Corrective Action Plans

Finding 539687 (2024-005)

Material Weakness 2024

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Material Weakness Reporting

Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (ASU) Responsible Official: Kisha Bond, Registrar Corrective Action Planned: ASU must report enrollment status for students in the NSLDS database within a 60-day window. ASU reported the enrollment status for the ...

Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (ASU) Responsible Official: Kisha Bond, Registrar Corrective Action Planned: ASU must report enrollment status for students in the NSLDS database within a 60-day window. ASU reported the enrollment status for the students but not within 60 days. Moving forward, ASU will monitor the activity for the NSLDS database and submit student enrollment data on a timely basis. Estimated Completion Date: August 29, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (JSU) Responsible Official: Ms. Lakesha Tubbs, Registrar Corrective Action Planned: Jackson State University will implement a multi-tiered enrollment reporting schedule to enhance accuracy and prevent certification and enrollment reporting errors. Effective immediately, JSU will submit an initial enrollment reporting file to the National Student Clearinghouse at the beginning of each term. Additionally, two subsequent enrollment reports will be submitted—one at midterm and another within ten (10) days of final grade publication at the end of the term. To ensure consistency, transparency, and alignment across university departments, JSU will establish an Enrollment Reporting Oversight Committee composed of representatives from key university offices. This committee will convene quarterly throughout the academic year to review enrollment reporting processes, address potential discrepancies, and implement best practices. By fostering collaboration amongst stakeholders, JSU will ensure compliance, accuracy, and efficiency in enrollment reporting. Estimated Completion Date: May 9, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (MSU) Responsible Official: Emily Shaw, University Registrar Corrective Action Planned: In addition to reporting in a timely manner to National Student Clearinghouse, MSU will also begin to monitor NSC’s reports to NSLDS. Estimated Completion Date: June 15, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (MVSU) Responsible Official: Jeffrey Loggins, Director of Student Records Corrective Action Planned: The Office of Student Records will review the schedule submission dates for enrollment reporting to the National Student Clearinghouse to ensure compliance with certifying student enrollment within 60-day timeframe from program enrollment effective date. Additionally, enrollment reporting data will be carefully reviewed in an effort to avoid future enrollment errors. Moreover, this may include adding an additional date to report enrollment data during semesters. Estimated Completion Date: February 15, 2026 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (UMMC) Responsible Official: Emily Cole, Executive Director Office of Enrollment Management Corrective Action Planned: As an internal control measure, the Office of Enrollment Management has identified two individuals to verify all enrollment changes are appropriately captured in the National Student Loan Data System (NSLDS) within the 60-day time period. The Senior Record Specialist and Senior Enrollment Data Specialist will review pertinent records in the NSLDS monthly to verify all information has been correctly conveyed from the National Student Clearinghouse System. Estimated Completion Date: Effective immediately

View Audit 350191

Finding 539685 (2024-003)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

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

Finding Reference: 2024-003 - SFA COD Reporting (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU reconciles Pell and federal direct student loans to COD monthly. The reconciliation is done timely, and ASU will continue to reconcile and pr...

