Corrective Action Plans

Finding 1204917 (2025-001)

Material Weakness 2025

City of Madera

CA

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Finding 2025-001 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency) Criteria: Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet cri...

Finding 2025-001 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency) Criteria: Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared. Condition and Context: The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements. The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample. City’s Corrective Action Plan: The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project. Corrective Action Plan (Continued) Contact person responsible for corrective action: Michael Lima, Finance Director Anticipated completion date: June 30, 2026

View Audit 396513

Finding 1204912 (2025-002)

Material Weakness 2025

Kildahl Park Pointe Cooperative

MN

Questioned Costs Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperativ...

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 396512

Finding 1204907 (2025-001)

Material Weakness 2025

Town of Westport, Massachusetts

MA

Questioned Costs Subrecipient Monitoring Reporting § 200.1

Finding 2025-001 Condition: Expenditures were not reconciled to the general ledger for reporting submitted to the U.S. Department of the Treasury and Bristol County, Massachusetts. Corrective Action Planned: To ensure the accuracy of ARPA reporting, and all Federal Grants, a reconciliation process w...

Finding 2025-001 Condition: Expenditures were not reconciled to the general ledger for reporting submitted to the U.S. Department of the Treasury and Bristol County, Massachusetts. Corrective Action Planned: To ensure the accuracy of ARPA reporting, and all Federal Grants, a reconciliation process will be implemented and followed by all involved. Anticipated Completion Date: April 30, 2026 Contact: Nicole Pearsall, Town Accountant

View Audit 396509

Finding 1204904 (2025-008)

Material Weakness 2025

County of Ventura

CA

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

Program: COVID-19 - Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listing No.: 93.323 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award No.: COVID-19ELC114 Award Year: 2021 Compliance Requirements...

Program: COVID-19 - Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listing No.: 93.323 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award No.: COVID-19ELC114 Award Year: 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Department’s Management Response: VCPH Management agrees with the recommendation for the Department to strengthen its policies and procedures to ensure all required reports are reviewed, approved and retained as evidence in the applicable grant folder. View of Responsible Officials and Corrective Action: VCPH Management will implement a requirement that all applicable reports must include documented review and approval (e.g. email approval, signed cover sheet, or workflow confirmation) before submission and retention of such approval evidence in the applicable grant folder location. Name of Responsible Persons: Maria Macias, Manager, VCPH Rigoberto Vargas, Director, VCPH Implementation Date: April 2026

View Audit 396507

Finding 1204900 (2025-005)

Material Weakness 2025

County of Ventura

CA

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

Program: Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii Assistance Listing No.: 14.228 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Pass-Through California Department of Housing and Community Development Award No.: 17-MITP...

Program: Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii Assistance Listing No.: 14.228 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Pass-Through California Department of Housing and Community Development Award No.: 17-MITPPS-21029, 18-DRWD-23003, 21-CDBG-HK-0010 Award Year: 2022, 2024 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Department’s Management Response: Management agrees with the recommendation to revise its procedures to include evidence documenting the individual who reviewed and approved required reports prior to submission. View of Responsible Officials and Corrective Action: a. With regards to the CDBG-CV2 and CDBG-MIT reports managed by the County Executive Office Community Development Division, procedures were revised beginning in April 2025 due to prior year findings 2024-007 and 2024-008 to incorporate documented review and approval requirements for all applicable federally required reports. These enhanced internal controls are being phased in across all relevant reporting processes, with full implementation completed by the end of June 2025. These changes are intended to ensure that evidence of review and approval is consistently retained and that reporting is accurate, complete, and compliant with federal requirements. The reports identified in the finding were completed prior to the stated corrective action. b. With regards to the VC Heal Activity reports managed by Ventura County Workforce Development (VCWD) management, the required reports were prepared by the subrecipient (Career TEAM) using the standardized HCD format and underwent multiple levels of review, the County acknowledges that documentation of the specific individual review and approval prior to submission was not consistently retained. To strengthen internal controls to ensure all required reports include documented evidence of review and approval prior to submission, VCWD management will: • Implement a standardized review and approval protocol requiring documented sign‑off by designated VCWD management prior to submission. • Require Career TEAM to use a formal certification or routing process identifying the preparer and reviewer. • Maintain centralized documentation identifying the report preparer, reviewer/approver, and date of review. • Incorporate these requirements into internal procedures and contractor guidance. • Conduct periodic internal monitoring to verify compliance. Name of Responsible Persons: a. Kimberlee Albers, Deputy Executive Officer b. VCWD staff responsible for the CDBG program Career TEAM (Subrecipient – Report Preparation) Implementation Date: a. April – June 2025 b. April 2026

