Corrective Action Plans

Finding 1169763 (2025-001)

Material Weakness 2025

MD

Student Financial Aid Reporting Significant Deficiency § 200.303

U.S. Department of Education 2025-001: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During our testing of enrollment status reporting, we noted the change in enrollment status was not reported within 60 day...

U.S. Department of Education 2025-001: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During our testing of enrollment status reporting, we noted the change in enrollment status was not reported within 60 days. Recommendation: We recommend Hagerstown Community College reevaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure timely and accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid has contacted the National Student Clearinghouse (NSC) to assess whether any errors occurred during the file transmission process. As of the date of this submission, HCC has not received a response from NSC. Upon receipt of NSC’s findings, HCC will work collaboratively with NSC to identify the root cause of the error and implement corrective actions to prevent recurrence. HCC will continue to perform periodic spot checks of student records transmitted to NSC and subsequently reported to the National Student Loan Data System (NSLDS). Any discrepancies identified through these reviews will be addressed through coordinated corrective action by the Financial Aid, Registrar, and Institutional Effectiveness offices to ensure data accuracy and regulatory compliance. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 382851

Finding 1169732 (2025-002)

Material Weakness 2025

Council Groves Apartments, Inc.

MT

Subrecipient Monitoring HUD Housing Programs Matching / Level of Effort / Earmarking

2025-002, Section 207 Loan Pursuant to Section 223(f), Federal Assistance Listing Number 14.134 Planned Corrective Action: Management has corrected the identified deficiency related to the tenant security deposit bank account. Subsequent to year end, on December 12, 2025, management transferred fund...

2025-002, Section 207 Loan Pursuant to Section 223(f), Federal Assistance Listing Number 14.134 Planned Corrective Action: Management has corrected the identified deficiency related to the tenant security deposit bank account. Subsequent to year end, on December 12, 2025, management transferred funds into the tenant security deposit bank account to fully fund the account in an amount equal to the related tenant security deposit liability. In addition, management has implemented procedures to ensure ongoing compliance with HUD requirements, including: • Monthly reconciliation of the tenant security deposit bank account to the related liability balance; • Management review of the reconciliation to ensure the account remains fully funded at all times; and • Enhanced monitoring of the tenant security deposit account, particularly during periods of property management transition. These actions are intended to ensure tenant security deposits are fully segregated and safeguarded in accordance with HUD regulations and program requirements. Anticipated Completion Date: Corrected as of December 12, 2025; ongoing monitoring thereafter. Status: Corrected.

View Audit 382803

Finding 1169731 (2025-001)

Material Weakness 2025

Pacific University

OR

Student Financial Aid Matching / Level of Effort / Earmarking

Name of Contact Person: Tammy Sanders, Controller, tammy.sanders@pacificu.edu Corrective Action Planned: Pacific University acknowledges the importance of an effective control environment. Management will implement proper reviews of disbursement notices to ensure timeliness and completeness. Anticip...

Name of Contact Person: Tammy Sanders, Controller, tammy.sanders@pacificu.edu Corrective Action Planned: Pacific University acknowledges the importance of an effective control environment. Management will implement proper reviews of disbursement notices to ensure timeliness and completeness. Anticipated Completion Date: January 31, 2026 Statement of Concurrence or Nonconcurrence: Pacific University management agrees with the finding.

View Audit 382800

Finding 1169641 (2025-002)

Material Weakness 2025

City of Great Falls, Montana

MT

Reporting Internal Control / Segregation of Duties HUD Housing Programs

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Community Development Block Grants/Entitlement Grants Assistance Listing Number: 14.218 Finding Summary: One of three quarterly PR29 Cash on Hand reports submitted to HUD contained an inaccurate figure for revolving ...

