Corrective Action Plans

Finding 1202062 (2025-014)

Material Weakness 2025

FL

Questioned Costs Allowable Costs / Cost Principles Period of Performance

Finding Number: 2025-014 Planned Corrective Action: Expenditures reviewed were for services or travel that occurred in June at the end of the grant budget period/state fiscal year but were paid by the Florida Department of Health (Department, FDOH) in July. During this time new Other Cost Accumulato...

Finding Number: 2025-014 Planned Corrective Action: Expenditures reviewed were for services or travel that occurred in June at the end of the grant budget period/state fiscal year but were paid by the Florida Department of Health (Department, FDOH) in July. During this time new Other Cost Accumulators (OCA) are created to match the new budget period/state fiscal year. Of the 16 expenditures provided to the Public Health Emergency Preparedness Program (PHEP) for review, 11 were for purchasing card (Pcard) charges for travel that occurred at the end of June but cleared in July. Previous year’s codes are not available when clearing Pcard charges from a previous fiscal year. The remaining expenditures were for payments that were redistributed by finance and accounting and could not be charged to current fiscal year OCAs once the new fiscal year began. Language has been added to the PHEP’s checkbook review process to specifically identify expenses that occur at the end of a budget period/fiscal year but are cleared or paid at the beginning of the next fiscal year. A correction will be submitted to move those expenses to the previous fiscal year as appropriate. Anticipated Completion Date: Completed Responsible Contact Person: Jennifer Coulter

View Audit 396183

Finding 1201937 (2025-010)

Material Weakness 2025

Liberty County District School Board

FL

Questioned Costs Special Tests & Provisions Eligibility

Finding Number: 2025-010 Planned Corrective Action: FCOM worked with its Employ Florida vendor and deployed a fix for the connectivity issue between Reconnect and Employ Florida in January 2025. A follow up meeting in April of 2025 where the issue was discussed did not reveal that the issue persiste...

Finding Number: 2025-010 Planned Corrective Action: FCOM worked with its Employ Florida vendor and deployed a fix for the connectivity issue between Reconnect and Employ Florida in January 2025. A follow up meeting in April of 2025 where the issue was discussed did not reveal that the issue persisted. In February 2026, the Auditor General notified FCOM that the fiscal year 2024/2025 audit revealed that the connectivity issue raised previously may still persist. FCOM is currently conducting an evaluation of the Auditor General’s sample and its larger datasets to isolate the variables causing these inconsistencies to determine if the issue has been resolved or if there is potentially a new connectivity issue to be resolved. The updated resolution will be completed by December 31, 2026. Anticipated Completion Date: December 31, 2026 Responsible Contact Person: Roosevelt Petithomme/Wendy Castle

View Audit 396183

Finding 1201616 (2025-003)

Material Weakness 2025

Ottawa University

KS

Special Tests & Provisions Questioned Costs Student Financial Aid

Corrective Action Plan 2025-003: Student Financial Aid and Accounts Receivable will work in coordination to sync the process of importing files and posting to accounts on the same day. Our new ERP has streamlined reporting to COD and catches and corrects any date discrepancies between the two system...

Corrective Action Plan 2025-003: Student Financial Aid and Accounts Receivable will work in coordination to sync the process of importing files and posting to accounts on the same day. Our new ERP has streamlined reporting to COD and catches and corrects any date discrepancies between the two systems. This finding was directly related to the migration from our old system and the disruption of data flow. Additionally, a review for matching COD disbursement dates will now be included during the monthly reconciliation process moving forward as a second layer of quality control. Anticipated Completion Date: June 30, 2026 Contact Person: Mary Reed, Director of Financial Aid & Advising

View Audit 396178

Finding 1201609 (2025-005)

Material Weakness 2025

Massachusetts College of Liberal Arts

MA

Questioned Costs Student Financial Aid

Corrective Action Plan: The Financial Aid Office will revise procedures to ensure reconciliation of Pell funding against enrollment on a monthly basis. Additionally, the Registrar’s office will revise and implement procedures to ensure timely reporting of administrative add/drops to SFS. Timeline fo...