Finding Reference: 2024-003 - SFA COD Reporting (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU reconciles Pell and federal direct student loans to COD monthly. The reconciliation is done timely, and ASU will continue to reconcile and provide evidence of review. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships; Ms. Lakesha Tubbs, Registrar; Adrienne Walls, Bursar Corrective Action Planned: In previous years, Jackson State University has extended the purge and registration dates to better serve a high number of students from underrepresented communities and low-income backgrounds, ensuring that they have the opportunity to complete the enrollment process. However, this practice has led to inaccurate reporting of enrollment dates. Moving forward, Jackson State University will work with new, continuing, and readmit students beginning in April 2025 through the start of the Fall 2025 semester on August 18, 2025, to ensure all enrollment materials are completed before the beginning of each term. As part of this effort, Jackson State University has redesigned its new student orientation process with the goal of ensuring students are completely registered before arriving on campus for the fall semester. Within this new model, a dedicated position has been created for First-Time Freshmen to establish proactive outreach and education regarding costs to students and families. The redesigned orientation process places a strong emphasis on First-Time Freshmen, guaranteeing they receive the necessary guidance and support to successfully transition into college life. Additionally, the university will enforce enrollment deadline dates to prevent inaccurate enrollment data and eliminate errors in disbursement records. In addition to enhancing the student enrollment process, JSU is also taking steps to strengthen financial accountability. Furthermore, Jackson State University’s Financial Aid Office, in coordination with its Business Office, will begin holding regularly scheduled reconciliation meetings at the end of each month. These meetings will ensure that the amounts disbursed on both sides align and that figures from both departments match what has been drawn down and either paid out or returned to the U.S. Department of Education Common Origination and Disbursement (COD). Both departments will also utilize an institutional reconciliation document to add another layer of control and prevent errors. These strategic improvements reflect Jackson State University’s ongoing commitment to compliance, operational efficiency, and student success. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The internal control procedures will initiate a reconciliation of disbursement dates against COD data. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (UMMC) Responsible Official: Davita Weary, Director of Student Financial Aid Corrective Action Planned: Reconciliations will be reviewed with Kelly Dismuke, Director of Finance Operations, on a monthly basis. Estimated Completion Date: March 26, 2025 Finding Reference: 2024-003 - SFA COD Reporting (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: USM reconciles Pell and DL monthly. Copies of reconciliations are saved in a shared drive and can be made available upon request. The reconciliations will be reviewed on a monthly basis by the Financial Aid Assistant Director (Alanna McDonald) and Director (David Williamson), and the Bursar (Barbara Madison) when necessary. Estimated Completion Date: March 17, 2025

View Audit 350191

Finding 539678 (2024-008)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: The Jackson State University Division of Financial Aid has implemented a co...

Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: The Jackson State University Division of Financial Aid has implemented a comprehensive training initiative to strengthen compliance, improve accuracy, and enhance staff proficiency in federal student aid verification. As of May 7, 2024, ongoing training has commenced for all financial aid staff on the 2024-2025 verification process and required documentation. Additionally, beginning April 4, 2025, the department will launch continuous training on verification procedures and Federal Student Aid compliance to ensure staff remains informed of regulatory updates and best practices. To further enhance accuracy and accountability, the department will collaborate with the Department of Information Technology (IT) to develop internal error reports that proactively identify discrepancies in student records. An internal checklist will also be implemented to ensure that each student selected for verification by the U.S. Department of Education has submitted all required documentation. This checklist must be reviewed and signed off by the Executive Director of Student Financial Aid Services and Scholarships before final processing. As part of the department’s transition to a more automated verification process, JSU will integrate Campus-Logic, powered by Ellucian, to streamline operations and reduce manual errors. Comprehensive training sessions will be conducted to ensure financial aid staff are proficient in using the platform. Additionally, an internal checklist within Campus-Logic will be established to facilitate structured review and compliance tracking. A final verification review will be conducted by the Executive Director of Student Financial Aid Services and Scholarships to uphold accuracy and federal compliance, ultimately mitigating errors and improving audit outcomes. Estimated Completion Date: December 19, 2025 Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The verification process will ensure all student data is accurate and corrected by staff. Estimated Completion Date: September 30, 2025

View Audit 350191

Finding 539677 (2024-006)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

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

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver ...

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver credit balance to students. The contract with the servicer should have been uploaded to the Dept of Ed database. Since the audit finding, the contract has been uploaded. ASU will upload the contract timely going forward. Estimated Completion Date: Effective Immediately Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (MVSU) Responsible Official: Mrs. Brittney Manuel-Carpenter, Account Receivable Supervisor Corrective Action Planned: MVSU acknowledged the findings of reference 2024-06 SFA-Special Test- Using a Servicer to Deliver Title IV Credit Balances. MVSU acknowledges that the servicer contract is uploaded to the Department of Education database and is available for viewing. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: University will contact the Department of Education Cash Management to correct the URL link. While the link was broken on the Cash Management site it was active on the USM Business Services website: https://www.usm.edu/business-services/refunds.php and is continually maintained on their site. Estimated Completion Date: April 1, 2025

View Audit 350191

Finding 539676 (2024-004)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

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

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that...

