Corrective Action Plans

Finding 1169500 (2025-002)

Material Weakness 2025

IA

School Nutrition Programs Questioned Costs Allowable Costs / Cost Principles

Response and Corrective Action Plan: The District will annually prepare the indirect cost charged to the program based on the actual fiscal year trial balance and the federal government MTDC requirements. The calculation process will implement a procedure to consider other adjustments necessary to b...

Response and Corrective Action Plan: The District will annually prepare the indirect cost charged to the program based on the actual fiscal year trial balance and the federal government MTDC requirements. The calculation process will implement a procedure to consider other adjustments necessary to be in compliance. The District will provide an estimate to the Board each June to ensure proper approval of fund transfers.

View Audit 382422

Finding 1169433 (2025-001)

Material Weakness 2025

Los Angeles Christian Health Centers and Subsidiary

CO

Questioned Costs HUD Housing Programs Significant Deficiency

Sliding Scale Assessment Billing Planned Corrective Action: Clinic management will implement additional checks and balances to ensure that Sliding Fee Application Forms and written income verification documentation are included in patients’ records and agree to the sliding fee level maintained in th...

Sliding Scale Assessment Billing Planned Corrective Action: Clinic management will implement additional checks and balances to ensure that Sliding Fee Application Forms and written income verification documentation are included in patients’ records and agree to the sliding fee level maintained in the electronic health records system. The Revenue Cycle Manager will increase the level of monitoring of required documentation of sliding fee levels used in billing patient charges. Person Responsible for Corrective Action Plan: Steonée Laskey, Chief Operations Officer Anticipated Date of Completion: January 31, 2026

View Audit 382377

Finding 1169430 (2025-002)

Material Weakness 2025

University of the Cumberlands, Inc.

KY

Questioned Costs Student Financial Aid Reporting

2025-002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education - Federal Work Study Program, ALN #84.033) The University noted that multiple students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to b...

2025-002 Significant Deficiency: Working During Scheduled Class Time (U.S. Department of Education - Federal Work Study Program, ALN #84.033) The University noted that multiple students appear to have been paid for Federal Work Study hours logged and submitted for time the student was scheduled to be in class without verification of a reasonable exemption. Management Response Management concurs with the auditor’s finding. Due to incomplete documentation of reasonable exemptions, students were paid Federal Work Study funds for time worked during regularly scheduled class meeting times. Responsible Person(s) Alex Campbell, Director of Financial Aid, and Bobbi Farris, Manager for Student Employment, are the responsible parties for the corrective action. Corrective Action Plan Upon identifying deficiencies related to the lack of documentation for allowable exemptions, the University immediately communicated with all Student Employment Supervisors regarding permitted exemptions and required documentation for students to work during scheduled class times. These requirements and exemptions are reviewed and agreed upon during the annual Student Employment Supervisor Trainings, which occur prior to job postings. Students are notified of the documentation required to be exempt and eligible to work during a scheduled class time during the onboarding process. In collaboration with Information Technology and third-party consultants, the Student Employment Office is enhancing reporting functions to ensure accurate identification of students with conflicting work and class times and to flag any conflicting entries for review and resolution prior to approval. These reports will be reviewed each pay period to ensure accurate documentation is obtained for any conflicting times flagged. While these fields are being implemented, regulations related to working during scheduled class times have been reinforced with both students and supervisors. Beginning with the Spring 2026 term, the University will implement a new policy prohibiting students participating in the Federal Work Study Program from working during scheduled class times, regardless of any met exemptions. All Student Employment Supervisors will be notified of this updated policy by the end of the Fall 2025 term. Training will continue on an annual basis to ensure proper procedures are followed by Student Employment Supervisors and students participating in the Federal Work Study Program. The Director of Financial Aid and Manager for Student Employment will review student time records each pay period to ensure full compliance with these policies. Expected Completion Date This corrective action plan was implemented in September 2025, during the Fall 2025 term. Final implementation will occur at the start of the Spring 2026 term.

View Audit 382359

Finding 1169429 (2025-001)

Material Weakness 2025

University of the Cumberlands, Inc.

KY

Student Financial Aid Questioned Costs Eligibility

2025-001 Significant Deficiency: Awards in Excess of Aggregate Limits (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University awarded and disbursed Federal Direct Loans beyond aggregate limits. Management Response Management concurs with the auditors’ finding....