Corrective Action Plan: The Financial Aid Office will revise procedures to ensure reconciliation of Pell funding against enrollment on a monthly basis. Additionally, the Registrar’s office will revise and implement procedures to ensure timely reporting of administrative add/drops to SFS. Timeline for Implementation: Spring 2027 Contact Person: Joe DaSilva (or Director of Student Financial Services upon hire) Vice President of Administration and Finance Peter Long Registrar & Director of Student Records

View Audit 396176

Finding 1201605 (2025-004)

Material Weakness 2025

Massachusetts College of Liberal Arts

MA

Questioned Costs

Corrective Action Plan: The Financial Aid Office will revise and implement procedures to reconcile SEOG funding at the end of each semester. Timeline for Implementation: Spring 2027 Contact Person: Joe DaSilva (or Director of Student Financial Services upon hire) Vice President of Administration and...

Corrective Action Plan: The Financial Aid Office will revise and implement procedures to reconcile SEOG funding at the end of each semester. Timeline for Implementation: Spring 2027 Contact Person: Joe DaSilva (or Director of Student Financial Services upon hire) Vice President of Administration and Finance

View Audit 396176

Finding 1201604 (2025-002)

Material Weakness 2025

Circle the City

AZ

Special Tests & Provisions Questioned Costs Material Weakness

Item: 2025-002 Assistance Listing Number: 93.224 Programs: Health Center Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A Contract Number: 24H80CS28365; H8JCS54690; 21H8HCS44987 Award Year: June 1, 2024 to May 31, 2025; December 1, 2024 to November 30, 20...

Item: 2025-002 Assistance Listing Number: 93.224 Programs: Health Center Program Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A Contract Number: 24H80CS28365; H8JCS54690; 21H8HCS44987 Award Year: June 1, 2024 to May 31, 2025; December 1, 2024 to November 30, 2025; September 1, 2023 to August 31, 2025 Compliance Requirement: Special Tests and Provisions Criteria: Health Centers must prepare and apply a sliding fee discount schedule so that the amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient’s ability to pay. Condition: For five claims tested, the discount for eligible patients was inaccurately calculated and billed. Name of Contact Person: Michele Grebisz, CFO Phone Number: (602)776-0776 Anticipated Completion Date: March 31, 2026 Views of Responsible Officials and Corrective Actions: Management agrees with the finding and will implement additional controls to ensure sliding fee discounts applied are reviewed and approved before patients are billed. Management will ensure this additional process includes clearly documenting the review and approval.

View Audit 396169

Finding 1201602 (2025-002)

Material Weakness 2025

Housing Authority of the County of Jackson

IL

Questioned Costs Significant Deficiency Matching / Level of Effort / Earmarking

Finding Numbers: 2025-001 and 2025-002 Program: USDA Rural Rental Housing Loans – ALN 10.415 Title: Noncompliance with Loan Agreement Corrective Action Plan: The Jackson County Development Corporation (JCDC) defaulted on the USDA Rural Development loan in 2017 due to insufficient operating cash flow...

Finding Numbers: 2025-001 and 2025-002 Program: USDA Rural Rental Housing Loans – ALN 10.415 Title: Noncompliance with Loan Agreement Corrective Action Plan: The Jackson County Development Corporation (JCDC) defaulted on the USDA Rural Development loan in 2017 due to insufficient operating cash flow generated by the Walker Hill Apartments. Since that time, the Housing Authority of Jackson County (JCHA) and JCDC have actively engaged in ongoing communication with USDA Rural Development to resolve the matter. During fiscal year 2025 and continuing into 2026, JCHA has taken the following actions to resolve the default: • In January 2025, JCHA requested an appraisal from USDA Rural Development; however, Rural Development indicated that an appraisal would not be conducted until an offer was received on the property. • JCHA coordinated with a licensed broker and posted the Walker Hill development for sale on April 15, 2025, for the balance owed on the USDA note. • Due to lack of offers, the listing price was reduced to $355,000. • Two residents relocated to public housing units, and the property currently has one remaining resident. • USDA Rural Development also indicated that they would post an additional listing on their portal to assist with marketing the property. • On August 8, 2025, JCHA received a cash offer for the property and forwarded the information to USDA Rural Development for review. • USDA Rural Development ordered an appraisal on August 11, 2025; the appraisal inspection was completed October 3, 2025. • The appraisal resulted in a value of approximately $250,000. USDA Rural Development indicated that a $75,000 offer could not be accepted based on the appraised value. • The property was subsequently listed at $285,000 to solicit additional interest. • As of March 25, 2026, a potential buyer has provided proof of funds and is pursuing financing. Upon receipt of a pre-approval letter, the offer will be formally submitted to USDA Rural Development for approval. It remains the intent of JCHA and JCDC to fully resolve this matter through completion of the USDA foreclosure and disposition process. JCHA will continue to cooperate with USDA Rural Development and provide documentation, property access, and administrative support necessary to facilitate resolution. Upon final disposition of the property, JCHA anticipates dissolving the JCDC entity, thereby eliminating any remaining obligations associated with the loan. Anticipated Completion Date: Resolution is dependent upon USDA Rural Development approval of a sale or completion of foreclosure proceedings. Management anticipates resolution during fiscal year ending June 30, 2026, subject to USDA Rural Development timelines. Responsible Party: Executive Director, Housing Authority of Jackson County JCDC Board of Commissioners Respectfully Submitted,