Federal Agency Name: U.S. Department of Housing and Urban Development Program Name: Community Development Block Grants/Entitlement Grants Assistance Listing Number: 14.218 Finding Summary: One of three quarterly PR29 Cash on Hand reports submitted to HUD contained an inaccurate figure for revolving funds received on Line 13, due to insufficient internal review and reconciliation. Additionally, the amount on Line 5 on the PR26 Financial Summary Report was unable to be supported. Corrective Action Plan: The City will strengthen internal controls over CDBG reporting by: • Implementing a documented secondary review process for all PR29 and PR26 reports. • Requiring reconciliation of source data to report figures prior to submission. Responsible Individual(s): Melissa Kinzler, Finance Director Tom Hazen, Grant Administrator Anticipated Completion Date: January 2026

View Audit 382641

Finding 1169558 (2025-002)

Material Weakness 2025

Rock Valley College

IL

Special Tests & Provisions Student Financial Aid Reporting

2025-002: Late Return of Title [V Financial Aid - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title [V Fund testing, we noted that the College did not calculate or return Title IV ...

2025-002: Late Return of Title [V Financial Aid - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title [V Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for two out of twenty-five students tested until after 45 days when the ryan student ceased attendance. We consider the untimely calculation and Return of Title TV Student Financial Aid to be an instance of noncompliance relating to the Special Tests and Provisions Compliance Requirement. This is a repeat finding of prior year Finding 2024-001. Corrective Action Plan To strengthen compliance with R2T4 timelines, the Financial Aid Office has implemented enhanced monitoring and workflow procedures. Responsibility for the weekly review and processing of R2T4 calculations has been reassigned to the Coordinator of Student Loans, ensuring consistent oversight and timely completion of required actions. Meetings are held every Wednesday to address any cases requiring follow-up creating a checkpoint to prevent delays. Responsible Person for Corrective Action Plan Coordinator of Student Loans Executive Director of Financial Aid Implementation Date of Corrective Action Plan 10/01/2025

View Audit 382544

Finding 1169505 (2025-003)

Material Weakness 2025

Bishop State Community College

AL

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.328

Finding 2025 – 003 - Reporting (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the abov...

Finding 2025 – 003 - Reporting (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To enhance the effectiveness of internal controls and ensure that all Title III reports are accurate, properly reviewed, and approved prior to submission, the Fiscal Service office will require management to review and sign off as confirmation of approval prior to submission.

View Audit 382425

Finding 1169504 (2025-002)

Material Weakness 2025

Bishop State Community College

AL

Allowable Costs / Cost Principles Period of Performance Significant Deficiency § 200.308 § 200.309 § 200.403

Finding 2025 – 002- Allowable Costs & Period of Performance (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as in...

Finding 2025 – 002- Allowable Costs & Period of Performance (Significant Deficiency and Noncompliance) Management’s Response: Management concurs with the above finding, and the Fiscal Service Office will implement corrective action before September 2026. Management acknowledges the process gap as indicated and noted in the above findings. To strengthen policies and procedures surrounding grant disbursements and ensure expenses are properly approved and allowable under the specific grant budget, the Fiscal Service Office along with the Human Resources Department will implement a process to properly document, review, and approve all allowable grant pay rates and salaries.

View Audit 382425

Finding 1169412 (2025-003)

Material Weakness 2025

Life University, Inc.

GA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Individuals Responsible for Corrective Action Plan: •Collections Coordinator •Director of Student Accounts Condition: Life University transitioned from UAS services to ECSI. In the transition of that service provides, documentation that was to be maintained to remain compliant with the Federal Perki...