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that addresses all 7 required elements of the GLBA regulations: • Review GLBA Requirements: Conduct a thorough review of the Gramm-Leach-Bliley Act (GLBA) regulations to understand the 7 required elements. - Completed • Gap Analysis: A gap analysis has been performed to identify missing elements in the current information security program. - Completed • Program Development: Develop and implement policies and procedures to address the identified gaps. This includes administrative, technical, and physical safeguards. - In Progress • Training: Provide training to staff on the new policies and procedures to ensure compliance and proper implementation. - Planning • vCISO Support: Leverage the expertise of the newly hired virtual Chief Information Security Officer (vCISO) to guide the development and implementation of the information security program. - In Progress 2. Conduct a Comprehensive Risk Assessment to identify and address significant gaps in the risk assessment process: • Risk Assessment Framework: Establish a risk assessment framework that aligns with GLBA requirements. - In Progress • Identify Risks: Identify potential risks to the confidentiality, integrity, and availability of customer information. – In Progress • Evaluate Controls: Assess the effectiveness of existing controls and identify areas for improvement. – In Progress • Mitigation Plan: Develop a risk mitigation plan to address identified vulnerabilities and implement appropriate controls. - Planning • vCISO Support: Utilize the vCISO's expertise to ensure a thorough and effective risk assessment process. – In Progress 3. Monitoring and Continuous Improvement to ensure ongoing compliance and continuous improvement of the information security program: • Regular Audits: Conduct regular audits to ensure compliance with GLBA regulations and the effectiveness of the information security program. – Planning • Feedback Mechanism: Establish a feedback mechanism to gather input from staff and stakeholders on the effectiveness of the program. - Planning • Update Policies: Periodically review and update policies and procedures to address emerging threats and changes in regulations. – In Progress • vCISO Support: Engage the vCISO in monitoring and continuous improvement efforts to maintain high standards of information security. – In Progress 4. Reporting and Accountability to ensure accountability and transparency in the implementation of the corrective action plan: • Assign Responsibility: Assign responsibility for the implementation of the corrective action plan to a dedicated team or individual. - Planning • Progress Reports: Provide regular progress reports to senior management and stakeholders on the implementation of the corrective action plan. - Planning • Documentation: Maintain thorough documentation of all actions taken to address the identified issues. - Planning • vCISO Support: Include the vCISO in reporting and accountability processes to ensure expert oversight and guidance. – In Progress By following this corrective action plan and leveraging the expertise of the vCISO, MVSU can address the deficiencies in its information security program and risk assessment process, ensuring compliance with GLBA regulations and protecting customer information effectively. Estimated Completion Date: November 30, 2025

View Audit 350191

Finding 539675 (2024-002)

Material Weakness 2024

State of Mississippi Institutions of Higher Learning

MS

Questioned Costs Student Financial Aid Special Tests & Provisions

Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU will ensure that post withdrawal aid that could have been disbursed will be disbursed timely unless...

Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU will ensure that post withdrawal aid that could have been disbursed will be disbursed timely unless the student requests otherwise. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has examined the error and has implemented targeted training on the Return of Title IV (R2T4) process. This training focuses on accurately determining break days and performing the required calculations to ensure precision and compliance. To reinforce these efforts, the university will continue to provide quarterly training and cross-training opportunities for staff, ensuring a comprehensive understanding of R2T4 policies and procedures. To further strengthen accuracy, an additional internal review process has been established within the financial aid office. This review will be conducted by the Executive Director of Financial Aid, who will oversee calculations until the responsibility is designated to another team member with demonstrated expertise in R2T4 processing. These corrective measures will enhance the accuracy of R2T4 calculations, ensure compliance with federal regulations, and improve overall financial aid operations at Jackson State University. Estimated Completion Date: May 2, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (MSU) Responsible Official: Lori Ball Executive Director for Financial Aid and Scholarship Corrective Action Planned: Our interpretation of the regulation was that if classes were held on weekends before or after the 5-day break, the weekend days were not counted, only the week itself (Monday- Friday) and the weekend afterwards. Classes started back the next Monday so we used 7 days. If we do not have classes on Saturday before spring break, we are now counting 9 days. Estimated Completion Date: March 15, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The internal control procedures have been updated to incorporate a nine-day break. The refund of funds to the Department of Education will be processed upon completion of the necessary calculations. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (UM) Responsible Official: Mr. Eduardo Prieto, Vice Chancellor for Enrollment Management Corrective Action Planned: The University of Mississippi’s Office of Financial Aid has an existing process for next-level supervisor review of all Return of Title IV (R2T4) calculations. To further strengthen compliance, future R2T4 reviews will also include any documentation used to determine the date of withdrawal. While it is believed that communication with instructors was accurate, messaging will be refined to clarify which activities cannot be used to document academic engagement (e.g., simply logging into the online system). Additional scrutiny will be applied when determining the last date of attendance for online courses, and instructors will be contacted for clarification as needed. The Office of Financial Aid has also established a unit to enhance compliance through internal reviews of various processes, including R2T4. Although not all R2T4 calculations will be selected for examination, sample evaluations will provide an additional level of oversight. Additionally, a transition to Ellucian’s Banner system is planned for the 2026-2027 academic year, requiring instructors to report the last date of attendance for all F grades at the time of grade entry. This change will help minimize ambiguity regarding unofficial withdrawals. Estimated Completion Date: April 1, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (UMMC) Responsible Official: Coralisa Williams, Senior Financial Aid Advisor Corrective Action Planned: Processing procedure has been updated to state the use of the “last date in class” from the academic calendar published in the UMMC Bulletin to ensure consistent and correct processing of R2T4. Estimated Completion Date: Effective immediately (has reviewed current R2T4 for accuracy) Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: The university included the Friday commencement day as last day of the term. Our reasoning is that some students are still completing assignments, tests, and class projects through the day of commencement. The financial aid office will verify the number of class days with the registrar office before each semester to ensure all class days are included in the award period. The student with the possible post-withdrawal disbursement withdrew prior to our census and all institutional charges were reversed and we could not verify that the student actually attended any of their classes. Effective February 3, 2025, institutions are exempt from performing an R2T4 calculation in this situation. Amend § 668.22(a)(2)(ii)(A)(6) to exempt institutions from performing an R2T4 calculation if: (1) a student is treated as never having begun attendance; (2) the institution returns all title IV, HEA assistance disbursed to the student for that payment period or period of enrollment; (3) the institution refunds all institutional charges to the student for that payment period or period of enrollment; and (4) the institution writes off or cancels any payment period or period of enrollment balance owed by the student to the institution due to the institution's returning of title IV, HEA funds to the Department. Going forward, USM intends to not perform R2T4 calculations for students that meet one of the above exemptions. Other possible post withdrawal disbursement will be tracked, and communication will be sent to students eligible once they are identified and calculated upon withdrawal. Estimated Completion Date: March 17, 2025

View Audit 350191 Questioned Costs: $1

Finding 539640 (2024-005)

Significant Deficiency 2024

Nbcc

CA

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

xiii. Management Response and Corrective Action Plan: One of the individuals tested was identified as not being enrolled in the audited grant during the audit period. This is correct. The individual was exited from the program in the previous audit period and written documentation was uploaded to d...

xiii. Management Response and Corrective Action Plan: One of the individuals tested was identified as not being enrolled in the audited grant during the audit period. This is correct. The individual was exited from the program in the previous audit period and written documentation was uploaded to demonstrate this. However, the case manager neglected to exit the individual from HMIS during the previous audit period. This has been corrected. No services or funds were provided to this individual following their exit from the program. Our program has a good track record of data compliance and we expect this was an exception and not the rule. Program management will review and train staff again on data compliance during a weekly staff meeting, and will also counsel the involved staff member on the error to ensure there is no similar future error. xiv. Contact Person (s) Responsible for Corrective Action: Cassie Roach, Safe Parking Program Director, croach@sbnbcc.org Joel Goforth, Homeless Services Director, jgoforth@sbnbcc.org xv. Anticipated Completion Date: The anticipated completion date is April 30, 2025.

View Audit 350179

Finding 539638 (2024-003)

Significant Deficiency 2024

Nbcc

CA

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

vii. Management Response and Corrective Action Plan: The travel in question involved staff travel to the annual National Alliance to End Homelessness (NAEH) conference. As evidenced by correspondence with HUD AAQ, it has long been established that attending an NAEH conference is an eligible use of ...