2025-001 Significant Deficiency: Awards in Excess of Aggregate Limits (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University awarded and disbursed Federal Direct Loans beyond aggregate limits. Management Response Management concurs with the auditors’ finding. Due to delays and changes in the National Student Loan Data System (NSLDS) post-screening process for the 2024–25 award year, Federal Direct Loans were inadvertently awarded and disbursed to students who had previously exceeded Federal Direct Loan aggregate limits. Responsible Person(s) Alex Campbell, Director of Financial Aid, and Kaitrin Parrett, Assistant Director of Financial Aid, are designated as the individuals responsible for implementing the corrective action. Corrective Action Plan Upon identifying deficiencies in loan aggregate reporting and over-award status, the Financial Aid Office initiated communication with the identified students to inform them of their overaward status and the process for resolving inadvertent overborrowing. In collaboration with software engineers, the Financial Aid Office is developing updated reporting to ensure proper identification of students who are ineligible due to meeting or exceeding aggregate limits set by the U.S. Department of Education. The Financial Aid Office tested and reviewed NSLDS post-screen data and student loan aggregates prior to the disbursement of Fall 2025 Federal Direct Loans to ensure students were not awarded or disbursed aid for which they were ineligible. Reviews of NSLDS post-screen data confirm that the Student Information System (SIS) accurately identifies student aggregate borrowing flags. The Financial Aid Office is also monitoring designated mailboxes to ensure any additional NSLDS post-screen data is reviewed and aggregate limits on student accounts are updated accordingly. All financial aid staff involved in awarding federal loans completed additional training on NSLDS review requirements, aggregate limit monitoring, and reaffirmation procedures prior to Fall 2025 disbursements. Training will continue on a quarterly basis to ensure proper procedures are followed by Financial Aid staff. Compliance reviews will be conducted on a semester basis to ensure that Title IV aid is not awarded to students in excess of their annual or aggregate limits. The Director and Assistant Director of Financial Aid will review aggregate limit reports monthly as part of the University’s internal operational calendar. Expected Completion Date This corrective action plan was implemented in September 2025, prior to Fall 2025 aid disbursements, which began on September 12, 2025.

View Audit 382359

Finding 1169412 (2025-003)

Material Weakness 2025

Life University, Inc.

GA

Special Tests & Provisions Questioned Costs Student Financial Aid

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 1169370 (2025-001)

Material Weakness 2025

Community College District of Newton and McDonald Counties, Missouri

MO

Student Financial Aid Questioned Costs Reporting

Corrective Action Plan December 19, 2025 U.S. DEPARTMENT OF EDUCATION Crowder College respectfully submits the following corrective action plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Mr. Joseph Brenner, Vice President of Financ...

Corrective Action Plan December 19, 2025 U.S. DEPARTMENT OF EDUCATION Crowder College respectfully submits the following corrective action plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Mr. Joseph Brenner, Vice President of Finance Crowder College 601 Laclede Avenue Neosho, MO 64850 (417) 451-3223 Independent public accounting firm: KPM CPAs, PC, 1445 E Republic Rd, Springfield, Missouri 65804 Audit Period: Year Ended June 30, 2025 The finding from the June 30, 2025, audit of the financial statements is below. The findings is numbered with the number assigned in the schedule. FINDING - MAJOR FEDERAL AWARD PROGRAM AUDIT 2025-001 Special Test and Provisions - Return of Title IV Funds Recommendation: We recommend the College implement procedures to strictly comply with the requirements of 34 CFR §668.22 as it relates to calculations of return of Title IV funds. Corrective Action Taken: The College reviewed all accounts affected by this error and identified 15 students whose accounts required adjustments. Upon review, the financial aid representative determined that excess funds were returned when the R2T4 calculations were completed. Financial Aid has since corrected the accounts and requested the additional funds owed. To prevent this issue from recurring, a representative from the Financial Aid Office will be included on the calendar committee. Additionally, Financial Aid Policies and Procedures have been updated to require calendar changes to be promptly updated in PowerFaids to ensure accuracy. Anticipated Completion Date: Fall semester 2025 and ongoing. Sincerely, Joseph Brenner Vice President of Finance

View Audit 382304

Finding 1169350 (2025-001)

Material Weakness 2025

Wayland Baptist University

TX

Questioned Costs Student Financial Aid Material Weakness

Lack of Administrative Capability Planned Corrective Action: The Office of Financial Aid and Wayland Baptist University agree with this finding. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. This system w...