View Audit 396507

Finding 1204890 (2025-003)

Material Weakness 2025

County of Ventura

CA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Finding 2025-003 Program: CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Direct Award and Pass-Through City of San Buenaventura Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-05...

Finding 2025-003 Program: CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Direct Award and Pass-Through City of San Buenaventura Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, B-24-UC-06-0507, 95-6000807 Award Year: 2024 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Department’s Management Response: The County Executive Office Community Development Division agrees with the recommendation to revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission. View of Responsible Officials and Corrective Action: Procedures were revised beginning in April 2025 due to prior year findings 2024-007 and 2024-008 to incorporate documented review and approval requirements for all applicable federally required reports. These enhanced internal controls are being phased in across all relevant reporting processes, with full implementation completed by the end of June 2025. These changes are intended to ensure that evidence of review and approval is consistently retained and that reporting is accurate, complete, and compliant with federal requirements. The reports identified in the finding were completed prior to the stated corrective action. Name of Responsible Persons: Kimberlee Albers, Deputy Executive Officer Implementation Date: April – June 2025

View Audit 396507

Finding 1204867 (2025-003)

Material Weakness 2025

Ohio Christian University

OH

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

Need Analysis Planned Corrective Action: The institution is moving to automated loan packaging by the Power FAIDS financial aid management system, which packages the loan based on grade level and remaining unmet financial need. Therefore, if a student’s remaining need is less than the available subs...

Need Analysis Planned Corrective Action: The institution is moving to automated loan packaging by the Power FAIDS financial aid management system, which packages the loan based on grade level and remaining unmet financial need. Therefore, if a student’s remaining need is less than the available subsidized eligibility, the system will only package up to the remaining need. Furthermore, as a second quality assurance check, a rule has been written in the PowerFAIDS financial aid management system that will flag any student that has been awarded sub over need. Person Responsible for Corrective Action Plan: Justin Pichey, Director of Financial Aid Anticipated Date of Completion: This has already been implemented for fiscal year 2026-2027.

View Audit 396488

Finding 1204864 (2025-004)

Material Weakness 2025

Gila Crossing Community School

AZ

Allowable Costs / Cost Principles Questioned Costs Procurement, Suspension & Debarment

Finding Number: 2025‐004 Program Name/Assistance Listing Title: Indian School Equalization Program, Special Education Cluster (IDEA) Assistance Listing Number: 84.425, 84.027 Contact Person: Holena Lebron, Superintendent Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The Schoo...

Finding Number: 2025‐004 Program Name/Assistance Listing Title: Indian School Equalization Program, Special Education Cluster (IDEA) Assistance Listing Number: 84.425, 84.027 Contact Person: Holena Lebron, Superintendent Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The School lacked adequate internal controls over disbursements, journal entries, and payroll. - Efforts to maintain proper supporting documentation for various transactions must improve.Staff training to highlight the importance of following procedures and maintaining supporting documentation for all transactions has already occurred and will be held multiple times in the future. - Two current employees have unusual employment status that makes recalculating their pay difficult; they are part‐time, but on salary.

View Audit 396487

Finding 1204856 (2025-001)

Material Weakness 2025

Gila Crossing Community School

AZ

Special Tests & Provisions Questioned Costs Significant Deficiency

Finding Numbers: 2025‐001, 2024‐001, 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Holena Lebron, Superintendent Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The School did not complete character ...