Individuals Responsible for Corrective Action Plan: •Collections Coordinator •Director of Student Accounts Condition: Life University transitioned from UAS services to ECSI. In the transition of that service provides, documentation that was to be maintained to remain compliant with the Federal Perkins loan program was lost. The university has attempted on numerous occasions to assign the defaulted loans using alternative documentation to verify the debt. All attempts have been denied. The university has now been in practice with the current corrective action plan to address the deficiencies in documentation and reestablish the validity of the debt. Management’s Corrective Action Plan: Life University has implemented and continues to maintain the following corrective measures to ensure ongoing compliance: 1.Borrower Contact and Notification Life University has initiated and continues to conduct proactive outreach to borrowersrequiring an updated or newly established MPN (Master Promissory Note) or equivalentdocumentation. Communication is conducted through multiple channels, including: •Phone •Email 2.Clear Documentation Instructions The University will continue to issue formal notices to affected borrowers outlining therequirement for a new MPN or equivalent documentation. Each notice includes step-by-stepinstructions for completion, a clear explanation of the purpose and importance of the MPN,and information regarding its impact on the borrower’s outstanding loan balance. 3.Reassignment of Collection Rights Upon borrower completion of the required documentation, Life University has coordinatedwith ECSI to reassign the University’s right to collect on any remaining balances. This processcontinues to be applied as additional borrowers complete their documentation. 4.Documentation Review and Verification The University has established and continues to follow a review process to verify that eachnew MPN is complete, accurate, and properly executed. This ensures that borrower consentis valid and that all collection rights are appropriately reassigned. 5.Financial Record Updates Life University has updated and continues to maintain accurate financial records reflectingthe new MPNs and reassigned collection rights. Outstanding amounts, repayment schedules,and related data are verified and recorded to ensure consistency with federal andinstitutional requirements. 6.Ongoing Communication and Monitoring The University continues to monitor borrower compliance and maintain communicationthroughout the process. Regular follow-ups and reminders are sent as needed to ensuretimely completion and documentation integrity. At the conclusion of a 12 month outreach,students who have not verified their debt to come within compliance will be written off. Anticipated Completion Date: ongoing

View Audit 382340

Finding 1169348 (2025-006)

Material Weakness 2025

Wayland Baptist University

TX

Eligibility Significant Deficiency Matching / Level of Effort / Earmarking

Incorrect Resolution of ISIR Aggregate Limits Flag Planned Corrective Action: All financial aid staff received a copy of the FAFSA Specifications Guide, Volume 7 – Comment Codes applicable to the current academic year, and are required to reference this guide for each student file they review to ens...

Incorrect Resolution of ISIR Aggregate Limits Flag Planned Corrective Action: All financial aid staff received a copy of the FAFSA Specifications Guide, Volume 7 – Comment Codes applicable to the current academic year, and are required to reference this guide for each student file they review to ensure that all comment codes requiring resolution are properly addressed. Additionally, the Assistant Director of Financial Aid distributes daily ISIR import reports to all financial aid staff. Any ISIRs requiring resolution are identified within these reports as well as within the corresponding student files in our system. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler, and Assistant Director of Financial Aid, Alyssa Shealor Anticipated Date of Completion: June 30, 2026

View Audit 382279

Finding 1169345 (2025-002)

Material Weakness 2025

Wayland Baptist University

TX

Reporting Student Financial Aid Eligibility

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: WBU has entered into an agreement with Ellucian to implement Ellucian Student powered by Colleague as the new student information system. WBU will start utilizing this new student information syste...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: WBU has entered into an agreement with Ellucian to implement Ellucian Student powered by Colleague as the new student information system. WBU will start utilizing this new student information system in April 2026. WBU will utilize the built-in functionality and tools to report to NSLDS at that time which should correct this issue completely. We will continue to work towards compliance with NSLDS reporting requirements through the following action plan: An internal SSRS report for official and unofficial withdrawals which accurately reflects withdrawn students remains available to the WBU offices of Financial Aid and the Registrar for verification as part of the planned corrective action. The custom NSC reporting tool(s) will continue to be updated to make sure the correct combination of fields and corresponding data sources are reported as accurately as possible. WBU will continue to work with NSC to mitigate issues related to data not transferring correctly between NSC and NSLDS. • A field-by-field analysis plus any needed corrections to the queries will be performed. o By default, term "W" withdrawals are reconsidered by the updated tool each time a report is generated for NSC. o Some date fields have been corrected that were previously misunderstood by the custom tool's historical authors. o Post-submission error corrections by registrar staff via NSC's website are spot-checked by Information Technology when requested. o If certain data issues cannot be resolved satisfactorily via NSC alone, then corrective measures via NSLDS directly may be considered. o The PowerCampus 9.1.2 baseline product's NSC reporting tool was determined to be insufficient for timely and accurate reporting to NSC with WBU's current data on several counts. WBU has upgraded the PowerCampus system to version 9.2.3 and will continue to work towards a solution for the baseline reporting tool with the upgraded system.  Some of the recurring data updates needed before running the PC baseline tool, are still being run periodically as a source data benefit for the custom tool. Person Responsible for Corrective Action Plan: Chief Information Officer, Cagan Cummings Anticipated Date of Completion: Ongoing

View Audit 382279

Finding 1169342 (2025-004)

Material Weakness 2025

Wayland Baptist University

TX

Significant Deficiency Matching / Level of Effort / Earmarking

Need Analysis Planned Corrective Action: The Assistant Director of Compliance & Reporting developed reports to help identify any students who were not properly offered the subsidized loan which was reviewed before the start of the first term of the current academic year. In addition, the reports wil...

