Corrective Action Plans

Finding 1205369 (2025-001)

Material Weakness 2025

OH

Eligibility School Nutrition Programs Matching / Level of Effort / Earmarking

We have followed up with PaySchools and they have a target date of 4/30/26 for release of SOC Type II report, which should provide documentation on the effectiveness of their controls upon which we can rely when it comes to using their automated free and reduced application processing. In the meanti...

We have followed up with PaySchools and they have a target date of 4/30/26 for release of SOC Type II report, which should provide documentation on the effectiveness of their controls upon which we can rely when it comes to using their automated free and reduced application processing. In the meantime, our Food Service Supervisor will be reviewing all applications retroactive to the beginning of 2025-26.

View Audit 397060

Finding 1205361 (2025-003)

Material Weakness 2025

City of Alexandria

VA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

HeadStart Assistance Listing No. 93.600 Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation o...

HeadStart Assistance Listing No. 93.600 Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation of supporting compliance should be readily available for review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The reporting has been completed. New employees will be trained in the procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation will be available for review during the audit period. Name(s) of the contact person(s) responsible for corrective action: Noah Abraham, DCHS Operations Director. Planned completion date for corrective action plan: Complete

View Audit 397053

Finding 1205331 (2025-004)

Material Weakness 2025

Washington Adventist University

MD

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

Explanation of disagreement with audit finding: Prior finding was specific to change to withdrawal status not being timely reported in relation to students who never attended and/or stopped attending. Additional scenarios in this finding, to our knowledge, have not been found in a previous audit. We...

Explanation of disagreement with audit finding: Prior finding was specific to change to withdrawal status not being timely reported in relation to students who never attended and/or stopped attending. Additional scenarios in this finding, to our knowledge, have not been found in a previous audit. We acknowledge that they fall within the same finding, but the scenarios that fall within the overall finding are not repeats. Action taken in response to finding: WAU acknowledges the importance of effective internal controls in regards to compliance. As a result, the following corrective action steps will be implemented: • Enrollment Date Discrepancies: o The Registrar’s Office will review finding and determine the best course of action to ensure the degree conferral date for a graduate (Effective date per Institutional Record) and the Effective date per NSLDS Campus Record align. After determination of action an SOP will be created. o The Registrar’s Office will create an SOP and add to the withdrawal policy a statement regarding what the effective date will be when students are unofficially withdrawn for not attending and then later submit an official university withdrawal form. o The Registrar’s Office will research the option of continuous enrollment for students who receive a DG and/or Incomplete grade at the end of a term and do not enroll in the next term. Also, the DG and Incomplete policy will be reviewed to determine if the removal of DG and Incomplete deadline needs to be adjusted. • Program Start Date Discrepancies: o The Registrar’s Office will review finding and determine the best course of action to ensure academic program start dates in institutional records align with NSLDS program start dates. After determination of action an SOP will be created. • Missed Enrollment Certification: o See action plan for Enrollment date discrepancies above (bullet 3) • Enrollment Stats discrepancies: o The Registrar will confirm in NSC that all students who graduated but were not enrolled in the term they graduated from are reported as graduated in NSC in a timely manner and work with financial aid to determine the graduation information is recorded timely and accurately in NSLDS as well. After determination of action an SOP will be created. • Inaccurate Institutional Records: o The Registrar’s Office will review finding and determine the best course of action to ensure that students who we send University Withdrawal forms to, upon their request, get withdrawn even if the form is not returned in a timely manner. After determination of action an SOP will be created. Name(s) of the contact person(s) responsible for corrective action: • Team Lead: Registrar (Lynn Zabaleta) • Internal Control Team: Office staff • Senior Management: AVP Enrollment Management (Dirk Whatley) Planned completion date for corrective action plan: June 30, 2026

View Audit 397028

Finding 1205323 (2025-002)

Material Weakness 2025

Washington Adventist University

MD

Internal Control / Segregation of Duties Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

1. Drawdown- Financial Director will authorize drawdown with the AVP of Enrollment reviewing and approving the drawdown. 2. Reconciliation- An SOP will be developed having the Financial Advisor/Pell Grant Officer who manages reconciliation of Pelll, SEOG, and Federal work study. Director financial a...