Finding Numbers: 2025‐001, 2024‐001, 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Holena Lebron, Superintendent Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The School did not complete character reinvestigations timely for all employees. - An internal review identified that employee suitability determinations and five‐year reinvestigations were not consistently tracked. - To address this, the administration will review all personnel files to identify employees who are due or overdue for reinvestigation. Any overdue determinations will be completed immediately. A tracking system will be implemented to monitor the five‐year requirement and ensure reinvestigations are completed on time moving forward. Periodic file reviews will also be conducted to maintain compliance.

View Audit 396487

Finding 1204849 (2025-002)

Material Weakness 2025

Nami Chicago

IL

Questioned Costs Eligibility Procurement, Suspension & Debarment § 200.318

NAMI Chicago acknowledges the finding and has revised the finance policy as of January 1, 2026 to clearly define micro-purchase thresholds and procedures for micropurchases, simplified acquisition thresholds and procedures for simplified acquisitions, formal procurement methods for use when transact...

NAMI Chicago acknowledges the finding and has revised the finance policy as of January 1, 2026 to clearly define micro-purchase thresholds and procedures for micropurchases, simplified acquisition thresholds and procedures for simplified acquisitions, formal procurement methods for use when transactions exceed acquisition threshold and noncompetitive procurement methods. Management will monitor procurement activity for compliance with the updated policy.

View Audit 396483

Finding 1204848 (2025-001)

Material Weakness 2025

Nami Chicago

IL

Allowable Costs / Cost Principles Questioned Costs § 200.303

NAMI Chicago acknowledges the finding regarding documentation of approvals for expenses charged to federal awards. The exceptions identified occurred during the first half of the fiscal year, prior to the January 1, 2025, implementation of our enhanced Internal Control and Disbursement Policy develo...

NAMI Chicago acknowledges the finding regarding documentation of approvals for expenses charged to federal awards. The exceptions identified occurred during the first half of the fiscal year, prior to the January 1, 2025, implementation of our enhanced Internal Control and Disbursement Policy developed in direct response to the FY24 audit recommendations, which were finalized and communicated in early 2025. Since January 1, 2025, NAMI Chicago has successfully implemented a mandatory digital approval workflow for all grant-funded expenditures to ensure contemporaneous documentation. Management is confident that these strengthened protocols, which were fully operational for the latter half of FY2025 and continue to date, have resolved the underlying issue. We expect no further instances of this finding in future audit cycles.

View Audit 396483

Finding 1204843 (2025-006)

Material Weakness 2025

Stevenson University, Inc.

MD

Internal Control / Segregation of Duties Questioned Costs Period of Performance

FINDING 2025-006 Name of Responsible Individual: Brandon Rhone, Systems Administrator Corrective Action: To resolve the finding of loan period academic end dates being inaccurately reported, we now utilize system forms that allow us to identify and batch-correct any student record with incorrect dat...

FINDING 2025-006 Name of Responsible Individual: Brandon Rhone, Systems Administrator Corrective Action: To resolve the finding of loan period academic end dates being inaccurately reported, we now utilize system forms that allow us to identify and batch-correct any student record with incorrect dates. This process enhances data accuracy, ensures proper reporting, prevents COD rejects and reduces the risk of future compliance issues. Anticipated Completion Date: Already completed

View Audit 396468

Finding 1204842 (2025-005)

Material Weakness 2025

Stevenson University, Inc.

MD

Student Financial Aid Internal Control / Segregation of Duties Questioned Costs

FINDING 2025-005 Name of Responsible Individual: Chad Wick, Director of Financial Aid Corrective Action: We have implemented a new Quality Assurance Measure for Auditing all students with a C-Flag. The process begins with the FA advisor team. They are responsible for ensuring all documents have been...