Need Analysis Planned Corrective Action: The Assistant Director of Compliance & Reporting developed reports to help identify any students who were not properly offered the subsidized loan which was reviewed before the start of the first term of the current academic year. In addition, the reports will be reviewed periodically throughout the aid year to identify enrollment or academic record changes that may affect loan eligibility. When discrepancies are identified, loan offers will be adjusted promptly to ensure compliance with federal loan limits. These corrective actions strengthen oversight, improve accuracy in loan awarding, and enhance internal controls to prevent recurrence of this issue. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler Anticipated Date of Completion: June 30, 2026

View Audit 382279

Finding 1169311 (2025-002)

Material Weakness 2025

Hands Triad Housing, Inc.

PA

HUD Housing Programs Matching / Level of Effort / Earmarking

B. Comment on Findings and Recommendations We concur with the auditor's finding that HANDS Metro's funds were used to fund the HANDS Triad Housing insurance audit escrow. We had a new employee and they made a mistake and it was not found until the assistant controller reviewed the ledgers 2 weeks la...

B. Comment on Findings and Recommendations We concur with the auditor's finding that HANDS Metro's funds were used to fund the HANDS Triad Housing insurance audit escrow. We had a new employee and they made a mistake and it was not found until the assistant controller reviewed the ledgers 2 weeks later (which happened to be past year end). This was not an intentional transaction to use a different properties funds to put into an escrow account, it was a mistake. The funds have since been transferred back to HANDS Metro. C. Actions Taken or Planned The Assistant Controller and Property Accountant will review all funds were paid from the correct account before the transfer is completed in the bank account.

View Audit 382257

Finding 1169309 (2025-002)

Material Weakness 2025

Hands Metro Apartments, Inc.

PA

HUD Housing Programs Matching / Level of Effort / Earmarking

B. Comment on Findings and Recommendations We concur with the auditor's finding that HANDS Metro's funds were used to fund the HANDS Triad Housing insurance audit escrow. We had a new employee and they made a mistake and it was not found until the assistant controller reviewed the ledgers 2 weeks la...

B. Comment on Findings and Recommendations We concur with the auditor's finding that HANDS Metro's funds were used to fund the HANDS Triad Housing insurance audit escrow. We had a new employee and they made a mistake and it was not found until the assistant controller reviewed the ledgers 2 weeks later (which happened to be past year end). This was not an intentional transaction to use a different properties funds to put into an escrow account, it was a mistake. The funds have since been transferred back to HANDS Metro. C. Actions Taken or Planned The Assistant Controller and Property Accountant will review all funds were paid from the correct account before the transfer is completed in the bank account.

View Audit 382256

Finding 1169297 (2025-001)

Material Weakness 2025

University of Oklahoma Health Sciences Center

OK

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was n...

The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately. Officials Responsible for Ensuring Corrective Action: Shanna Pope, Registrar Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding and will implement enhanced procedures to ensure internal controls support the timely and accurate reporting of student status, program, and completion information to the National Student Loan Data System (NSLDS). For each National Student Clearinghouse (NSC) file submitted, students with status, program, or completion changes will be systematically identified and flagged for review. Registrar staff will conduct a targeted, sample-based review of these flagged records directly within NSLDS to verify that data transmitted from NSC was received, processed, and reflected accurately. All policies and procedures governing enrollment reporting and the processing of student status, program, and completion changes will be reviewed, revised as necessary, and formally implemented no later than April 1, 2026, to align with this corrective action.