View Audit 396158

Finding 1201592 (2025-003)

Material Weakness 2025

Army West Point Athletic Association, Inc.

NY

Questioned Costs Reporting § 200.328

Audit Finding: Pursuant to 2 CFR 200.512 Report submission, Army West Point Athletic Association Inc. ("AWPAA") did not submit interim performance reports within 30 days after completion of the reporting period through the term of the agreement. Speciﬁcally, the interim performance report for one of...

Audit Finding: Pursuant to 2 CFR 200.512 Report submission, Army West Point Athletic Association Inc. ("AWPAA") did not submit interim performance reports within 30 days after completion of the reporting period through the term of the agreement. Speciﬁcally, the interim performance report for one of two quarters selected during the period July 1, 2024 – June 30, 2025 was not submitted within 30 days after completion of the reporting period. Root Cause Analysis: The frequency of the reporting has not consistently aligned with material updates. Deadlines were not strictly monitored. Corrective Action Plan: Monitor Reporting Compliance and track submission of Interim Performance Reports to ensure submission by the due date(s). Estimated Completion Date: June 30, 2026 Point of Contact: Thomas Theodorakis, Athletic Director/CEO

View Audit 396151

Finding 1201591 (2025-001)

Material Weakness 2025

City of Cincinnati

OH

Questioned Costs Period of Performance Significant Deficiency § 200.309

Planned Corrective Action: The City acknowledges the finding. Based on the recommendation, the City plans to do the following: • Establish separate program/project accounts within the financial system for each WIC grant award to ensure expenditures are recorded and tracked individually by grant peri...

Planned Corrective Action: The City acknowledges the finding. Based on the recommendation, the City plans to do the following: • Establish separate program/project accounts within the financial system for each WIC grant award to ensure expenditures are recorded and tracked individually by grant period. • Develop and implement written procedures requiring that all expenditures be reviewed and recorded based on the date incurred relative to the grant’s period of performance. • Perform monthly reconciliations of WIC expenditures by grant to verify that costs are accurately recorded and aligned with the appropriate funding period. • Implement period-end cutoff procedures to ensure expenditures near grant end dates are reviewed and properly assigned to the correct grant period. CHD Fiscal will begin implementing the plan by creating the program codes and will meet with WIC to establish roles for the written procedures. Anticipated Completion Date: 06/30/2026 Responsible Contact Person: Mark Menkhaus, Division Manager

View Audit 396143

Finding 1201573 (2025-002)

Material Weakness 2025

Urban College of Boston

MA

Questioned Costs Student Financial Aid

Finding number: 2025-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 & 84.268 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding. The Business Office will re-emphasize and...