1. Drawdown- Financial Director will authorize drawdown with the AVP of Enrollment reviewing and approving the drawdown. 2. Reconciliation- An SOP will be developed having the Financial Advisor/Pell Grant Officer who manages reconciliation of Pelll, SEOG, and Federal work study. Director financial aid will review and approve reconciliation. For Direct Loans the Direct of Financial aid will prepare the reconciliation to review by the Controller and AVP of Enrollment on a monthly basis. 3. Financial aid Packages- Third party service provider Financial Aid Services (FAS) will complete all financial aid packages with the Director of Financial aid reviewing packaging accuracing by pulling samples of at minimum 25 students for both fall and spring semester. 4. Professional Judgement- An SOP for professional judgment will be created. The Financial aid Director or Pell Grant Officer will prepare the professional judgement. The review and approval to complete by AVP of Enrollment. 5. RT24- Third party service provider (FAS) will prepare RT24 calculations with review and approval by Director of Financial aid and the Associate Vice President of Enrollment. 6. Credit Balances- An SOP will be created to ensure that credit balances are distributed to students within 14 days by verifying enrollment during disbursement. 7. Incentive Compensation – We were unable to verify whether the control to ensure that no incentive compensation is made to employees in the student recruiting and admission, and financial aid departments, is designed and operating effectively. 8. Eligibility – We identified instances in which the Cost of Attendance (COA) used to calculate financial need was inaccurate due to insufficient review and oversight over COA calculations. 9. NSLDS – We noted instances where the University’s records do not match the information shown in the Colleague system, particularly the effective withdrawal dates. Name(s) of the contact person(s) responsible for corrective action: Team Lead: Interim Director of Financial Aid (Alfred Taylor), Director of Student Accounts (Keisha Dublin) ● Internal Control team: Associate Director of Financial Aid (Associate Director of Student Accounts (Arlene Joy Canong), Financial Aid Advisor (Don Lodenquai) ● Senior Management: AVP of Enrollment Management (Dirk Whatley), Controller (Ronald Somervell) ● Financial Aid Services (FAS) Planned Completion Date for Corrective Action Plan: April 26, 2026

View Audit 397028

Finding 1205315 (2025-001)

Material Weakness 2025

Town of Stoneham, Massachusetts

MA

Reporting Allowable Costs / Cost Principles Period of Performance

The town notified the U.S. Treasury Department of the error in reporting on 01/20/26, requesting to update the FY25 Project & Expenditure Report. The U.S. Treasury Department stated “Prior submitted reports are not eligible to be reopened for revisions since the reporting deadline has passed. The SL...

The town notified the U.S. Treasury Department of the error in reporting on 01/20/26, requesting to update the FY25 Project & Expenditure Report. The U.S. Treasury Department stated “Prior submitted reports are not eligible to be reopened for revisions since the reporting deadline has passed. The SLFRF Project and Expenditure Reports are cumulative reports and any adjustments needed can be made in the current reporting period if it is still open or next open reporting period.” In addition, the town has implemented quarterly reconciliation procedures to ensure all eligible expenditures for the project reporting period are reported correctly. These procedures include a secondary review of all expenditures, reporting parameters and requirements.

View Audit 397023

Finding 1205290 (2025-004)

Material Weakness 2025

Belcourt Public School District #7

ND

Equipment & Real Property Management Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.311 § 200.313

Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will...

Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will be acquired by District purchasing agents on the ND DPI Capital Expenditure Prior Approval For Use of Federal Funding form before capital purchase is made using federal funding. Anticipated Completion Date: Fiscal Year 2025-2026

View Audit 396993

Finding 1205276 (2025-002)

Material Weakness 2025

Zane Trace Local School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management

The District will work with the contractors to get the proper payroll records to meet the prevailing wage requirements agreed upon in the contract.

View Audit 396991

Finding 1205275 (2025-007)

Material Weakness 2025

Roof Above, Inc.