vii. Management Response and Corrective Action Plan: The travel in question involved staff travel to the annual National Alliance to End Homelessness (NAEH) conference. As evidenced by correspondence with HUD AAQ, it has long been established that attending an NAEH conference is an eligible use of CoC and ESG grant funds. We perceived the historical general approval to be in alignment with the contract requirement of obtaining written approval for the reimbursement of costs incurred for travel outside the county. All costs submitted for reimbursement were eligible and reasonable expenses. We now understand this historical approval by HUD was not transferrable to this grant and therefore, moving forward, we will secure email approval of travel eligibility for specific grant reimbursement prior to travel. To that end, we have already been in contact with Housing and Community Development (HCD) fiscal staff at Santa Barbara County about a reliable method to secure said approvals in advance moving forward. If travel is not approved for a specific grant, or not obtained prior to travel, other unrestricted income will be utilized for that portion of the travel expenses. viii. Contact Person (s) Responsible for Corrective Action: Kristine Schwarz, Executive Director, kschwarz@sbnbcc.org Victoria Garfield, Grants Administrator, vgarfield@sbnbcc.org ix. Anticipated Completion Date: Staff anticipate attending the annual NAEH conference this year, therefore we will request approval once registration is confirmed and expect to receive approval or rejection from County CD staff by no later than the date of travel, or approximately July 15, 2025.

View Audit 350179 Questioned Costs: $1

Finding 539637 (2024-002)

Significant Deficiency 2024

Nbcc

CA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.430 § 200.431

iv. Management Response and Corrective Action Plan: Program staff allocate their time spent at work each day based on their client load and recurring weekly activities, e.g., case conferencing meetings. Staff must allocate their daily time and activity hours on their timesheets corresponding to the...

iv. Management Response and Corrective Action Plan: Program staff allocate their time spent at work each day based on their client load and recurring weekly activities, e.g., case conferencing meetings. Staff must allocate their daily time and activity hours on their timesheets corresponding to the project/s each client is enrolled in. Leave allocations should reflect each payroll period’s project time and activity actual percentages. Staff must manually record this information on complicated timesheets and consequently errors are made as not all staff are equally administratively adept. While there are multiple levels of review over timesheets, as the company has grown, it has become apparent that NBCC must integrate a more reliable method of always ensuring accurate allocation calculation of regular and leave hours. The expectation was that our new payroll solution provider, Paychex, was going to custom tailor a system that prevented such calculation errors, but this has not been the case thus far. Therefore, NBCC is actively once again researching payroll companies in an effort to find a solution better aligned with our timesheet needs. In the interim, management will work to edit our existing timesheet template to create a more user-friendly timesheet tool that auto-calculates where necessary and as appropriate so as to avoid misallocation. Management will also conduct additional timesheet trainings with staff as necessary. The end goal will be to secure a new payroll solution provider with system functionality that eliminates this kind of human error. v. Contact Person (s) Responsible for Corrective Action: Kristine Schwarz, Executive Director, kschwarz@sbnbcc.org Victoria Garfield, Grants Administration Director, vgarfield@sbnbcc.org Michael Dzierski, Finance Director, mdzierski@sbnbcc.org vi. Anticipated Completion Date: The anticipated completion date of the first step of editing our existing timesheet and retraining all staff as necessary is June 30, 2025. The anticipated completion date of the second step of having an integrated new payroll system with a new payroll solution provider will be dictated by the identification of a new vendor, and the subsequent development and implementation process of the new system, with an estimated completion date of December 31, 2025.

View Audit 350179

Finding 539632 (2024-002)

None 2024

Argus Manor Association

WA

HUD Housing Programs Subrecipient Monitoring Reporting

S3800-010: Finding Reference Number 2024-002 S3800-030: Statement of Condition: Our audit procedures revealed that the security deposit cash account was underfunded for nine (9) out of the twelve (12) months tested. Specifically, the required balance for security deposits was not fully met in...

S3800-010: Finding Reference Number 2024-002 S3800-030: Statement of Condition: Our audit procedures revealed that the security deposit cash account was underfunded for nine (9) out of the twelve (12) months tested. Specifically, the required balance for security deposits was not fully met in these months, resulting in a deficiency in the account. Although the funding deficit amounts were not always significant, it is important that the security deposit cash account be fully funded at all times. S3800-080: Auditor Recommendation: We recommend that property management implement a more robust process for monitoring and reconciling the security deposit cash account on a monthly basis. This process should ensure that the account balance is consistently maintained at the required level. Furthermore, management should conduct periodic reviews of the security deposit balances to identify and address any discrepancies promptly. Training for staff involved in managing security deposits should be considered to ensure compliance with HUD regulations and internal policies. FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT (Continued) S3800-010: Finding Reference Number 2024-002 (Continued) S3800-045: Actions Taken or to be Taken: It is management’s policy to fully fund the security deposit account so the balance in cash meets or exceeds the total liability of deposits collected from tenants. Management discussed the importance of reviewing funding monthly with the Project Accountant, and new procedures have been implemented to include a monthly process to compare the security deposit liability to the bank account and fund any shortages to ensure the security deposit bank account is consistently maintained at the required level.