Lack of Administrative Capability Planned Corrective Action: The Office of Financial Aid and Wayland Baptist University agree with this finding. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. This system will replace the current platform and is intended to improve automation, reporting accuracy, workflow tracking, and overall compliance with federal and state financial aid requirements. In addition, the Office of Financial Aid is actively reevaluating workload distribution and staff assignments to ensure responsibilities are appropriately aligned with compliance-critical functions. The University is also increasing staffing levels within the Office of Financial Aid to strengthen oversight, reduce processing risk, and ensure timely and accurate completion of compliance and reporting obligations. Collectively, these actions are designed to enhance administrative capacity, strengthen internal controls, and mitigate the risk of future compliance deficiencies. 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 1169348 (2025-006)

Material Weakness 2025

Wayland Baptist University

TX

Questioned Costs Eligibility Significant Deficiency

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 1169347 (2025-005)

Material Weakness 2025

Wayland Baptist University

TX

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Incorrect Pell Calculations Planned Corrective Action: The Office of Financial Aid will obtain enrollment reports for each term and session to ensure that Pell Grant eligibility is accurately determined and awarded to students based on their enrollment intensity. To address the system limitations id...

Incorrect Pell Calculations Planned Corrective Action: The Office of Financial Aid will obtain enrollment reports for each term and session to ensure that Pell Grant eligibility is accurately determined and awarded to students based on their enrollment intensity. 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 1169346 (2025-003)

Material Weakness 2025

Wayland Baptist University

TX

Questioned Costs Student Financial Aid Material Weakness

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will provide regular in-house R2T4 training specific to WBU for all financial aid staff. All financial aid staff responsible...

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will provide regular in-house R2T4 training specific to WBU for all financial aid staff. All financial aid staff responsible for R2T4 will be required to complete pertinent training provided by FSA and purchased through NASFAA. In addition, financial aid staff responsible for R2T4 have established procedures to ensure the accurate and timely Return of Title IV Funds. 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 1169342 (2025-004)

Material Weakness 2025

Wayland Baptist University

TX

Questioned Costs 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 Questioned Costs 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 Questioned Costs 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 1169303 (2025-001)

Material Weakness 2025

Community Health Center of Central Missouri

MO

Questioned Costs Subrecipient Monitoring Reporting § 200.329

Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No. 21.027 U.S. Department of Treasury Missouri Primary Care Association Criteria or specific requirement – Reporting (2 CFR 200.329) Condition – The Organization’s internal controls over compliance were not able to ensure progress...

Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No. 21.027 U.S. Department of Treasury Missouri Primary Care Association Criteria or specific requirement – Reporting (2 CFR 200.329) Condition – The Organization’s internal controls over compliance were not able to ensure progress reporting required to be submitted to the pass-through entity was completed timely. Cause – The Organization’s internal controls over compliance did not ensure all grant reporting requirements were completed timely. Effect or potential effect – The Organization did not submit the required quarterly and annual performance reports in a timely manner. Questioned costs – None Context – The Organization is required to submit quarterly status reports and an annual performance report to the pass-through entity in a timely manner. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consider implementing a grant reporting calendar for all grants with reporting requirements. Views of responsible officials and planned corrective actions – In order for this finding not to occur in the future, the Chief Financial Officer will • Create a Grant calendar to track report due dates • Hold quarterly meetings with managers to ensure we have all reports submitted timely in the future Contact person responsible for corrective action – Toby Barnett, Chief Financial Officer Anticipated completion date – December 2025

View Audit 382245

Finding 1169297 (2025-001)

Material Weakness 2025

University of Oklahoma Health Sciences Center

OK

Internal Control / Segregation of Duties Questioned Costs Special Tests & Provisions

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 1169290 (2025-001)

Material Weakness 2025

Monterey Peninsula Community College District

CA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Views of Responsible Officials and Corrective Action Plan Each Return of Title IV calculation will be supported by verifiable supporting reports or information demonstrating the number of calendar days used in the calculation. During the annual New Year Roll, all date fields will be manually reviewe...

Views of Responsible Officials and Corrective Action Plan Each Return of Title IV calculation will be supported by verifiable supporting reports or information demonstrating the number of calendar days used in the calculation. During the annual New Year Roll, all date fields will be manually reviewed to ensure default system values are appropriate and consistent with the academic calendar. This information will be reviewed by supervisory personnel independent of the staff member preparing the dates and calculations.

View Audit 382233

Finding 1169285 (2025-001)

Material Weakness 2025

Southwestern Community College District

CA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Management's Reponse: We concur. View of Responsible Offiicals and Corrective Action Plan The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehens...