View Audit 382241

Finding 1169279 (2025-004)

Material Weakness 2025

Lewis & Clark Community College District 536

IL

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

Procedures are currently in place to comply with the requirement to send Direct Loan notifications within the regulatory time frame. To support this, the responsible team member will have a weekly reminder added to their Lewis & Clark Outlook work calendar to prompt timely notifications. Management ...

Procedures are currently in place to comply with the requirement to send Direct Loan notifications within the regulatory time frame. To support this, the responsible team member will have a weekly reminder added to their Lewis & Clark Outlook work calendar to prompt timely notifications. Management will also add a weekly reminder to one of the office managers' calendars to assist with ongoing monitoring and compliance checks. Person(s) Responsible: Angela Weaver Timing for Implementation: November 7, 2025

View Audit 382227

Finding 1169278 (2025-003)

Material Weakness 2025

Lewis & Clark Community College District 536

IL

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

The Financial Aid office conducted a comprehensive internal review in Spring 2025 to verify that our procedures were consistently followed. As a result, management corrected a student’s loan proration calculation to be consistent with current practices, regarding truncating rather than rounding the ...

The Financial Aid office conducted a comprehensive internal review in Spring 2025 to verify that our procedures were consistently followed. As a result, management corrected a student’s loan proration calculation to be consistent with current practices, regarding truncating rather than rounding the fractional percentage (decimal) of loan eligibility for students receiving one-semester loans in their last semester of study. Management corrected the loan proration calculation in accordance with current procedures, and the loan amount was adjusted accordingly, resulting in the institution returning $64 in Federal Unsubsidized loan funds to Federal Student Aid. The student was eligible only for unsubsidized loans. Person(s) Responsible: Angela Weaver Timing for Implementation: November 21, 2025

View Audit 382227

Finding 1169245 (2025-001)

Material Weakness 2025

City of Central

LA

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

We have carefully reviewed the finding of Documentation of Internal Controls over Federal Awards. The City of Central concurs with the finding. City management recognizes the importance of maintaining current, comprehensive, and properly documented internal controls over federal awards in accordance...

We have carefully reviewed the finding of Documentation of Internal Controls over Federal Awards. The City of Central concurs with the finding. City management recognizes the importance of maintaining current, comprehensive, and properly documented internal controls over federal awards in accordance with 2 CFR part 200.303(a). The City acknowledges that while formal policies and procedures existed, they were not fully updated to reflect current Uniform Guidance requirements and did not sufficiently address all applicable compliance areas for the federal programs administered. The City will undertake a comprehensive review of its existing policies and procedures. Management will update and formalize internal control documentation over federal awards to ensure alignment with Uniform Guidance requirements and to address all relevant compliance areas applicable to the City’s federal programs. This process will include identifying key control activities, documenting responsibilities, and ensuring controls are properly designed and implemented. Additionally, management will increase awareness of Uniform Guidance requirements and internal controls documentation standards by providing resources to applicable staff. Management will continue to periodically review internal control documentation to ensure continued compliance as federal requirements change. Responsible Officials: Mayor Wade Evans; Suzonne Cowart, CPA; Michele Lobianco Anticipated Completion Date: February 2026

View Audit 382200

Finding 1169244 (2025-001)

Material Weakness 2025

Lone Star College System

TX

Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking

1. Immediate Compliance Review and Documentation Grants Accounting & Grants Development and Compliance (GDC) will conduct a comprehensive review of the five HEIA grants renewed for FY2026: • Verify each employee's current compensation source (institutional vs. grant funds) • Calculate the correct gr...

