Provider List (ETPL). Due to document volume size, this documentation has not historically been included in BOE-approved subrecipient agreements or retained within Workday award files. As a corrective action, MOED will formally incorporate ETPL verification into subrecipient agreements. Single Audit reports will be retained separately from the BOE approval package and uploaded to the applicable Grant Award record in Workday to ensure consistent documentation and accessibility. MOED will utilize the GMO’s subrecipient monitoring templates provided on the centralized SharePoint Grants Management platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reports are completed. Additionally, MOED will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOED will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all City-wide requirements for subrecipient monitoring. MOED will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: September 30, 2026

View Audit 384683

Finding 1171505 (2025-012)

Material Weakness 2025

City of Baltimore, Maryland

MD

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

Finding 2025-012 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOED will strengthen its fiscal reporting ...

Finding 2025-012 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOED will strengthen its fiscal reporting controls to ensure all required fiscal reports are submitted timely and in accordance with the grantor’s established timetable. This corrective action includes formal distribution of the grantor’s fiscal reporting schedule to responsible staff, implementation of internal calendar tracking for all fiscal reporting deadlines, and enhanced monitoring procedures to ensure deadlines are met and escalated when necessary. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: June 30, 2026

View Audit 384683

Finding 1171473 (2025-010)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.330 § 200.331 § 200.332 § 200.501

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and ...

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and formalize subrecipient monitoring procedures to ensure full compliance with Uniform Guidance requirements. Subrecipient agreement templates will be revised to require inclusion of the subrecipient’s Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) for all subawards, in accordance with 2 CFR §§25.300 and 200.332. MOHS has previously developed subrecipient risk assessment and monitoring tools for the Continuum of Care (CoC) program. These tools and procedures will be reviewed, updated as needed, and expanded to apply to all MOHS grants, including HOPWA. This includes documented risk assessments, monitoring plans, and verification that required Single Audit reports are obtained, reviewed, and retained when applicable. MOHS will maintain centralized subrecipient monitoring files containing executed agreements, audit reviews, monitoring documentation, and follow-up actions. Program and fiscal staff will receive training on updated subrecipient monitoring policies and documentation standards to ensure consistent implementation across all funding sources. MOHS will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, MOHS will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOHS will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. MOHS will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: September 30, 2026

View Audit 384683

Finding 1171472 (2025-009)

Material Weakness 2025

City of Baltimore, Maryland

MD

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Finding 2025-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-013 Auditee’s Corrective Action Plan: MOHS will strengthen internal contro...

Finding 2025-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-013 Auditee’s Corrective Action Plan: MOHS will strengthen internal controls over federal reporting to ensure accuracy, completeness, and compliance with HUD and Uniform Guidance requirements. Specifically, MOHS will implement a documented reconciliation process requiring all HOPWA expenditures reported in the Federal Financial Report (FFR) to be reconciled to the general ledger prior to regular submission, with supervisory review and approval documented. MOHS will establish a formal reporting calendar and standardized checklist to ensure timely preparation, review, and submission of all required HUD reports, including the FFR, Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting (FSRS), and the Consolidated Annual Performance and Evaluation Report (CAPER). • Written procedures will be developed to clearly define staff roles and responsibilities for federal reporting and FFATA compliance, including identification of reportable first-tier subawards and documentation of FSRS submissions. MOHS will also provide targeted training to program and fiscal staff responsible for federal reporting and will conduct periodic internal monitoring to verify compliance with 2 CFR §200.303 and 2 CFR Part 170. MOHS will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. • Per the GMO’s guidance, MOHS will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: June 30, 2026

View Audit 384683

Finding 1171413 (2025-008)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking HUD Housing Programs Reporting § 200.303

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, t...