Finding number: 2025-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 & 84.268 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding. The Business Office will re-emphasize and reinforce current procedures for identifying and monitoring student credit balances, including reviews triggered by changes to student accounts such as late disbursements of Title IV aid, tuition and fee adjustments. Staff have recently gone through retraining of this process and are reminded of the importance of conducting timely and thorough reviews after all account activity that may result in a credit balance. To strengthen adherence, together with the Financial Aid office, the Business Office will enhance oversight by increasing supervisory review of credit balance processing and refund timelines. Existing tracking mechanisms will be more closely monitored to ensure that all Title IV-related credit balances are refunded within required time frames. Additionally, both the Finance Aid Office and the Business office will conduct periodic internal reviews to confirm that procedures are being followed and to identify any areas where further reinforcement may be needed. Timeline for Implementation of Corrective Action Plan: Continued oversight and implementation of further checks and balances will be effective April 1, 2026. Contact Person: Erline Tanice, Chief Financial Officer: Erline.Tanice@urbancollege.edu

View Audit 396129

Finding 1201571 (2025-004)

Material Weakness 2025

Urban College of Boston

MA

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

Finding number: 2025-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and t...

Finding number: 2025-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined this was an isolated incident. The student was incorrectly marked in the system as having attended a course she had not, therefore she did not pull on any of the systems drop or withdrawal reporting. It was later discovered that the student had not attended the course therefore making the Return to Title IV calculation submission and refund late. No other students in the semester were affected by the miscalculation of attendance. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue a different situation from the prior year’s late refund return. This year’s late return was due to a systems issue and not due to internal process and procedure. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 396129

Finding 1201570 (2025-003)

Material Weakness 2025

Urban College of Boston

MA

Student Financial Aid Questioned Costs

Finding number: 2025-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected student and th...

Finding number: 2025-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected student and the college’s policies and procedures, has determined the error was a result of an isolated event due to human error. This was an oversight on the part of the processor. The processor failed to include break days of 5 days or more in the denominator of the Return to Title IV calculation resulting in an incorrect return amount. Urban College has applied institutional funding to the overpayment of funds. The Director of Financial Aid (DFA) has reviewed all Return to Title IV calculations for the Spring 2025 semester and confirms no other students were affected. The DFA is working with Global Financial Aid Services to include reviewing scheduled breaks as part of their quarterly audit review process. Timeline for Implementation of Corrective Action Plan: Implementation of new processes effective April 1, 2026 Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 396129

Finding 1201551 (2025-010)

Material Weakness 2025

City of Checotah

OK

Procurement, Suspension & Debarment Questioned Costs

Views of Responsive Officials and Planned Corrective Action: In the future, the City will solicit Requests for Proposals and/or Qualifications for any contracts that exceed $250,000 in which federal funding is involved in accordance with 2 CFR Part 200.

View Audit 396119

Finding 1201547 (2025-002)

Material Weakness 2025

Beulah Heights University

GA

Student Financial Aid Internal Control / Segregation of Duties Questioned Costs

Finding 2025-002 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Work-Study Community Service Requirement Not Met and Failure to Report FWS Earnings (significant deficiency): Criteria – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-...

Finding 2025-002 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Work-Study Community Service Requirement Not Met and Failure to Report FWS Earnings (significant deficiency): Criteria – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities unless the institution has received an approved waiver from the Department of Education. Per 34 CFR § 675.19(b), institution must maintain fiscal control and accountability over FWS funds and comply with all reporting requirements established by the Secretary. This includes accurately reporting FWS student earnings through required federal systems and maintaining documentation to support reported activity. Condition - Based on documentation provided for the 2024–2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, only $1,057 was identified as wages paid to students employed in community service activities. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from the U.S. Department of Education of not meeting the required 7 percent community service expenditure threshold. Additionally, during review of the institution’s 2024–2025 Federal Work-Study (FWS) activity, it was noted that FWS student earnings were not reported to the Common Origination and Disbursement (COD) System. The institution’s financial aid records and payroll registers indicate that students earned a total of $23,131 in FWS wages during the award year; however, no corresponding COD submissions or COD acknowledgment files were provided for review to demonstrate that these earnings were reported as required. Cause – The infraction appears to have resulted from failure to monitor compliance with the 7 percent FWS community service requirement and inadequate internal controls to ensure timely and accurate reporting of FWS earnings. Effect – The institution did not comply with the statutory community service spending requirement and FWS earnings were not reported through required federal reporting channels, limiting transparency and federal oversight. Questioned Costs - $0 Perspective – The Federal Work-Study Program includes explicit statutory spending and reporting requirements that are considered key compliance controls. In this instance, the institution expended approximately 4 percent of its authorized FWS allocation ($1,057 of $26,649) on community service wages, compared to the required 7 percent, resulting in a 43 percent shortfall from the required threshold. In addition, 100 percent of FWS earnings identified during testing ($23,131) were not reported to the COD System, as no submission or acknowledgment records were available. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen monitoring of community service requirements and establish formal FWS reporting controls and perform periodic internal audits of FWS expenditures and reporting to identify and correct issues prior to year-end and federal reporting deadlines. Management’s Response – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities. Based on documentation provided for the 2024-2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, $1,057 was identified as community service wages. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from ED was requested or approved