NC

Subrecipient Monitoring Reporting Significant Deficiency

Corrective Action Plan Reporting Finding 2025-007 Roof Above will ensure the review of all grant invoices is documented through the signature of the reviewer on the grant cover sheet. Roof Above will institute a policy that grant invoices will not be submitted without the corresponding review signat...

Corrective Action Plan Reporting Finding 2025-007 Roof Above will ensure the review of all grant invoices is documented through the signature of the reviewer on the grant cover sheet. Roof Above will institute a policy that grant invoices will not be submitted without the corresponding review signature. Contact person responsible for corrective action: Tonya Frye, Chief Financial Officer Anticipated completion date: September 30, 2026

View Audit 396990

Finding 1205264 (2025-003)

Material Weakness 2025

Roof Above, Inc.

NC

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

Corrective Action Plan Special Tests: Housing Quality Standards Finding 2025-003 Roof Above will document review of the inspection by sending an email to the grants administrator stating the inspection has been reviewed. Contact person responsible for corrective action: Katie Church, Vice President ...

Corrective Action Plan Special Tests: Housing Quality Standards Finding 2025-003 Roof Above will document review of the inspection by sending an email to the grants administrator stating the inspection has been reviewed. Contact person responsible for corrective action: Katie Church, Vice President of Scattered Site Housing Anticipated completion date: June 30, 2026

View Audit 396990

Finding 1205262 (2025-002)

Material Weakness 2025

Roof Above, Inc.

NC

Subrecipient Monitoring Eligibility Material Weakness

Corrective Action Plan Eligibility Finding 2025-002 Roof Above will add signature lines to current client eligibility checklist, to include the name, signature and date for both the person preparing and the person reviewing tenant eligibility. Contact person responsible for corrective action: Katie ...

Corrective Action Plan Eligibility Finding 2025-002 Roof Above will add signature lines to current client eligibility checklist, to include the name, signature and date for both the person preparing and the person reviewing tenant eligibility. Contact person responsible for corrective action: Katie Church, Vice President of Scattered Site Housing Anticipated completion date: June 30, 2026

View Audit 396990

Finding 1205249 (2025-001)

Material Weakness 2025

Local Area of the Workforce Development in the Northwest

PR

Matching / Level of Effort / Earmarking

VIEWS OF RESPONSIBLE OFFICIALS Corrective Action Plan: • The Youth Committee of the Northwest Local Board will be composed of representatives from finance, Budget and Planning staff (Youth Program and Executive), who will measure compliance with 20% work experience expenditure requirement on a month...

VIEWS OF RESPONSIBLE OFFICIALS Corrective Action Plan: • The Youth Committee of the Northwest Local Board will be composed of representatives from finance, Budget and Planning staff (Youth Program and Executive), who will measure compliance with 20% work experience expenditure requirement on a monthly and quarterly basis using updates financial reports. • An immediate review of current fund expenditure will be conducted to determine the exact percentage of compliance and to establish an accelerated spending plan, to ensure compliance with the 20%. • The committee will provide the Executive Director with recommendations to operation areas to meet required expenditure targets in accordance with section 20CFR 681.590, 684.00(a), and 681.600 of WIOA, including specific corrective actions when deviations are identified. • The Northwest Local Area will strengthen outreach strategies for youth program services through social media (Facebook, ticktock, Instagram) radio, television, and the official website, with the goal of increasing recruitment of eligible participants, particularly out of school youth. • Job Fair and Educational fairs for the Youth Program will be developed and implemented to recruit out-of-school youth and increase participation in work experience activities. • Efforts will continue through mass outreach campaigns with an effective strategic plan to expand the reach of the youth program, ensuring a measurable increase in enrollment and participation. • Ongoing monitoring with performance indicators will be implemented, including the percentage of expenditures on work experience and services to out-of-school Youth, with periodic reviews. • If necessary, technical assistance will be requested form the Youth Program Specialist of the Workforce Development Program (PDL) at the Department of Economic Development and Commerce (DDEC). IMPLEMENTATION DATE Immediately RESPONSIBLE PERSONS Executive Director, Finance Director, Youth Program Staff

View Audit 396941

Finding 1205242 (2025-004)

Material Weakness 2025

Metropolitan School District of Southwest Allen County

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

Finding 2025-004 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Participation of Private School Children Summary of Finding: The School Corporation did not provide supporting documentation for the amounts disbursed for Participation of Private School C...