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, the Consolidated Planning Division has been conducting a widespread effort to ensure programmatic compliance with all City and Federal requirements. To date, it has prioritized: • Reducing the grant’s at-risk financial exposure from approximately $28M in FY23 to $1.03M in FY25. • Implemented moving all NPO operating contracts to the same Period of Performance (July 1 – June 30 of the grant year) to ensure timely expenditure of funds and reduce compliance burden on staff. • Implemented the use of a form agreement approval process for the Board of Estimates (BOE) which reduced the lag time for contract execution and subsequent reimbursement from over 12 months, to approximately 2 months once the executed grant agreement has been received from HUD and approved by the BOE. • Standardized required subrecipient activity reporting and requests for reimbursement in Neighborly (the City’s reporting system of record for the CDBG grant program) to a quarterly basis. • Required all supporting documentation be submitted and reviewed quarterly to eliminate the possibility of overpayment or reimbursement for ineligible activities. • Hired a Director of CDBG finance to improve fiduciary and compliance oversight of federal funds. • Ensured the HUD-required Cash-on-Hand report is entered into a new screen in HUD’s system of record - Integrated Disbursement and Information System (IDIS) - (reporting that was previously collected through Federal Financial Report (FFR)/Standard Form 425 (SF-425) on a timely basis. Corrective Action Plan: • A new Director of CDBG Finance will be hired before the end of FY26. • The new Director of CDBG Finance will be provided training to complete the Cash on Hand Report and will cross-train additional staff on the completion of this report to ensure redundancy. • Supporting documents will be kept on the divisional shared drive in a clearly named subfolder. Contact Person: Mary Correia, Deputy Commissioner David Fielder, Assistant Commissioner Completion Date: June 30, 2026

View Audit 384683

Finding 1171367 (2025-002)

Material Weakness 2025

Sheltercare

OR

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

--Corrective Action Plan: As part of the significant turnover within the accounting department in FY24-25, the individual preparing the current year SEFA this year had no previous experience with doing so. Management will take better care to prepare it next year so that it does not require adjustmen...

--Corrective Action Plan: As part of the significant turnover within the accounting department in FY24-25, the individual preparing the current year SEFA this year had no previous experience with doing so. Management will take better care to prepare it next year so that it does not require adjustment, and has prepared a written procedure to follow for preparation of the SEFA. --Person Responsible: Phoebe Benjamin, Associate Finance Director --Date Implemented: 1/1/2026

View Audit 384658

Finding 1171320 (2025-005)

Material Weakness 2025

Eastern Greene Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.208 § 200.303

FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Contact Person Responsible for Corrective Action: Superintendent and Title I Program Director Mr. Todd Tanksley Contact Phone Number and Email Address: 812-849-4...

FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Contact Person Responsible for Corrective Action: Superintendent and Title I Program Director Mr. Todd Tanksley Contact Phone Number and Email Address: 812-849-4481 – tanksleyto@mitchell.k12.in.us Views of Responsible O􀆯icial: We concur with the finding. Description of Corrective Action Plan The School Corporation has implemented enhanced internal control procedures to ensure compliance with Assessment System Security requirements and applicable state and federal regulations. E􀆯ective immediately, the School Corporation will: 1. Require all employees who administer, handle, or have access to secure test materials to complete annual assessment security training in accordance with the Indiana Assessment Policy Manual. 2. Require all such employees to sign the Indiana Testing Security and Integrity Agreement annually by an established deadline. INDIANA STATE BOARD OF ACCOUNTS 34 3. Establish a standardized process to collect, review, and retain signed testing security agreements at the building level. 4. Maintain a centralized tracking log of all employees required to complete training and sign agreements. 5. Conduct an annual verification review to ensure that all required documentation is complete prior to the testing window. 6. Retain all assessment security training documentation and signed agreements in accordance with federal record retention requirements under 2 CFR 200.334. Planned Evidence of Correction The School Corporation will maintain the following documentation as evidence of corrective action: ● Annual assessment security training agendas and attendance record ● Signed Indiana Testing Security and Integrity Agreements for all applicable sta􀆯 ● Centralized tracking logs indicating completion of training and agreement signatures ● Building-level verification checklists signed and dated by administrators ● Written internal procedures related to assessment system security compliance Anticipated Completion Date Implemented and ongoing beginning with the FY2026 assessment cycle.

View Audit 384594

Finding 1171316 (2025-003)

Material Weakness 2025

Eastern Greene Schools

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2025-03 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Dr. Emily Dykstra Contact Phone Number and Email Address: 812-849-4481 / dykstrae@mitchell.k12.in.us Views of Responsible Officials: “We concur with the finding.” Descript...

FINDING 2025-03 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Dr. Emily Dykstra Contact Phone Number and Email Address: 812-849-4481 / dykstrae@mitchell.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: Mitchell Community Schools will utilize time and effort logs to track time that personnel spend working with non-public students. These logs will be turned into the Director of Special Education at the end of each school year, so that they will be available for future audits. A time and effort log template will be created by March 6, 2026 to be utilized with personnel for future IDEA grants. Anticipated Completion Date: March 6, 2026

View Audit 384594

Finding 1171162 (2025-003)

Material Weakness 2025

Arizona Christian University

AZ

Student Financial Aid Eligibility Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure the Stafford loans are awarded within the annual and aggregate limits. Explanation of disagreement with audit finding: T...