View Audit 396108

Finding 1201543 (2025-001)

Material Weakness 2025

Beulah Heights University

GA

Student Financial Aid Reporting Questioned Costs

Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. F...

Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Finding 2025-001 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs- Pell Grant Disbursement Reported in Incorrect Award Year (significant deficiency): Criteria – Per 34 CFR § 690.61, institutions must ensure that Pell Grant disbursements are made and reported for the correct award year and in accordance with program requirements. Institutions are required to report Pell Grant disbursements in the correct award year and submit all disbursement records by the published COD closeout deadline for the applicable award year Disbursements not reported by the closeout deadline may not be shifted to a subsequent award year to compensate for missed reporting. Condition - For the 2024–2025 award year, testing revealed that one (1) out of ten (10) students selected for testing became eligible for a Federal Pell Grant disbursement of $204 during the 2023–2024 award year. The institution failed to process and report the disbursement in COD prior to the 2023–2024 COD closeout deadline. To compensate, the institution incorrectly posted the $204 disbursement to the student’s account and reported the payment to COD under the subsequent 2024–2025 award year. Cause – The infraction appears to have resulted from failure to monitor and comply with COD Pell Grant closeout deadlines and inadequate controls to ensure disbursements are reported in the correct award year. Effect – Pell Grant disbursement activity was reported inaccurately to the Department of Education. Reporting the disbursement in the incorrect award year compromises the accuracy and integrity of federal Pell reporting. Misreported Pell activity increases the risk of required data corrections and program review findings. Questioned Costs - $204 Perspective – Accurate and timely reporting of Pell Grant disbursements by award year is a key Title IV compliance control, as Pell Grant funding is awarded, monitored, and closed out on an annual basis. In this instance, one (1) out of ten (10) students tested (10%) had a Pell Grant disbursement that was reported in an incorrect award year due to failure to meet the applicable COD closeout deadline. Although the dollar amount involved was limited, the error demonstrates that controls designed to ensure award-year accuracy and timely COD reporting did not operate effectively. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen closeout monitoring procedures, ensure award-year accuracy, and perform periodic internal reviews. Management’s Response – For the 2024–2025 award year, one (1) out of ten (10) students selected for testing became eligible for a Federal Pell Grant disbursement of $204 in the 2023-2024 award year. The institution failed to process the disbursement in COD prior to the 2023-2024 closeout deadline. To compensate, the institution incorrectly posted the $204 disbursement to the student’s account and reported the payment to COD under the subsequent 2024-2025 award year. Per 34 C.F.R. § 690.61 and the U.S. Department of Education’s Common Origination and Disbursement (COD) system requirements, institutions must report Pell Grant disbursements in the correct award year and by the published COD closeout deadline. A. Agree B. Conditions That Caused the Infraction a. Upon further review of the student’s account ledger, the institution identified that a $204 Pell Grant disbursement was incorrectly reflected for the Fall 2024 term. The student did not attend or enroll in Fall 2024; therefore, no Title IV funds should have been associated with that payment period. b. The Pell award was disbursed but was not properly aligned with the student’s actual enrollment timeline. Although the student attended Summer 2024 and Spring 2025, the institution did not submit a Student Bill Letter (SBL) for Spring 2025 because the student was enrolled in only one course. At the time, institutional practice did not require SBL submission for students enrolled less than half time or in a single course. As a result:  The Pell disbursement was not aligned with the correct payment period.  The $204 Pell award was incorrectly reflected as a Fall 2024 disbursement instead of being applied to the appropriate term.  This created a compliance issue related to Title IV disbursement timing and documentation.  Subsequent guidance from FA Solutions clarified that SBLs must be submitted for all enrolled students, regardless of enrollment intensity, to ensure proper alignment of Title IV funds with the correct payment period. C. The School’s Planned Corrective Action Plan (CAP)- The institution will implement the following corrective actions to address and prevent recurrence of this finding: a. Ledger Correction  The Student Accounts Office will revise the student’s ledger to accurately reflect the $204 Pell Grant disbursement as a Summer 2024 credit/refund, the term in which the student had eligible enrollment.  Any misapplied term references will be removed to ensure alignment with Title IV regulations. b. Policy and Procedure Update  Institutional procedures will be updated to require submission of Student Bill Letters (SBLs) for all enrolled students, including those enrolled in a single course or less than half time, when Title IV funds are involved.  This requirement will be documented in both Financial Aid and Student Accounts procedural manuals. c. Staff Training  Financial Aid and Student Accounts staff will receive training on updated SBL submission requirements and Title IV disbursement alignment.  Training will include review of payment period eligibility, enrollment intensity, and documentation standards. d. Cross Departmental Review Process  Financial Aid and Student Accounts will implement a secondary review process prior to Pell disbursement to confirm:  Enrollment for the applicable term  Presence of a submitted SBL  Correct payment period assignment D. Responsible Officials a. Dr. Gina Garlington, Financial Aid Administrator Responsible for Title IV compliance, staff training, SBL submission, and oversight of Pell disbursement procedures. b. CLA, Third Party Servicer and School’s Student Accounts Office Responsible for ledger corrections, and reconciliation of student accounts. E. Expected Timeline for Implementation a. All timelines have been complete F. Monitoring of Corrective Action Plan a. The CAP will be monitored through the following mechanisms:  Monthly reconciliation reviews between Financial Aid and Student Accounts  Random sampling of Pell disbursements to confirm correct payment period alignment.  Annual internal compliance review of SBL submissions and Title IV disbursements.  Documentation of corrective actions retained for audit and program review purposes.  Any discrepancies identified during monitoring will be addressed immediately and documented. G. Status of CAP Prior to This Finding a. This is the first occurrence of this finding for the institution. b. No prior corrective action plan existed addressing this specific issue. View of Responsible Officials- Officials agree with findings