View Audit 350177

Finding 539625 (2024-001)

Significant Deficiency 2024

Goldey-Beacom College, Inc.

DE

Student Financial Aid Reporting Significant Deficiency

The Registrar’s Office will incorporate the recommendations to fix the deficiency to create and deploy a more timely report to identify students who re-enroll at the College. It should be noted that since the College is implementing this change as early as March 2025, there may be a continuation of ...

The Registrar’s Office will incorporate the recommendations to fix the deficiency to create and deploy a more timely report to identify students who re-enroll at the College. It should be noted that since the College is implementing this change as early as March 2025, there may be a continuation of the deficiency from July 1, 2024 through March 31, 2025.

View Audit 350162

Finding 539602 (2024-002)

Significant Deficiency 2024

Bay County District School Board

FL

Questioned Costs Matching / Level of Effort / Earmarking § 200.303

Finding Number: 2024-002 Planned Corrective Action: The District had an unusually high volume of federal grants related to the CARES Act. There were expenditures planned for these funds; however, due to supply issues with both vendors and materials, other projects had to be substituted for the p...

Finding Number: 2024-002 Planned Corrective Action: The District had an unusually high volume of federal grants related to the CARES Act. There were expenditures planned for these funds; however, due to supply issues with both vendors and materials, other projects had to be substituted for the planned expenditures to meet timing requirements of the grant. It was during this process that the requirements related to the Davis Bacon Act were not followed. Moving forward, staff has gained experience and are more aware of the effects of moving expenditures for grant-related funds. Anticipated Completion Date: 3/31/2025 Responsible Contact Person: Jacqueline Webb

View Audit 350140 Questioned Costs: $1

Finding 539593 (2024-001)

Significant Deficiency 2024

Occidental College

CA

Student Financial Aid Special Tests & Provisions Reporting

Occidental College Corrective Action Plan Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Explanation of Deficiency: Occidental sent a degree file to the National Student Clearinghouse (NSC) on June 12, 2024. It was...

Occidental College Corrective Action Plan Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Explanation of Deficiency: Occidental sent a degree file to the National Student Clearinghouse (NSC) on June 12, 2024. It was a sent a week after an enrollment file. The enrollment file had errors which required resolution before the NSC could process the degree file. The enrollment file errors were remedied on June 25, 2024. The degree file also had errors posted on June 26, 2024, and corrected by Occidental on July 29, 2024. Correction Action Plan: The staff member currently responsible for resolving National Student Clearinghouse (NSC) file errors has now been trained in the institutional responsibility to send NSC files on time and to resolve any resulting errors immediately. In additional, the College will soon be hiring an administrative position (currently open) in the Registrar’s Office who will act as Occidental’s main liaison with the NSC. Plans for the new liaison training include both NSC processing as well as the relationship between NSC submissions and the institutional responsibility to report accurate enrollment to the National Student Loan Data System (NSLDS) as required. Training will be conducted by the Registrar with the assistance of the Director of Financial Aid for emphasis on institutional responsibilities as outlined in 34 CFR 685.3096(b). Contact Person Responsible for Corrective Action: James Herr, Occidental College Registrar Anticipated Completion Date: December 12, 2024 (end of Fall semester but before next degree file is sent to NSC)

View Audit 350130

Finding 539584 (2024-004)

Material Weakness 2024

West Mifflin Area School District

PA

Questioned Costs Special Tests & Provisions Matching / Level of Effort / Earmarking

FINDING 2024-004: US Department of Education and PA Department of Education - COVID-19 Education Stabilization Fund (ESF) - ALN #84.425 - Special Tests and Provisions - Wage Rate Requirements Criteria: In accordance with Uniform Guidance requirements found in Part 3 Section N, "Special Tests and Pro...