FINDING 2025-005 Name of Responsible Individual: Chad Wick, Director of Financial Aid Corrective Action: We have implemented a new Quality Assurance Measure for Auditing all students with a C-Flag. The process begins with the FA advisor team. They are responsible for ensuring all documents have been received and all steps have been completed to clear the C-Flag. In Colleague the advisor will then mark the file is ready for audit. Chad Wick, Director, Financial aid or Brandon Rhone, Systems Administrator, will review all documents and steps needed to clear C-Flag and then update the communication code to audited and make any adjustments if needed to the FAFSA. Anticipated Completion Date: Already completed

View Audit 396468

Finding 1204838 (2025-004)

Material Weakness 2025

Stevenson University, Inc.

MD

Student Financial Aid Questioned Costs Special Tests & Provisions

FINDING 2025-004 Name of Responsible Individual: Chad Wick, Director of Financial Aid, and Brandon Rhone, Systems Administrator Corrective Action: We will implement a second check process after R2T4 has been calculated to ensure the correct dates are being used. Chad Wick, Director, Financial Aid wi...

FINDING 2025-004 Name of Responsible Individual: Chad Wick, Director of Financial Aid, and Brandon Rhone, Systems Administrator Corrective Action: We will implement a second check process after R2T4 has been calculated to ensure the correct dates are being used. Chad Wick, Director, Financial Aid will conduct the initial calculating of R2T4 on a weekly basis. Brandon Rhone, Systems Administrator, will review all calculations prior to processing them in Colleague. Anticipated Completion Date: March 31, 2026

View Audit 396468

Finding 1204835 (2025-003)

Material Weakness 2025

Stevenson University, Inc.

MD

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid

FINDING 2025-003 Name of Responsible Individual: Brandon Rhone, Systems Administrator Corrective Action: We implemented a process which assigns communications management codes based on transmittal activity of each federal direct loan. On the same day a loan is disbursed, our system applies the appro...

FINDING 2025-003 Name of Responsible Individual: Brandon Rhone, Systems Administrator Corrective Action: We implemented a process which assigns communications management codes based on transmittal activity of each federal direct loan. On the same day a loan is disbursed, our system applies the appropriate code to the student record. These codes are then automatically selected for the correct loan disbursement notification to be sent either to the student or parent based on the federal loan type. Anticipated Completion Date: Already completed

View Audit 396468

Finding 1204834 (2025-002)

Material Weakness 2025

Stevenson University, Inc.

MD

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid

FINDING 2025-002 Name of Responsible Individual: Chad Wick, Director of Financial Aid Corrective Action: We have implemented a new Quality Assurance Measure for Auditing all students selected for verification. The process begins with the FA advisor team. They are responsible for ensuring all documen...

FINDING 2025-002 Name of Responsible Individual: Chad Wick, Director of Financial Aid Corrective Action: We have implemented a new Quality Assurance Measure for Auditing all students selected for verification. The process begins with the FA advisor team. They are responsible for ensuring all documents have been received and verification has been completed. In Colleague the advisor will then mark the file is ready for audit. Chad Wick, Director, Financial aid or Brandon Rhone, Systems Administrator, will review all documents and verification steps and then update the verification status to verified and the communication code to audited. Anticipated Completion Date: Already completed

View Audit 396468

Finding 1204823 (2025-001)

Material Weakness 2025

T.p. White Complex, Inc. Dba Traskwood Complex

AR

HUD Housing Programs Internal Control / Segregation of Duties Questioned Costs

Name: T.P. White Complex, Inc., d/b/a Traskwood Complex, Inc. Contact: Patricia Walker, Chief Financial Officer Contact Phone Number: 501-982-0528 Audit Period Ending: June 30, 2025 Anticipated Completion Date: May 31, 2026 Finding 2025-001: Upon renewal of its Project Rental Assistance Contract (PR...

Name: T.P. White Complex, Inc., d/b/a Traskwood Complex, Inc. Contact: Patricia Walker, Chief Financial Officer Contact Phone Number: 501-982-0528 Audit Period Ending: June 30, 2025 Anticipated Completion Date: May 31, 2026 Finding 2025-001: Upon renewal of its Project Rental Assistance Contract (PRAC) on November 30, 2024, the Project did not remit residual receipts in excess of $250 per unit to HUD as required by HUD guidance. Management’s Response and Planned Corrective Actions: Subsequent to year end, management engaged in discussions with HUD and intends to identify eligible Project needs and submit a HUD 9250 request to use the excess residual receipts in accordance with HUD Handbook 4350.1, Chapter 25, Section 25 9. Approval of such a request is at HUD’s discretion.