View Audit 396108

Finding 1201539 (2025-004)

Material Weakness 2025

Drexel University

PA

Reporting Questioned Costs Eligibility

Management agrees with this finding. The instance in which a Pell Grant disbursement was not reported to the U.S. Department of Education Common Origination and Disbursement (COD) System within the required 15 calendar days was due to the student not answering the high school completion question on ...

Management agrees with this finding. The instance in which a Pell Grant disbursement was not reported to the U.S. Department of Education Common Origination and Disbursement (COD) System within the required 15 calendar days was due to the student not answering the high school completion question on the Free Application for Federal Student Aid (FAFSA), which relates to Ability to Benefit (ATB) eligibility. To address this issue and prevent recurrence, we have implemented an additional control. We now identify students who have been awarded a Pell Grant but have not answered the FAFSA high school completion question. For these students, an ATB requirement is posted on RRAAREQ, which prevents the Pell Grant from disbursing until the FAFSA question has been resolved. This process change ensures that Pell Grant funds will not disburse until the FAFSA high school completion question is completed, allowing the Pell Grant record to successfully extract to COD within the required reporting timeframe. This system update corrects the condition identified in the audit finding and strengthens our internal controls to ensure compliance with federal reporting requirements.

View Audit 396098

Finding 1201534 (2025-002)

Material Weakness 2025

Drexel University

PA

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

Management agrees with this finding. During the merger process, the U.S. Department of Education required that Salus University’s academic year for federal loans be closed out in order to complete the institutional consolidation. During this closed period, several students withdrew from the Summer t...

Management agrees with this finding. During the merger process, the U.S. Department of Education required that Salus University’s academic year for federal loans be closed out in order to complete the institutional consolidation. During this closed period, several students withdrew from the Summer term, which made it difficult to complete the R2T4 process within the standard timeline. This situation was the result of the unique operational constraints associated with the merger and is considered an anomaly rather than a reflection of Salus and Drexel University’s standard procedures. Now that Salus University and Drexel University are fully consolidated, we do not anticipate this circumstance occurring again. Drexel University maintains a written R2T4 policy that includes established procedures, system edit checks, and clearly defined staff responsibilities. Financial Aid team members are fully trained on R2T4 requirements and are responsible for monitoring student withdrawals and completing R2T4 calculations within the required timeframes to ensure compliance with federal regulations.