Finding 2025-004 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Participation of Private School Children Summary of Finding: The School Corporation did not provide supporting documentation for the amounts disbursed for Participation of Private School Children. No time sheets or logs were provided to support the hours paid to employees for working with the Private School Children. Contact Person Responsible for Corrective Action: Randi Libby, Chief Operating Officer Contact Phone Number and Email Address: (260)431-2030, rlibby@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement procedures to ensure consistent documentation supporting Title I services provided to non-public school students. All Title I staff providing services to non-public schools will be required to submit consistent, detailed timesheets documenting hours and/or days worked by non-public school, activity, and grant year. Timesheets will be completed, reviewed, and approved prior to payroll processing. The Payroll Manager will not process payroll for Title I non-public services unless the required timesheets are submitted and approved. Approved timesheets will be retained in the payroll files and organized by payroll dates, and will be made available for audit review. Anticipated Completion Date: July 1, 2026 _________________________ _Randi Libby (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)

View Audit 396929

Finding 1205240 (2025-003)

Material Weakness 2025

Metropolitan School District of Southwest Allen County

IN

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

Finding 2025-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: The School Corporation and we could not verify the unused Homeless set-aside funds were transferred to the next grant award. Contact Person Responsible for Corrective Action: Randi Libby, ...

Finding 2025-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: The School Corporation and we could not verify the unused Homeless set-aside funds were transferred to the next grant award. Contact Person Responsible for Corrective Action: Randi Libby, Chief Operating Officer Contact Phone Number and Email Address: (260)431-2030, rlibby@sacs.k12.in.us Views of Responsible Official: We disagree with the finding. Explanation and Reasons for Disagreement The School Corporation respectfully disagrees with the conclusion that it failed to comply with Title I homeless setaside requirements. Title I, Part A requires local educational agencies to reserve “such funds as are necessary” to serve homeless children and youth (20 U.S.C. § 6313(c)(3)). Neither the statute nor implementing regulations require that homeless set-aside funds be fully expended each fiscal year, nor do they require unspent homeless set-aside funds to be rolled forward and maintained as a cumulative earmark across successive grant years. During the audit period, the School Corporation increased its homeless set-aside allocation each year based on annual needs assessments. The existence of unspent balances is attributable to year-over-year increases in allocation rather than failure to reserve or obligate funds. Requiring the perpetual rollover of unspent homeless set-aside funds would be inconsistent with Title I’s annual reservation framework and would eventually consume the full 15% Title I carryover limitation, a result not contemplated by federal statute or guidance. While the auditors were unable to verify homeless set-aside expenditures to their satisfaction due to documentation and monitoring gaps, the School Corporation does not agree that this constitutes noncompliance with the earmarking requirement itself. The statutory obligation is to reserve funds based on need, which the School Corporation did. Description of Corrective Action Plan: Although the School Corporation disagrees with the compliance conclusion, it recognizes the need to strengthen internal controls and documentation related to Title I set-aside monitoring. Going forward, the School Corporation will implement enhanced procedures to document: • the annual determination of the homeless set-aside amount, • periodic monitoring of expenditures against the approved reservation, and • year-end reconciliation of reserved versus expended funds within each grant year. These procedures are intended to improve audit transparency and documentation while maintaining compliance with Title I statutory requirements. INDIANA STATE BOARD OF ACCOUNTS 31 Preparing today’s learners for tomorrow’s opportunities. Anticipated Completion Date: January 31, 2026 _________________________ _Randi Libby (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)

View Audit 396929

Finding 1205238 (2025-002)

Material Weakness 2025

Metropolitan School District of Southwest Allen County

IN

School Nutrition Programs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding 2025-002 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or dete...