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure the Stafford loans are awarded within the annual and aggregate limits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the time the Subsidized Direct Loan was initially awarded, the student was classified as grade level one and was correctly awarded $3,500. Subsequently, the student’s grade level increased; however, the Direct Loan award was not adjusted accordingly. The Office of Financial Aid relies on email notifications to identify students with grade-level changes, and the notification for this student was inadvertently missed. In response to this error, the Office of Financial Aid implemented additional monitoring controls. A report was developed to identify all students with changes in grade level and is now generated and provided weekly by the Office of the Registrar to the Office of Financial Aid. A designated Financial Aid Advisor has been assigned responsibility for reviewing this report and adjusting Direct Loan awards as necessary to ensure accuracy. As an additional preventative measure, the Director of Financial Aid will verify student grade level and corresponding Direct Loan eligibility prior to disbursement. The Office of Financial Aid will also conduct periodic reviews to confirm that Direct Loan awards consistently and accurately align with students’ grade levels.

View Audit 384567

Finding 1171157 (2025-002)

Material Weakness 2025

Arizona Christian University

AZ

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding:...

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The withdrawal dates applied in the Return to Title IV (R2T4) calculations were based on the dates students were administratively withdrawn by the Office of the Registrar. Upon identification of the audit finding, the Office of Financial Aid conducted a comprehensive review of the affected R2T4 calculations and made the necessary corrections. Any balances resulting from these errors were subsequently written off. Additionally, the Director of Financial Aid completed a full file review for the applicable award year to assess the accurate inclusion of scheduled break days. During this review, two additional students were identified whose R2T4 calculations did not include the appropriate number of break days. The calculations for these students were corrected, and the resulting balances were written off. No further errors were identified. As part of the corrective action, the Office of Financial Aid has hired an additional Financial Aid Advisor dedicated to the review and completion of R2T4 calculations. Furthermore, the Director of Financial Aid has implemented a secondary review process for all completed R2T4 calculations to ensure accuracy and compliance. The Office of Financial Aid has also reviewed the Financial Aid Handbook and applicable Code of Federal Regulations (CFR) related to R2T4 calculations to reinforce adherence to regulatory requirements. Name(s) of the contact person(s) responsible for corrective action: Angel Faast and Laura Silva Planned completion date for corrective action plan: 12/17/2025

View Audit 384567

Finding 1171136 (2025-001)

Material Weakness 2025

Sharon Ridge Expansion Corporation

CT

Matching / Level of Effort / Earmarking

Finding No. 2025-001 - Replacement Reserve Deposits Planned Corrective Action - Management will ensure that required monthly deposits are brought current and kept current in the future. Anticipated Completion Date - June 30, 2026. As of December 2025, Sharon Ridge Expansion Corporation has made paym...

Finding No. 2025-001 - Replacement Reserve Deposits Planned Corrective Action - Management will ensure that required monthly deposits are brought current and kept current in the future. Anticipated Completion Date - June 30, 2026. As of December 2025, Sharon Ridge Expansion Corporation has made payments for deposits through August 2025. Responsible Contact Person - Donn Castonguay, Treasurer

View Audit 384521

Finding 1171099 (2025-002)

Material Weakness 2025

Northeast Ohio Medical University

OH

Student Financial Aid Subrecipient Monitoring Reporting

Finding Number: 2025-002 Anticipated Completion Date: 10/07/2025 Responsible Contact Person: Katherine Miranda, University Registrar Kelly Burt, Assistant Registrar Records Management and Reporting Michele Bergman, Assistant Registrar, Records Management and Reporting Planned Corrective Action: The ...

Finding Number: 2025-002 Anticipated Completion Date: 10/07/2025 Responsible Contact Person: Katherine Miranda, University Registrar Kelly Burt, Assistant Registrar Records Management and Reporting Michele Bergman, Assistant Registrar, Records Management and Reporting Planned Corrective Action: The Offices of the Registrar and Admission Operations reviewed the case, reviewed the proper student record protocol, and added a reporting checkpoint to review for dually enrolled students before submitting enrollment reports to the National Student Clearinghouse (NSC). Once NSLDS is updated with NSC data, the Office of the Registrar will work with Office of Financial Aid to confirm NSLDS is accurate for the dually enrolled students.