FINDING 2024-004: US Department of Education and PA Department of Education - COVID-19 Education Stabilization Fund (ESF) - ALN #84.425 - Special Tests and Provisions - Wage Rate Requirements Criteria: In accordance with Uniform Guidance requirements found in Part 3 Section N, "Special Tests and Provisions" of the Compliance Supplement, all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than the prevailing wages rates established by the Department of Labor (DOL). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance. Condition: The School District did not have adequate internal control procedures in place to ensure that all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds were paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor. As a result, the School District did not properly notify 1 of the 3 contractors tested of the requirements to comply with the wage rate requirements via the including of a prevailing wage rate clause in the contract between the contractor and the School District, and therefore, the use prevailing wage rates were not determined. Cause: The School District did not have formal procedures in place to ensure that prevailing wage rate requirements were met on all construction projects over $2,000. Effect: The School District was not in compliance with the Special Tests and Provisions - Wage Rate Requirements of the Uniform Guidance. Repeat Finding: No Questioned Costs: Unknown Recommendation: We recommend that the School District revise its purchasing policy to formally reflect the requirements of Special Tests and Provisions - Wage Rate Requirements. Additionally, we recommend that the School District establish procedures to ensure that prevailing wage rate requirements are met for federally funded construction projects over $2,000. Views of Responsible Officials and Planned Corrective Action: The School District agrees with the recommendation. The Business Office will require that projects over $2,000 involving federal must use prevailing wage rates.

View Audit 350127 Questioned Costs: $1

Finding 539553 (2024-001)

Significant Deficiency 2024

Sacred Heart University, Inc.

CT

Student Financial Aid Special Tests & Provisions Eligibility

Name ofcontactperson: Julie B. Savino, Associate Vice President of Student Financial Assistance Corrective action: The University remains committed to maintaining compliance with federal requirements and ensuring accurate Free Application for Federal Student Aid (FAFSA) verification. Staff will c...

Name ofcontactperson: Julie B. Savino, Associate Vice President of Student Financial Assistance Corrective action: The University remains committed to maintaining compliance with federal requirements and ensuring accurate Free Application for Federal Student Aid (FAFSA) verification. Staff will continue to receive verification training through internal and external means to ensure the accuracy ofthe verification requirements. To address the identified issues, the University will strengthen verification policies and procedures by adding controls to prevent data entry errors. As part ofthese improvements, a secondary review process will require a Director level staff member to evaluate any Institutional Student Information Record (ISIR) updates or changes before finalizing the Student Aid Index (SAI) (previously known as Estimated Family Contribution EFC). Proposed completion date: April 15, 2025

View Audit 350102

Finding 539550 (2024-004)

Material Weakness 2024

City of Alexandria

VA

Subrecipient Monitoring Material Weakness Reporting § 200.303

DCHS has reviewed its procedures and will ensure that suspension and debarement status is documented prior to contracting with a vendor.

View Audit 350101

Finding 539535 (2024-002)

None 2024

Economic and Community Development Institute, Inc.

OH

Reporting Period of Performance Matching / Level of Effort / Earmarking

Finding Number: 2024-002 Condition: Organization failed to submit the SF PPR report as of December 31, 2023 by January 30, 2024. Planned Corrective Action: ECDI has created a calendar for deadlines that has been shared between Development, Fiscal, and Program managers to ensure all deadlines are m...

Finding Number: 2024-002 Condition: Organization failed to submit the SF PPR report as of December 31, 2023 by January 30, 2024. Planned Corrective Action: ECDI has created a calendar for deadlines that has been shared between Development, Fiscal, and Program managers to ensure all deadlines are met. Multiple notifications are provided to these parties in advance of due dates. Contact Person Responsible for Corrective Action: Brian Barrett, Hudu Ahmed and Louisa Dallett Completion Date: March 1, 2025

View Audit 350075

Finding 539534 (2024-001)

None 2024

Economic and Community Development Institute, Inc.

OH

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.516

Finding Number: 2024-001 Condition: GBQ identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of ho...