Finding 2025-002 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting material noncompliance. Contact Person Responsible for Corrective Action: Erika Horner, Director of Food Service Contact Phone Number and Email Address: (260)431-2030, ehorner@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All direct certification information shall be initiated by the Director of Food Service: pulling the information monthly from CNP Web. The list of students to be directly certified will be printed, signed and dated by the Director of Food Service. Once information is imported into the student management system, the Assistant Food Service Director would then cross reference the printed list of information to benefits assigned in the student management system to ensure accuracy. The Assistant Food Service Director will initial next to the students they spot check on the list. The printed document with signatures of both parties will be retained with the school years applications.􀯗 The Director of Food Service has the responsibility to ensure that all vendors are free from suspension, debarment, or aren’t otherwise excluded. Suspension and debarment documents are to be collected on a yearly basis. If such documents are not available through the SFA Cooperative, it will be the responsibility of the Director of Food Service to acquire them through SAM.gov website or contacting the vendor directly. All documents are to be signed, dated, and retained by school year by both the Director of Food Services and the Asst. Director of Food Services. Anticipated Completion Date: January 31, 2026 _________________________ Randi Libby_ (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)

View Audit 396929

Finding 1205229 (2025-001)

Material Weakness 2025

North Fork Local School District

OH

Eligibility School Nutrition Programs Matching / Level of Effort / Earmarking

All free and reduced meal applications are completed electronically by the parent or guardian through the District's online application system. The parent/guardian inputs household and financial information used to determine eligibility in accordance with the income eligibility guidelines establishe...

All free and reduced meal applications are completed electronically by the parent or guardian through the District's online application system. The parent/guardian inputs household and financial information used to determine eligibility in accordance with the income eligibility guidelines established by the State of Ohio and the National School Lunch Program. To ensure internal controls are in place and that eligibility determinations are accurate, the District will implement a review process whereby all electronic applications submitted by parents or guardians will be reviewed by the Cafeteria Supervisor or a designated staff member prior to final approval. The reviewer will ensure that all required fields are completed, the information provided appears reasonable, and the eligibility determination generated by the system is appropriate based on the information provided on the application. If any application appears incomplete or contains questionable information, the Cafeteria Supervisor or designee will contact the parent or guardian for clarification or correction prior to approving the application. Documentation of the review will be maintained by a checklist or retained electronically to demonstrate that the review occurred. Periodic monitoring of the process will be performed to ensure the control procedures continue to operate as intended and that applications are properly reviewed before eligibility is finalized. Anticipated Completion Date Effective immediately and ongoing. Responsible Contact Person Cafeteria Supervisor Dawn Nelson

View Audit 396900

Finding 1205225 (2025-001)

Material Weakness 2025

Rutgers, the State University of New Jersey

NJ

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2025-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Pro...

2025-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Program Titles and Assistance Listing Numbers (ALN): Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Perkins Loans (ALN 84.038), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268), Nurse Faculty Loan Program (ALN 93.264), Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students (ALN 93.342), Nursing Student Loans (ALN 93.364), Scholarships for Health Professions Students from Disadvantaged Backgrounds (ALN 93.925) Federal Grant Numbers: E P007A252602 (7/1/2024 – 6/30/2025), E P033A252602 (7/1/2024 – 6/30/2025), E P038A132602 (7/1/2024 – 6/30/2025), E P063P250272 (7/1/2024 – 6/30/2025), P268K260272 (7/1/2024 – 6/30/2025), E-01HP28821-02-02, E-01HP31830-01-00,(7/1/2024 – 6/30/2025), E4CHP42498-01-00 (7/1/2024 – 6/30/2025), E26HP25750, E36HP25751, E11HP27284, E36HP26092, E36HP25751, E26HP25748 (7/1/2024 – 6/30/2025) Contact Person: Robert Fahy, AVP of University Enrollment Services, 848-932-2603 Corrective Action: Since the audit period, the University has strengthened governance and oversight over OSFP by formalizing access controls and reinforcing monitoring practices. Management has established and documented OSFP system roles and responsibilities. A review of user access was performed to ensure alignment with job responsibilities, and users holding multiple or incompatible roles were corrected. In addition, the University implemented an audit log to track user provisioning and deprovisioning activity, providing documented evidence of access changes and removals. The University has also enhanced its change management process to ensure that all updates to OSFP follow the documented change management procedures. These measures collectively strengthen logical access and change management controls and support effective internal control over system operations. Management will continue to monitor the effectiveness of these controls. Anticipated Completion Date: Completed

View Audit 396899

Finding 1205215 (2025-002)

Material Weakness 2025

McKendree University

IL

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Student Financial Assistance Cluster Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to prope...