View Audit 384492

Finding 1170941 (2025-003)

Material Weakness 2025

Jewish Family Services, Inc.

WI

Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management § 200.305 § 200.318 § 200.326 § 200.430 § 200.431

Criteria or Specific Requirement: Subparts D and E of 2 CFR Part 200 require a nonfederal entity to establish written policies, procedures, and standards of conduct, including procedures to implement the cash management requirements of 2 CFR section 200.305, procedures that comply with the procureme...

Criteria or Specific Requirement: Subparts D and E of 2 CFR Part 200 require a nonfederal entity to establish written policies, procedures, and standards of conduct, including procedures to implement the cash management requirements of 2 CFR section 200.305, procedures that comply with the procurement standards of 2 CFR sections 200.318 through 200.326, and procedures for determining the allowability of costs in accordance with Subpart E of 2 CFR Part 200. Specifically, 2 CFR sections 200.430, 200.431, and 200.475 require written policies concerning compensation for personal services, fringe benefits, and travel costs, respectively. Views from Responsible Officials: Management agrees with the finding. Management has established written policies and procedures after yearend that were the policies and procedures followed during the year under audit and meets the requirements of Subparts D and E of 2 CFR Part 200. Contact Person: John Jacques Date of Completion: November 14, 2025

View Audit 384246

Finding 1170887 (2025-002)

Material Weakness 2025

Hood College of Frederick, Maryland and Affiliates

MD

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency § 200.303

Corrective Action Plan Finding Number: 2025-002 – Return of Title IV Funds Controls Finding: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Corrective Action Planned Given the size of the Financial Aid Office, the College will implement comp...

Corrective Action Plan Finding Number: 2025-002 – Return of Title IV Funds Controls Finding: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Corrective Action Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure R2T4 calculations are accurate, timely, and compliant with federal regulations. Effective immediately, the College will implement the following controls: 1. Standardized R2T4 Processing All R2T4 calculations will be performed using the Department of Education Common Origination & Disbursement (COD) system to ensure consistent application of federal formulas. Official withdrawal dates will be confirmed using Registrar records prior to calculation. 2. Independent Post-Calculation Review Each R2T4 calculation will be reviewed by an individual other than the preparer, where feasible, or through supervisory review when staffing is limited. The review will confirm the accuracy of withdrawal dates, days attended, calculation inputs, and Title IV funds included. 3. Coordination and Reconciliation The Office of Financial Aid will coordinate with Student Accounts to ensure R2T4 results are applied correctly to the student account and that returned funds are processed within required timelines. 4. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained for each R2T4 calculation. A simple R2T4 review checklist or log will be maintained. 5. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to ensure R2T4 calculations and reviews are completed accurately and timely. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: Implemented effective August 1, 2025 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been identified. While formal independent review controls were not documented during the audit period, there were no identified R2T4 compliance issues, late returns, or calculation errors. The corrective actions above are intended to formalize review processes and further reduce compliance risk.

View Audit 384186

Finding 1170880 (2025-001)

Material Weakness 2025

Hood College of Frederick, Maryland and Affiliates

MD

Matching / Level of Effort / Earmarking Student Financial Aid Allowable Costs / Cost Principles § 200.303

Corrective Action Plan Finding Number: 2025-001 – Enrollment Reporting Controls – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to NSLDS for student enrollment status changes. Corrective Actions Planned Given the size of the F...

Corrective Action Plan Finding Number: 2025-001 – Enrollment Reporting Controls – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to NSLDS for student enrollment status changes. Corrective Actions Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure accurate and timely enrollment reporting while maintaining operational efficiency. Effective immediately, the College will implement the following controls: 1. Continued Use of the National Student Clearinghouse (NSC) The College will continue to rely on the National Student Clearinghouse as its third-party servicer for enrollment status reporting to NSLDS. 2. Independent Post-Submission Review On a monthly basis, the Office of Financial Aid will review NSC enrollment reporting confirmation files to verify that enrollment status changes were submitted to NSLDS accurately and within the required 60-day timeframe. This review will be performed by an individual other than the primary preparer, where feasible, or through supervisory review when staffing is limited. 3. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained. A simple enrollment reporting review log will be maintained to document compliance. 4. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to confirm controls are operating as intended. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: February 1, 2026 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been initiated. While formal independent review controls were not documented during the audit period, there were no identified instances of late enrollment reporting or inaccurate enrollment status submissions to NSLDS. The corrective actions above are intended to formalize controls and ensure sustained compliance with federal requirements.