View Audit 396098

Finding 1201526 (2025-001)

Material Weakness 2025

Drexel University

PA

Questioned Costs Internal Control / Segregation of Duties

Management agrees with this finding and s currently working to implement an electronic consent (e-Consent) process for students to ensure compliance and improve documentation of student consent for electronic communications related to financial aid.Two processes are being implemented to address this...

Management agrees with this finding and s currently working to implement an electronic consent (e-Consent) process for students to ensure compliance and improve documentation of student consent for electronic communications related to financial aid.Two processes are being implemented to address this requirement: 1.Incoming Students:For new students, the e-Consent process will be incorporated into the confirmation section ofSlate (University incoming student CRM, Customer Relationship Mangement System). This willallow incoming students to review and complete the e-Consent electronically during theadmissions and enrollment confirmation process. 2.Continuing Students:For currently enrolled students, the e-Consent acknowledgment will be incorporated into theStudent Financial Obligation and Tuition Repayment Agreement (SFO). This ensures thatcontinuing students provide consent as part of the annual financial responsibility agreement process. In addition, information about the e-Consent policy will be published on the Drexel University website within the Terms and Conditions section so students have clear access to the policy and understand the requirements for electronic communication. These updates will ensure that students formally acknowledge and consent to electronic communications regarding financial aid and student account information, strengthening institutional compliance and internal controls. We anticipate having this in place for the start of the 26-27 academic year processing.

View Audit 396098

Finding 1201518 (2025-001)

Material Weakness 2025

Muhlenberg College

PA

Questioned Costs Student Financial Aid Reporting

Establish a formal reconciliation process between the general ledger and amounts reported in the FISAP; require documented review and approval of all FISAP data by the Controller or CFO prior to submission; Enhance the year-end closing timeline to ensure all relevant financial data is finalized befo...

Establish a formal reconciliation process between the general ledger and amounts reported in the FISAP; require documented review and approval of all FISAP data by the Controller or CFO prior to submission; Enhance the year-end closing timeline to ensure all relevant financial data is finalized before FISAP preparation; Develop and maintain written procedures for FISAP prepartion and review to ensure continuity during staffing transitions; Provide cross-training for key personnel involved in federal reporting to mitigate risks associated with turnover

View Audit 396095

Finding 1201514 (2025-001)

Material Weakness 2025

Family Planning Association of Maine, Inc. Dba Maine Family Planning

ME

Eligibility Internal Control / Segregation of Duties Questioned Costs

A. Remediation of Identified Files For participants who are no longer active in the WIC program, no further action will be taken, as the certification period has concluded. For participants who remain active and whose files lack a signed WIC Agreement of Rights and Responsibilities, an “alert” will ...

A. Remediation of Identified Files For participants who are no longer active in the WIC program, no further action will be taken, as the certification period has concluded. For participants who remain active and whose files lack a signed WIC Agreement of Rights and Responsibilities, an “alert” will be placed in the WIC system to ensure the required signature is obtained at the participant’s next scheduled appointment. The signed agreement will be retained in the participant’s certification file in accordance with documentation requirements. B. Staff Reinforcement and Training The WIC Director meets with staff weekly and will formally address the requirement to obtain and retain a signed WIC Agreement of Rights and Responsibilities annually. Staff will be reminded that a certification file is not considered complete unless all required eligibility documentation, including the signed agreement, is present. C. Strengthened Supervisory Review Control (Monitoring Control) Beginning immediately, the WIC Director (or designated supervisory staff) will implement a documented monitoring control to ensure completeness of eligibility documentation: 1. On a monthly basis, supervisory staff will select a sample of newly certified and recertified participant files. 2. The review will verify that all required eligibility documentation is present, including: o Categorical determination o Proof of residency o Income documentation o Nutritional risk documentation o Signed WIC Agreement of Rights and Responsibilities 3. Evidence of supervisory review (e.g., initials, checklist, or review log) will be retained. 4. Any deficiencies identified during internal monitoring will be corrected promptly, and trends will be discussed with staff. This monitoring control is designed to ensure ongoing compliance with federal and state eligibility documentation requirements and to prevent recurrence of the deficiency.