View Audit 396463

Finding 1204822 (2025-001)

Material Weakness 2025

Mulberry Place, INC

AR

HUD Housing Programs Internal Control / Segregation of Duties Questioned Costs

Name: Mulberry Place, Inc. Contact: Patricia Walker, Chief Financial Officer Contact Phone Number: 501-982-0528 Audit Period Ending: June 30, 2025 Anticipated Completion Date: May 31, 2026 Finding 2025-001: Upon renewal of its Project Rental Assistance Contract (PRAC) on July 31, 2024, the Project d...

Name: Mulberry Place, Inc. Contact: Patricia Walker, Chief Financial Officer Contact Phone Number: 501-982-0528 Audit Period Ending: June 30, 2025 Anticipated Completion Date: May 31, 2026 Finding 2025-001: Upon renewal of its Project Rental Assistance Contract (PRAC) on July 31, 2024, the Project did not remit residual receipts in excess of $250 per unit to HUD as required by HUD guidance. Management’s Response and Planned Corrective Actions: Subsequent to year end, management engaged in discussions with HUD and intends to identify eligible Project needs and submit a HUD 9250 request to use the excess residual receipts in accordance with HUD Handbook 4350.1, Chapter 25, Section 25 9. Approval of such a request is at HUD’s discretion.

View Audit 396459

Finding 1204821 (2025-009)

Material Weakness 2025

Urshan College

MO

Questioned Costs Eligibility Reporting § 200.303

2025-009 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation ...

2025-009 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University 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 University reviewed its awarding and reconciliation processes following the identified discrepancy between COD and the institutional ledger, which resulted from packaging based on an earlier ISIR transaction without confirming the most recent ISIR data. To address this, the University has partnered with FA Solutions and implemented enhanced controls within Regent, including system checks to flag updated ISIR information and require confirmation of the most current transaction prior to packaging.Additionally, reconciliations and related reporting provided by FA Solutions will be reviewed for accuracy and completeness. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 3/31/2026

View Audit 396458

Finding 1204819 (2025-007)

Material Weakness 2025

Urshan College

MO

Special Tests & Provisions Questioned Costs Significant Deficiency § 200.303

2025-007 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance over stale checks that need to be returne...

2025-007 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance over stale checks that need to be returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is implementing enhanced controls to ensure compliance with stale-dated Title IV credit balance checks. This includes establishing a monthly review process in coordination with Accounts Payable, Accounts Receivable, and the Financial Aid Office to identify any outstanding checks approaching or exceeding the 240-day threshold. As part of this process, a tracking mechanism will be maintained to monitor the status and issuance dates of all Title IV credit balance checks. The University will make reasonable efforts to contact students and reissue checks, as appropriate, to ensure funds are received. Any checks that remain uncashed and meet the stale-dated threshold will be voided and returned to the U.S. Department of Education in accordance with federal requirements. These procedures will be formalized within a standardized SOP to ensure consistent and timely compliance moving forward. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid, Accounts Receivable Clerk, and Accounts Payable Clerk Planned completion date for corrective action plan: 4/30/2026

View Audit 396458

Finding 1204818 (2025-006)

Material Weakness 2025

Urshan College

MO

Student Financial Aid Questioned Costs Eligibility § 200.303

2025-006 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are award...