View Audit 384186

Finding 1170768 (2025-002)

Material Weakness 2025

Unified School District Number 494

KS

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

Recommendations: The District should put controls in place that require contractors performing contract work valued at more than $2,000 and paid with federal funds to submit the required payroll reports, per the Wage Rate Requirements, throughout the contract work. Action Taken: We agree with the re...

Recommendations: The District should put controls in place that require contractors performing contract work valued at more than $2,000 and paid with federal funds to submit the required payroll reports, per the Wage Rate Requirements, throughout the contract work. Action Taken: We agree with the recommendation. Our targeted implementation date is January 2026

View Audit 384012

Finding 1170767 (2025-001)

Material Weakness 2025

Unified School District Number 494

KS

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

Recommendations: The District should include infrastructure items in the current inventory system. Action Taken: We agree with the recommendation. Our targeted implementation date is January 2026.

View Audit 384012

Finding 1170654 (2025-001)

Material Weakness 2025

Detroit Housing Commission

MI

Subrecipient Monitoring Matching / Level of Effort / Earmarking

Condition: The Commission was unable to send failed HQS inspection notices promptly to participants who needed to correct deficiencies. Planned Corrective Action: HCV will hire additional internal support for HQS inspections to work alongside external vendors and ensure timely updates/mailings/, and...

Condition: The Commission was unable to send failed HQS inspection notices promptly to participants who needed to correct deficiencies. Planned Corrective Action: HCV will hire additional internal support for HQS inspections to work alongside external vendors and ensure timely updates/mailings/, and closeouts are uploaded to the work management system, Yardi. Contact person responsible for corrective action: Felicia Burris, HCV Program Manager Anticipated Completion Date: 6/30/2026

View Audit 383877

Finding 1170625 (2025-001)

Material Weakness 2025

Primary Health Care, Inc.

IA

Special Tests & Provisions Matching / Level of Effort / Earmarking

Primary Health Care Corrective Action Plan – Sliding Fee Finding: During the External Financial Audit for FY 2025, it was determined that certain patients had received sliding fee discounts that were not consistent with the stated sliding fee discount categories under PHC’s policy. Action Step Lead ...

Primary Health Care Corrective Action Plan – Sliding Fee Finding: During the External Financial Audit for FY 2025, it was determined that certain patients had received sliding fee discounts that were not consistent with the stated sliding fee discount categories under PHC’s policy. Action Step Lead Support Due Date Update resource materials associated with sliding fee discounts and distribute to necessary staff. Provide training to necessary staff on sliding fee discount policy and any changes to discounts. Beth Frantum, CFO Revenue Cycle Director Patient Services Director March 2026 Develop and implement an internal review process to provide reasonable assurance that Slide calculations are accurate and EPIC reflects the correct amount expected for services. Beth Frantum, CFO Revenue Cycle Director Patient Services Director John Shaw, Director of Clinics April 2026

View Audit 383865

Finding 1170556 (2025-003)

Material Weakness 2025

Los Angeles Unified School District

CA

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

Payroll Administration concurs with the recommendation pertaining to the preparation, review, and approval of employee timesheets to ensure the accuracy and completeness of payroll records. Employee timesheets and payroll records are originated, reviewed, and retained at the respective work location...

Payroll Administration concurs with the recommendation pertaining to the preparation, review, and approval of employee timesheets to ensure the accuracy and completeness of payroll records. Employee timesheets and payroll records are originated, reviewed, and retained at the respective work locations. Therefore, Payroll Administration does not have direct access to these site-level records. To strengthen compliance, Payroll Administration will continue to provide targeted training and guidance to time reporters and time approvers on the timely review and approval of timesheets, the required time and effort certification, as well as the reconciliation of timesheet data with SAP entries. These topics will be reinforced during the monthly Time Reporter and Time Approver Virtual Office Hours. Furthermore, Payroll Administration will continue to issue periodic communications and disseminate the Best Practices Worksheet, which outlines key payroll compliance requirements, including adherence to payroll cut-off deadlines and reconciliation of timesheets and time entry in SAP. Payroll Administration remains committed to supporting District departments and school sites in maintaining full compliance with established payroll policies and procedures. Name: Araceli Pineda Title: Director, Payroll Administration Contact Information: araceli.pineda@lausd.net

View Audit 383812

Finding 1170483 (2025-001)

Material Weakness 2025

Antelope Valley Community College District

CA

Eligibility Student Financial Aid Matching / Level of Effort / Earmarking

The financial aid office is under new leadership as of January 1, 2025. During 2025, department leadership began its review of departmental policies and procedures, focusing on remediating compliance weaknesses within the department while moving toward best practice in federal and state aid delivery...