Finding Number: 2024-001 Condition: GBQ identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of hours tracked to the program for a selected month. Another employee had an inappropriate wage rate applied to allocated time to the program. Last, two employees had compensation levels allocated to the program in excess of the Executive Level II Salary max amount in effect for the respective period. Planned Corrective Action: ECDI will put additional steps in place in Payroll Review process to ensure reconciliation of payroll charges to actual time records and rates. The organization will modify it's calculations to ensure that pay rates are reflective of the timeframe in question (not for periods before or after). ECDI will update its calculations to include thresholds for Executive pay so they are not entered in excess of approved rates. The company is also exploring technology enhancements so that information from ECDl's Payroll system flows directly into ECDl's Accounting system to limit the chance of errors during extraction from Payroll system and uploading into Accounting system. Contact Person Responsible for Corrective Action: Brian Barrett and Hudu Ahmed. Completion Date: In process

View Audit 350075 Questioned Costs: $1

Finding 539523 (2024-004)

Significant Deficiency 2024

Region III Workforce Investment Board of Kanawha County, Inc.

WV

Questioned Costs Eligibility Matching / Level of Effort / Earmarking § 200.303

2024-004 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Act...

2024-004 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth Activities participants. Action Taken: The Board has established policies and procedures to strengthen eligibility verification for the Youth program participants. These policies outline clear documentation requirements, verification steps, and staff responsibilities. Staff involved in eligibility determination have been trained on the new procedures to ensure consistency and compliance with federal and state guidelines and will receive ongoing training and technical assistance. The Board has implemented internal controls, including multi-level verification and supervisory review to ensure the accuracy and completeness of participant eligibility determinations.

View Audit 350052 Questioned Costs: $1

Finding 539509 (2024-002)

Significant Deficiency 2024

Region III Workforce Investment Board of Kanawha County, Inc.

WV

Questioned Costs Reporting Matching / Level of Effort / Earmarking § 200.303

2024-002 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: Region III will establish cle...

2024-002 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: Region III will establish clear documentation checklist with requirements for each report to ensure completeness and accuracy. Assign specific roles and responsibilities for report preparation, review and approval before submission to ensure that multiple levels of review are in place.

View Audit 350052 Questioned Costs: $1

Finding 539502 (2024-001)

Significant Deficiency 2024

Region III Workforce Investment Board of Kanawha County, Inc.

WV

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

2024-001 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action T...

2024-001 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Taken: Region III will create a detailed workflow of the approval process that includes the following: Initial request, review by finance department, and approval by designated individuals. Ensure that no single individual has control over all aspects of the charge approval process. We will schedule quarterly internal audits to review samples of transactions for compliance.

View Audit 350052 Questioned Costs: $1

Finding 539482 (2024-001)

Material Weakness 2024

Athens Housing Authority

GA

HUD Housing Programs Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Finding 2024-001 – Accounting Controls – Internal Controls over Financial Statement Preparation ALN 14.850 – Noncompliance and Material Weakness Corrective Action Plan: The Housing Authority is working with new personnel to ensure processes are documented and proper training is taking place. The...

Finding 2024-001 – Accounting Controls – Internal Controls over Financial Statement Preparation ALN 14.850 – Noncompliance and Material Weakness Corrective Action Plan: The Housing Authority is working with new personnel to ensure processes are documented and proper training is taking place. The Housing Authority has contracted with BDO to assist with year-end processes and training. Person Responsible: Sheila Crisp, Executive Director Anticipated Completion Date: June 2025

View Audit 350010

Finding 539480 (2024-010)

Significant Deficiency 2024

Urshan College

MO

Cash Management Reporting Significant Deficiency § 200.303

Cash Management – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit...

Cash Management – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Director will ensure that when processes are completed, they are verifiable through documentation. Credit Balance refunds as well as drawdowns will be tracked for proper compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

View Audit 350009

Finding 539478 (2024-009)

Significant Deficiency 2024

Urshan College

MO

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

Special Tests and Provisions Direct Loan Reconciliation – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding:...

Special Tests and Provisions Direct Loan Reconciliation – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid director will institute a documented review of the Direct Loan reconciliations prepared by Campus Ivy or future third-party processors. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

View Audit 350009

Finding 539476 (2024-008)

Significant Deficiency 2024

Urshan College

MO

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

Special Tests and Provisions 240 Day Checks – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no...

Special Tests and Provisions 240 Day Checks – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office along with Student Accounts and the Business Office at Urshan University will collaborate on an SOP which will establish a process of reviewing any outstanding Title IV checks. Checks will be reissued as necessary to ensure the university stays compliant with all Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025

View Audit 350009

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