Management's Reponse: We concur. View of Responsible Offiicals and Corrective Action Plan The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehensive review to assess processes, staffing, and systems to ensure ongoing compliance and improvement. Implementation Date: September 2025

View Audit 382230

Finding 1169279 (2025-004)

Material Weakness 2025

Lewis & Clark Community College District 536

IL

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

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

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

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 1169277 (2025-002)

Material Weakness 2025

Lewis & Clark Community College District 536

IL

Questioned Costs HUD Housing Programs Special Tests & Provisions

Management will remind financial aid administrators of their responsibility to maintain internal controls and sign off on all quality assurance measures. Continued reinforcement of these standards will occur during regular department meetings. Person(s) Responsible: Angela Weaver Timing for Implemen...

Management will remind financial aid administrators of their responsibility to maintain internal controls and sign off on all quality assurance measures. Continued reinforcement of these standards will occur during regular department meetings. Person(s) Responsible: Angela Weaver Timing for Implementation: November 21, 2025

View Audit 382227

Finding 1169276 (2025-001)

Material Weakness 2025

Lewis & Clark Community College District 536

IL

Questioned Costs Internal Control / Segregation of Duties Special Tests & Provisions

Although Financial Aid Administrators pride themselves on their attention to federal guidelines and the administration of student aid, errors can occur. To reinforce our shared commitment, management has expanded quality assurance reviews and incorporated additional training into regular staff meeti...

Although Financial Aid Administrators pride themselves on their attention to federal guidelines and the administration of student aid, errors can occur. To reinforce our shared commitment, management has expanded quality assurance reviews and incorporated additional training into regular staff meetings. As a result of a verification compliance review, a misread number resulted in a higher Student Aid Index (SAI). A student received Direct Subsidized Loan funds in excess of financial need. Since the student is no longer enrolled during the loan period, according to federal aid guidelines, the institution is not required to take any action to eliminate the excess subsidized loan amount. In contrast if, due to an error, a student borrower who was eligible for a Direct Subsidized Loan instead received a Direct Unsubsidized Loan, the institution would have to correct the error, even if the loan period had ended, by submitting a downward adjustment to reduce or eliminate the Direct Unsubsidized Loan, as appropriate, and replacing it with the same amount of Direct Subsidized Loan funds. Person(s) Responsible: Angela Weaver Timing for Implementation: November 21, 2025

View Audit 382227

Finding 1169244 (2025-001)

Material Weakness 2025

Lone Star College System

TX

Questioned Costs Allowable Costs / Cost Principles Material Weakness

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 Questioned Costs 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 1169208 (2025-002)

Material Weakness 2025

Betty Jean Kerr - People's Health Centers

MO

Internal Control / Segregation of Duties Questioned Costs Special Tests & Provisions

Section III Federal Award Findings and Questioned Costs Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care),) Grants for New and Expanded Services Under the Health Center Program, COVID-19 Grants for New and Expanded...

Section III Federal Award Findings and Questioned Costs Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care),) Grants for New and Expanded Services Under the Health Center Program, COVID-19 Grants for New and Expanded Services Under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Item 2025 002 Special Tests Recommendation The Center should establish a system of internal controls to ensure that all slide fee discounts are properly calculated based on family size and income. Repeat Finding Yes Action Taken The Finance Department will take the following steps to enhance the slide fee discounts process: 1. Policy Revision: the health center will revise its Sliding Fee Discount Policy to ensure alignment with HRSA requirements, including accurate discount calculation methodologies, annual updates to the sliding fee scale, and proper utilization of NextGen system functionality to support implementation 2. Staff Training: the health center will provide comprehensive training to all relevant staff on the revised Sliding Fee Discount Policy and procedures. 3. Training will emphasize correct discount calculations, required documentation, and income verification processes. A recurring training program will be implemented to ensure ongoing compliance for both new hires and existing employees. 3. Retrospective Review: the health center will conduct a retrospective review of patient files for the current fiscal year to confirm that all sliding fee discounts are appropriately supported by required documentation. Any identified discrepancies will be corrected in a timely manner. 4. Ongoing Monitoring: the health center will establish monthly internal audits of sliding fee discount determinations to monitor compliance. Audit results will be documented and reviewed by management to ensure corrective actions are taken as needed. Responsible Party: Chief Financial Officer Target Completion Date: 04/30/2026 If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Javier Vallejo, CFO at (314)-482-0915. Sincerely yours, Javier Vallejo Chief Financial Officer

View Audit 382078

Finding 1169177 (2025-001)

Material Weakness 2025

City of Chattanooga, Tennessee

TN

Questioned Costs Significant Deficiency Matching / Level of Effort / Earmarking

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

Corrective Action Plans

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