The financial aid office is under new leadership as of January 1, 2025. During 2025, department leadership began its review of departmental policies and procedures, focusing on remediating compliance weaknesses within the department while moving toward best practice in federal and state aid delivery. Department leadership has put structures in place at multiple points of potential failure to prevent inaccurate aid calculations. These structures include new policy and procedure documentation, enhanced optimization in the Banner system, staff training in multiple modalities including intradepartmental training, asynchronous independent training, off-site training, and a monthly reconciliation program with AVC’s fiscal office. We have also begun a system of cross training to ensure that expertise persists within the department during times of staffing changes, extended leaves of absence, and vacancies.

View Audit 383685

Finding 1170481 (2025-001)

Material Weakness 2025

Millennium-Oakwood Apartments, LLC

IL

Cash Management HUD Housing Programs Matching / Level of Effort / Earmarking

Finding 2025-001: During the year ended September 30, 2025, the Company loaned funds totaling $10,850 to two other Communities under common management and affiliated with the Sole Member of the Company to help fund operating shortfalls of the other Communities. Comments on the Finding and Each Recom...

Finding 2025-001: During the year ended September 30, 2025, the Company loaned funds totaling $10,850 to two other Communities under common management and affiliated with the Sole Member of the Company to help fund operating shortfalls of the other Communities. Comments on the Finding and Each Recommendation: Management and/or the Sole Member should reimburse the Company for the funds that were loaned to the two other Communities. If there are further operating shortfalls in the future, these should be funded by Management and/or the Sole Member and not borrowed from other Communities. Action(s) taken or planned on the finding: Management concurs with the finding and agrees with the recommendation. On November 7, 2025, Management deposited $10,850 into the Community's operating account. No further action is required.

View Audit 383664

Finding 1170413 (2025-003)

Material Weakness 2025

Elmwood Park Community Unit School District 401

IL

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

Finding No: 2025-003 Condition: The District does not have an adequate review process in place for meal count claims prior to submission. Claims prepared by one individual are submitted without independent verification. As a result, the district reported an incorrect lunch count for January 2025. Th...

Finding No: 2025-003 Condition: The District does not have an adequate review process in place for meal count claims prior to submission. Claims prepared by one individual are submitted without independent verification. As a result, the district reported an incorrect lunch count for January 2025. This error appears to be isolated to January; however, it would likely have been prevented if a review process were in place. Plan: The District will implement a system in which meal count claims will have secondary approval by the CSBO. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Mark Orszula, CSBO

View Audit 383589

Finding 1170382 (2025-002)

Material Weakness 2025

Treasure Valley Community College

OR

Eligibility Significant Deficiency Matching / Level of Effort / Earmarking

Condition & Criteria: For three aviation program students, cost of attendance calculations were based on expected high-cost courses, but actual enrollment differed, resulting in overstated costs and excess aid disbursement. Auditor’s Recommendation: Adjust cost of attendance based on actual courses ...

Condition & Criteria: For three aviation program students, cost of attendance calculations were based on expected high-cost courses, but actual enrollment differed, resulting in overstated costs and excess aid disbursement. Auditor’s Recommendation: Adjust cost of attendance based on actual courses attended and fees incurred. Corrective Action: The Financial Aid Department now verifies actual course enrollment prior to disbursement for specialized programs, ensuring accuracy and compliance. Beginning Winter term 2026, mid-term audits for the aviation program have been implemented to strengthen oversight. Additionally, policy updates now require real-time cost of attendance adjustments for all individualized programs to maintain consistency and alignment with federal regulations. Responsible Person: Director of Financial Aid, with support from Aviation Program Director. Anticipated Completion Date: Begin implementation immediately and accomplish full implementation by Spring 2026; ongoing monitoring.

View Audit 383527

Finding 1170374 (2025-003)

Material Weakness 2025

Clinton Community Unit School District 15

IL

Reporting School Nutrition Programs Significant Deficiency § 200.303

The District will review the work performed by the individual preparing the reports before submission

View Audit 383519

Corrective Action Plans

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