Student Financial Assistance Cluster Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to properly capture return of Title IV funds on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned corrective action: Currently, the return of Title IV calculations are done manually and a second person within Financial Aid reviews the calculation. The University is working on a training engagement for the Financial Aid office which will explore the ability to perform the return of Title IV calculations within the ERP system. A second person would continue to review the calculation. Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid If the United States Department of Education has questions regarding this plan, please call Shari Keffer, Vice President for Administration & Finance at 618-537-6838.

View Audit 396879

Finding 1205208 (2025-006)

Material Weakness 2025

Salem Community College

NJ

Special Tests & Provisions Student Financial Aid Reporting

Views of Responsible Officials: SCC’s implementation of Student First on August 10, 2026, will help rectify the enrollment reporting issues.

View Audit 396871

Finding 1205204 (2025-002)

Material Weakness 2025

Southeast Nm Community Action Corporation

NM

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Corrective Action: SNMCAC will monitor administrative cost percentages against grant thresholds to ensure compliance. Person Responsible: Tracey Young, Fiscal Director Completion Date: March 31, 2026

View Audit 396867

Finding 1205203 (2025-001)

Material Weakness 2025

Southeast Nm Community Action Corporation

NM

Reporting Matching / Level of Effort / Earmarking

Corrective Action: SNMCAC will continue to work with the Office of Head Start to prevent future delays in filing. Person Responsible: Tracey Young, Fiscal Director Completion Date: March 31, 2026

View Audit 396867

Finding 1205201 (2025-004)

Material Weakness 2025

Jewish Child Care Association of New York and Affiliated Organization

NY

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking § 200.302

JCCA CORRECTIVE ACTION PLAN March 23, 2026 Health Resources and Services Administration Jewish Child Care Association of New York (d/b/a JCCA) and Affiliated Organization respectfully submits the following corrective action plan for the year ended June 30, 2025. _____________________________________...