1. Immediate Compliance Review and Documentation Grants Accounting & Grants Development and Compliance (GDC) will conduct a comprehensive review of the five HEIA grants renewed for FY2026: • Verify each employee's current compensation source (institutional vs. grant funds) • Calculate the correct grant-funded compensation based on Level of Effort percentages • Determine the period of noncompliance for each grant • Document total amount of personnel costs that should have been charged to grants • Make adjusting entries in FY2026 as needed 2. Transition Personnel to Grant-Funded Payroll (if required) Grants Accounting will work with the Program Team to: • Establish split-funding arrangements for each affected employee based on their Level of Effort • Update payroll accounting codes to properly charge personnel costs to grant accounts • Ensure proper fund availability and budget alignment 3. Review Time and Effort Reporting Procedures and Update (if necessary) Establish compliant time and effort documentation as required by 2 CFR 200.430: • For employees working solely on one grant (100% effort): Implement semi-annual certification • For employees on multiple cost objectives: Review time and effort documentation to ensure proper payroll allocation; correct as needed • Re-train all affected personnel on time and effort reporting requirements • Establish quarterly review process to ensure accurate reporting 4. Budget Realignment and Prior Approval Requests For each affected grant: • Review current budget vs. actual expenditures • Determine if budget modifications are needed to accommodate personnel costs • Submit prior approval requests to Department of Education if required (2 CFR 200.308) • Coordinate with program officers for each grant as needed 5. Policy and Procedure Updates Develop and implement enhanced procedures to prevent recurrence: • Update standard operating procedures for setting up grant-funded positions • Establish pre-award checklist requiring coordination between Grants Office and HR • Implement quarterly reconciliation between GAN key personnel and actual payroll charges • Require GDC to sign-off on all personnel appointments for grant-funded positions • Update training and grant orientation information as needed 6. Training and Communication Provide comprehensive training to: • All current Project Directors/Managers on federal grant personnel requirements • HR staff on grant-funded position management • Grants Accounting staff on proper cost allocation and monitoring • Department chairs/supervisors who oversee grant-funded personnel 7. Ongoing Monitoring and Quality Assurance Implement enhanced monitoring procedures: • Monthly reconciliation of GAN key personnel vs. actual grant charges • Quarterly review of time and effort reports for completeness and accuracy • Annual internal review of grant personnel compliance 8. Communication with Federal Agencies As appropriate: • Submit required modifications or amendments to grant agreements • Provide documentation of compliance restoration

View Audit 382199

Finding 1169243 (2025-001)

Material Weakness 2025

Bayport-Blue Point Union Free School District

NY

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

2025-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027 Special Education Preschool Grants ALN: 84.173 Condition: Subpart I, 2 CFR §200.4...

2025-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027 Special Education Preschool Grants ALN: 84.173 Condition: Subpart I, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employees work on more than one Federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, it was noted that in some instances, the District’s PARs were not signed by the employees. In addition, PARs for employees not charged 100% to a single grant were prepared retrospectively after year end rather than periodically throughout the year. Planned Corrective Action: PARS’s were sent to all employees on a bi-monthly basis beginning October 31, 2025. PAR’s that were not returned in a timely manner with signature were sent to the employee’s supervisor directly to obtain signature. Responsible Contact Person: Keri Loughlin Assistant Superintendent for Finance and Operations Bayport-Blue Point Union Free School District 189 Academy Street Bayport, New York 11705 Anticipated Completion Date: October 31, 2025

View Audit 382194

Finding 1169177 (2025-001)

Material Weakness 2025

City of Chattanooga, Tennessee

TN

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

The City will implement procedures to ensure that all current year expenditures related to federal awards are accurately recorded on the SEFA and properly reconciled to the General Ledger.

View Audit 382059

Finding 1169129 (2025-003)

Material Weakness 2025

Columbia Community Unit School District #4

IL

Matching / Level of Effort / Earmarking

Condition: All grant fund expenditures should be posted to and accounted for in the general ledger accounts separate from other district expenditures. Wages that were paid with grant funds were not posted to separate grant general ledger accounts. Recommendation: We recommend steps are taken to esta...

Condition: All grant fund expenditures should be posted to and accounted for in the general ledger accounts separate from other district expenditures. Wages that were paid with grant funds were not posted to separate grant general ledger accounts. Recommendation: We recommend steps are taken to establish additional IDEA grant accounts for the purposes of tracking payroll expenditures billed to the grant. We also recommend implementing a detailed grant tracking sheet that would add another level of reconciliation between the quarterly reports to ISBE and the general ledger data. Management Response: The District will consider the implementation of additional grant accounts and a detailed grant tracking sheet. Anticipated Date of Completion: June 30, 2026

View Audit 381940

Finding 1169093 (2025-001)

Material Weakness 2025

Bellin College, Inc.