2025-006 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has conducted a review of its procedures for awarding Title IV funds, with particular attention to the awarding of Summer Pell. Through this review, we identified that Summer Pell was not awarded to eligible students during the applicable period, due in part to a misunderstanding of awarding requirements during a transition in third-party processing support. Urshan has since partnered with FA Solutions to strengthen oversight and ensure alignment with federal awarding requirements. Updated procedures have been implemented to ensure all eligible students are properly evaluated for Title IV aid, including Summer Pell, across all applicable terms. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 8/31/2026

View Audit 396458

Finding 1204817 (2025-005)

Material Weakness 2025

Urshan College

MO

Special Tests & Provisions Questioned Costs Subrecipient Monitoring § 200.303

2025-005 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review the GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit ...

2025-005 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review the GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has completed a comprehensive review and revision of its Written Information Security Program (WISP) to ensure alignment with all applicable requirements under the Gramm-Leach-Bliley Act (GLBA). While these updates were finalized after the end of FY25, the revised WISP now includes all required elements. The University has also received confirmation from the U.S. Department of Education’s Cybersecurity Compliance team that the updated program meets minimum GLBA compliance requirements. Moving forward, the University will maintain and periodically review its WISP to ensure ongoing compliance with federal standards. Name(s) of the contact person(s) responsible for corrective action: Dewayne Presson & Keith Braswell | Urshan IT Department Planned completion date for corrective action plan: 3/31/2026

View Audit 396458

Finding 1204816 (2025-004)

Material Weakness 2025

Urshan College

MO

Special Tests & Provisions Questioned Costs Student Financial Aid § 200.303

2025-004 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation o...

2025-004 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Urshan has partnered with FA Solutions, an experienced third-party processor. Through this partnership, we have strengthened our processes and implemented additional checks and balances to ensure that R2T4 determinations are identified, calculated, and processed in a timely and compliant manner. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 3/31/2026

View Audit 396458

Finding 1204676 (2025-006)

Material Weakness 2025

University Enterprises Corporation at Csusb

CA

Questioned Costs Reporting Significant Deficiency § 200.303 § 200.328

Federal Program Title: Higher Education Institutional Aid Assistance Listing Number: 84.031 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Recommendation: We recommend that UEC strengthen its reporting procedures to ensure required performance reports a...

Federal Program Title: Higher Education Institutional Aid Assistance Listing Number: 84.031 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Recommendation: We recommend that UEC strengthen its reporting procedures to ensure required performance reports are reviewed and approved prior to submission and that documentation is retained to support evidence of management review and report submission in accordance with Federal award requirements. Views of Responsible Officials: There is no disagreement with the audit finding. Action Taken in Response to Finding: Sponsored Programs, in coordination with the Office of Academic Research, will implement formal procedures requiring documented review and approval of all performance and annual reports prior to submission. Standardized processes, including approval documentation and retention of supporting records, will be established in accordance with Federal requirements. Roles and responsibilities will be defined, and compliance will be monitored. Targeted training will be provided to ensure staff understand reporting requirements and the updated procedures. Contact(s) Responsible for Corrective Action: Director of Sponsored Programs Planned Completion Date for Corrective Action: June 30, 2026

View Audit 396456

Finding 1204661 (2025-001)

Material Weakness 2025

Alverno College

WI

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

Condition: Management's review of the enrollment reporting did not detect that 2 student's change status was reported to NSLDS with incorrect information. Corrective Action Planned: The offices of Academic Advising and the Registrar will follow the procedure and process on student withdrawals and st...

Condition: Management's review of the enrollment reporting did not detect that 2 student's change status was reported to NSLDS with incorrect information. Corrective Action Planned: The offices of Academic Advising and the Registrar will follow the procedure and process on student withdrawals and student dismissals and inform the Senior Data Specialist and the Office of Financial Aid to ensure the date of withdrawal or date of dismissal is accurately and consistently recorded according to Alverno policy and to the National Student Loan Data System (NSLDS). Name(s) of Contact Person(s) Responsible for Corrective Action: Kate Tisch, Director -Academic Advising, Jillian Smith, Registrar, Denise Sanders, Senior Data Specialist and Naomi Coe, Director of Financial Aid. Anticipated Completion Date: This corrective action has been established and review of student changes of status are reviewed and reported on timely basis and accurately immediately.

View Audit 396431

Corrective Action Plans

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