JCCA CORRECTIVE ACTION PLAN March 23, 2026 Health Resources and Services Administration Jewish Child Care Association of New York (d/b/a JCCA) and Affiliated Organization respectfully submits the following corrective action plan for the year ended June 30, 2025. ____________________________________________________________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT FINDINGS Finding 2025-001 – Account Analyses MATERIAL WEAKNESS Recommendation We recommend that the Agency implement policies, procedures and controls to ensure that all accounting records are analyzed and reconciled on a monthly basis. Action Taken BTQ Financial is spearheading a comprehensive stabilization project to refine the chart of accounts and reconstruct historical tracking for the permanent endowment fund. BTQ already has in place a rigorous monthly closing schedule. This includes establishing automated reconciliation protocols for program service revenue, endowment tracking, and inter-company accounts to ensure GAAP compliance and timely board reporting. These policies, procedures, and controls to ensure that all accounting records are analyzed and reconciled on a monthly basis have already been incorporated into FY2026 monthly close process. Finding 2025-002 – Information Technology – General Control Activities SIGNIFICANT DEFICIENCY Recommendation We recommend the Agency follow their policy for password age. We also recommend the Agency perform a risk assessment over the information technology environment. We recommend a written risk assessment and penetration test to be performed annually and vulnerability scans to be performed quarterly. Action Taken The Agency has configured NetSuite and Active Directory to programmatically enforce password aging and complexity requirements that strictly mirror our established IT Security Policy. Furthermore, we have moved beyond interview-based assessments to an annual cadence of formal, written risk assessments and penetration testing, supported by continuous monthly vulnerability monitoring through our Security Operation Center (SOC). An interview-based risk assessment was performed in Q3 2025, and monthly vulnerability scans are managed by Arctic Wolf, our Security Operation Center (SOC) service provider. To further strengthen our posture, we will initiate an annual cadence of formal external and internal penetration tests starting in Q2-Q3 2026. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, Unaccompanied Alien Children Program (Assistance Listing Number 93.676), FAIN # 90ZU0603, 90ZU0567, and 90ZU0536, for FY 2025 - Significant Deficiency Finding 2025-003 – Reporting Recommendation We recommend that management of the Agency implement procedures to track all federal reporting deadlines and ensure that reports are reviewed and submitted timely. This could include maintaining a centralized grant reporting calendar and implementing supervisory review prior to submission. Action Taken With the outsourcing to BTQ now fully operational, a centralized Federal Grant Reporting Calendar has been established. This calendar includes automated alerts for all 30/60/90-day deadlines. BTQ has also implemented a dual-level supervisory review process to ensure that all future reports are validated against the general ledger and submitted well in advance of federal deadlines. This protocol has been strictly applied to all federal reporting for the FY2026 cycle. U.S. Department of Health and Human Services, Unaccompanied Alien Children Program (Assistance Listing Number 93.676), FAIN # 90ZU0603, 90ZU0567, and 90ZU0536, for FY 2025 - Significant Deficiency Finding 2025-004 – Cash Management Recommendation We recommend that management of the Agency implement formal controls over the drawdown process that includes establishing procedures requiring documented supervisory review and approval of all drawdown requests and ensuring drawdowns are based on immediate cash needs so that federal funds are expended within a reasonable amount of time. Action Taken The Agency, in collaboration with BTQ Financial, has implemented a formalized "Drawdown Authorization Protocol." This new workflow improves upon the existing, and adds a standardized approach to every drawdown request, documented supporting schedules (showing immediate cash needs), and formal approval from BTQ’s PM, SVPF, VPF, or AVPF. This ensures a clear audit trail and prevents the accumulation of excess federal cash on hand. If the Health Resources and Services Administration has questions regarding this plan, please call Kenneth Shieh, Chief Administration Officer at (718) 747-4367. Sincerely yours, Kenneth Shieh, Chief Administrative Officer

View Audit 396857

Finding 1205195 (2025-002)

Material Weakness 2025

Gaudenzia Inc.

PA

Allowable Costs / Cost Principles Eligibility Material Weakness

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of Schuylkill - Home Investm...

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of Schuylkill - Home Investment Partnerships and Housing Trust Funds Programs: Fountain Springs - Loan Mayor and City of Baltimore: Baltimore Housing - Park Heights Women and Children - Loan Type of Finding: - Material Weakness in Internal Control over Compliance - Other Matters Condition: As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless). Of 40 resident client files reviewed, management could not provide proof of income or residency status for 16 clients, or policies and procedures manuals for 22 clients. Recommendation: We recommend that management adopt and implement formal policies and procedures to ensure compliance with HOME eligibility requirements. Such policies and procedures should include clear communication of compliance requirements between staff and locations, standardized documentation and processes for determining and verifying income eligibility during intake, and procedures for the redetermination of income eligibility for residential clients residing at a location for more than one year. Repeat Finding: 2024-001 Explanation of Disagreement with Audit Finding Management acknowledges the finding and continues to strengthen internal controls related to HOME program compliance, including eligibility documentation and file retention practices across all residential program locations. Management agrees that consistent documentation of eligibility, including proof of income and residency status (as applicable under HOME requirements), is critical. We are currently reviewing and enhancing intake procedures, documentation standards, and internal monitoring processes to ensure all required eligibility documentation is properly obtained, maintained, and uniformly applied across all locations. Action taken in response to finding: In response to the recommendation, management will develop and implement formalized policies and procedures to strengthen compliance with HOME requirements. These will include standardized guidance for eligibility determination at intake, clear documentation requirements across all sites, and procedures for ongoing eligibility review for clients residing in programs beyond one year. Name of the contact person responsible for corrective action: Dr. Deja Gilbert, PhD, MDA, FACHE, LPC, LMHC, President and CEO dgilbert@gaudenzia.org Planned completion date for corrective action plan: June 30, 2026

View Audit 396854

Finding 1205159 (2025-003)

Material Weakness 2025

Beacon College, Inc.