WI

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

The institution implemented adequate oversight to ensure the dates and the student information match NSLDS. To achieve this, the institution has started following up every NSLDS report-run with monitoring to visually confirm the correct data shows up in NSLDS within the required timeframe. The insti...

The institution implemented adequate oversight to ensure the dates and the student information match NSLDS. To achieve this, the institution has started following up every NSLDS report-run with monitoring to visually confirm the correct data shows up in NSLDS within the required timeframe. The institution will keep documentation of the audits and will audit 100% of the records until confidence is gained that the process is working and NSLDS reporting is compliant.

View Audit 381839

Finding 1169088 (2025-004)

Material Weakness 2025

City of Forest City

IA

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

The City will work on a formal process for tracking all federal grants so that the reported federal expenditures are accurate.

View Audit 381838

Finding 1169047 (2025-002)

Material Weakness 2025

Parents As Teachers National Center, Inc.

MO

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

View of Responsible Officials and Planned Corrective Actions: The Center concurs with the finding. We acknowledge that our current accounting systems are outdated and lack the functionality required to support accurate and efficient expense allocations. We are in the final stages of selecting a new ...

View of Responsible Officials and Planned Corrective Actions: The Center concurs with the finding. We acknowledge that our current accounting systems are outdated and lack the functionality required to support accurate and efficient expense allocations. We are in the final stages of selecting a new accounting system that which enhance our financial reporting capabilities and improve allocation accuracy. In the interim, the Center has implemented manual procedures to mitigate the risk of misallocations. Specifically, credit card purchases are now being manually entered into the general ledger to ensure each transaction is accurately matched to its corresponding receipt. This process provides greater transparency and reduces the likelihood of erroneous allocations. Additionally, we continue to utilize our Purchase Order process, which requires pre-approval by management for all purchases. This control ensures that expenditures are authorized and properly aligned with program objectives prior to being incurred. These interim measures, combined with our upcoming system upgrade, are intended to strengthen our internal controls and ensure that expenses charged to Federal awards are allocable in accordance with 2 CFR § 75.405.

View Audit 381737

Finding 1169044 (2025-002)

Material Weakness 2025

Lafayette School Corporation

IN

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

FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA)- Earmarking Summary of Finding: The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2023-2024, the Cooperative operated the special education programs and s...

FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA)- Earmarking Summary of Finding: The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2023-2024, the Cooperative operated the special education programs and spent the federal money on behalf of all of its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 22611-021-PN01, 22611-021-ARP, 22619-021-ARP, 23611-021-PN01, and 23619-021-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 22611-021-PN01, 22611-021-ARP, 22619-021-ARP, 23611-021-PN01, and 23619-021-PN01 grant awards. Contact Person Responsible for Corrective Action: Lissa Stranahan Contact Phone Number and Email Address: (Phone) 765-771-6013 (Email) lstranahan@lsc.k12.in.us Views of Responsible Officials: We concur with the finding. The Greater Lafayette Area Special Services (GLASS)and Local Education Agency, Lafayette School Corporation, concur with the audit finding for Earmarking. GLASS did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The methodology used by the Cooperative to monitor non-public proportionate share expenditures was based upon a percentage for each school corporation that comprises the Cooperative rather than basing the expenditures off of the grant award for each non-public school within the geographical boundaries of the school corporations. While all proportionate share funds were expended, it was problematic in determining if the minimum amount per the grant awards was expended and properly reported prior to July 1, 2024. INDIANA STATE BOARD OF ACCOUNTS 28 Description of Corrective Action Plan: The former Director of GLASS retired June 30, 2023. Upon hire on July 1, 2023, the new director immediately implemented measures to correct the previous methodology used at GLASS. Non-public proportionate share funds are identified and reported based upon the grant award for each school corporation. The expenditures are based upon the geographical location of the non-public school and the corresponding public school corporation, not based upon the “home” school corporation of the student. This process was implemented and descriptions were included on the ledgers to identify non-public school proportionate share for grants that were initiated during the FY 2024-2025 school year. Anticipated Completion Date: The corrective action was already put into place on July 1, 2023 and implemented with FY 2024-2025. The audit finding reflects the previous grant cycle for 2022 grants and 2023 grants, which is prior to this action taken.

View Audit 381720

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