FL

Student Financial Aid Eligibility Significant Deficiency

Recommendation: We recommend the College evaluate its procedures around packaging and awarding students to ensure loan eligibility is reassessed prior to disbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to...

Recommendation: We recommend the College evaluate its procedures around packaging and awarding students to ensure loan eligibility is reassessed prior to disbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 􀁸 The College determined that this issue resulted from the absence of a consistent process to identify and reassess students whose transfer credits were added or revised after initial financial aid packaging, potentially affecting grade level classification and Direct Loan eligibility. 􀁸 To correct this, the College will revise its packaging procedures to require a mandatory review of Direct Loan eligibility whenever transfer credits are added or updated. The Financial Aid Office will work in coordination with the IT Department and the Registrar’s Office to develop automated reports or system alerts that flag students with transfer credit changes occurring after packaging. These reports will be reviewed regularly, and any impacted student records will be reassessed and updated as necessary prior to disbursement. 􀁸 In addition, the College will strengthen oversight by implementing monitoring controls such as requirements. These measures are intended to prevent future instances of under-awarding and to enhance internal controls within the financial aid packaging and awarding process. Name(s) of the contact person(s) responsible for corrective action: Stephanie Liebowitz, Director of Financial Aid Planned completion date for corrective action plan: April 15, 2026 – Procedures will be in place for the awards cycle of the incoming 2026-2027 class.

View Audit 396825

Finding 1205148 (2025-030)

Material Weakness 2025

State of Arkansas

AR

Eligibility Subrecipient Monitoring Reporting

Finding Number: 2025-030 ALN Number(s) and Program Title(s): 93.778 – Medical Assistance Program (Medicaid Cluster) Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. DCO will continue periodic matching and review of state employees with public assistance pr...

Finding Number: 2025-030 ALN Number(s) and Program Title(s): 93.778 – Medical Assistance Program (Medicaid Cluster) Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. DCO will continue periodic matching and review of state employees with public assistance programs administered by the agency. Appropriate disciplinary action will continue to be taken by the agency on its own employees based on the outcome of case reviews. The agency will explore the addition of systematic data matching to ensure that salaries of state employees are properly reflected in the eligibility determination and benefit calculation for public assistance benefits. For additional controls, the agency has incorporated a notice into the hiring process regarding reporting all changes in household circumstance and annual communications to all staff regarding their reporting obligations. Anticipated Completion Date: 6/30/26 Contact Person: Name: Mary Franklin Title: Director, Division of County Operations Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-681-8377 Email Address: Mary.franklin@dhs.arkansas.gov

View Audit 396807

Finding 1205147 (2025-029)

Material Weakness 2025

State of Arkansas

AR

Subrecipient Monitoring Eligibility Significant Deficiency

Finding Number: 2025-029 ALN Number(s) and Program Title(s): 93.778 – Medical Assistance Program (Medicaid Cluster) Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. For cases that included a date of death in MMIS, most deficiencies can be attributed to cas...

Finding Number: 2025-029 ALN Number(s) and Program Title(s): 93.778 – Medical Assistance Program (Medicaid Cluster) Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. For cases that included a date of death in MMIS, most deficiencies can be attributed to case worker error which is being addressed through continued worker education and training. A small number of deficiencies can be attributed to a variety of system errors which are in the process of being corrected. Recoupments of overpayments are also being processed. For cases with no date of death in MMIS, almost half were the result of the eligibility system not receiving the date of death via the monthly match to the Arkansas Department of Health (ADH) vital records data. DHS will work with ADH to identity date of death for those cases and identify any corrective action needed to the match process. The remaining deficiencies can be attributed to a variety of system errors which are in the process of being corrected and worker errors which is being addressed through worker education and training. Recoupments will be processed through both automatic reconciliation and manual processes. Anticipated Completion Date: 6/30/2026 Contact Person: Name: Mary Franklin Title: Director, Division of County Operations Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-681-8377 Email Address: Mary.Franklin@dhs.arkansas.gov

View Audit 396807

Corrective Action Plans

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