View Audit 396093

Finding 1201513 (2025-005)

Material Weakness 2025

Volunteers of America Western Washington and Subsidiary

WA

Matching / Level of Effort / Earmarking Special Tests & Provisions Questioned Costs § 200.303

2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 ...

2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 out of 21 contractor and subcontractor certified payrolls tested were not submitted timely. VOAWW recognizes that timely receipt and review of certified payrolls is essential to ensuring compliance with federal wage requirements. To strengthen internal controls and ensure certified payrolls are consistently obtained, reviewed, and retained, VOAWW will implement the following corrective actions: Implementation of Certified Payroll Submission Controls Before the end of FY26, VOAWW will implement internal controls requiring contractors and subcontractors to submit certified payrolls with each pay application. These controls will include: • A requirement that certified payrolls be submitted prior to payment • A standardized checklist for verifying receipt of certified payrolls • Documentation of the review and approval process • Follow up procedures for missing or incomplete payrolls These steps will ensure certified payrolls are consistently obtained and reviewed before payment is released. Training for Staff on Wage Rate Requirements Beginning in FY26, staff responsible for managing HUD funded construction projects will receive training on: • Davis-Bacon and related wage requirements • Certified payroll documentation standards • Review procedures and red flags • Requirements under 29 CFR Part 5 Contractor Communication and Expectations Before the end of FY26, VOAWW will update contractor communication materials to clearly outline certified payroll requirements, including: • Submission timelines • Required documentation • Consequences for noncompliance • Points of contact for questions or clarifications These expectations will be reinforced during project kick off meetings and throughout the contract period. Centralized Tracking of Certified Payrolls By the end of FY26, VOAWW will implement a centralized tracking log for all certified payroll submissions. This log will document: • Receipt dates • Review dates • Reviewer initials • Any follow up actions taken This will ensure a complete audit trail and consistent monitoring of compliance. These corrective actions will strengthen VOAWW’s internal controls over Wage Rate Requirements, ensure timely receipt and review of certified payrolls, and reduce the risk of noncompliance with federal labor standards. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

View Audit 396088

Finding 1201512 (2025-004)

Material Weakness 2025

Volunteers of America Western Washington and Subsidiary

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Questioned Costs § 200.414

2025-004 Indirect Cost Rate Application on Federal Invoices We acknowledge BDO’s observation regarding the indirect cost rate applied to federal invoices during the period in which VOAWW transitioned from its approved NICRA rate to the de minimis rate. During this transition, VOAWW applied the NICRA...

2025-004 Indirect Cost Rate Application on Federal Invoices We acknowledge BDO’s observation regarding the indirect cost rate applied to federal invoices during the period in which VOAWW transitioned from its approved NICRA rate to the de minimis rate. During this transition, VOAWW applied the NICRA rate of 17.2% while moving to the de minimis rate but did not complete the required true-up to 10% for a three-month period prior to the de minimis rate being increased to 15%. VOAWW has reviewed the circumstances that led to this error and determined that it occurred during an unusual and infrequent set of conditions. Transitions between indirect cost methodologies are rare and increases to the federal de minimis rate are also uncommon. As a result, this specific scenario is unlikely to recur. Nonetheless, VOAWW recognizes the importance of strengthening controls around indirect rate changes to ensure accurate application during any future transitions. To address this finding and strengthen controls over indirect cost rate application, VOAWW will implement the following corrective actions: • Formal Rate Transition Procedures – Before the end of FY26, the Finance Department will develop and document a standardized procedure for transitioning between indirect cost rates, including effective dates, interim rate requirements, required true-ups, and approval checkpoints to ensure accurate application during any future rate changes. • Centralized Indirect Rate Tracking – Before the end of FY26, the Finance Department will maintain a centralized indirect rate schedule that includes approval documentation, effective dates, and any required adjustments. This schedule will be referenced during invoice preparation and review to ensure consistent and accurate rate application across all federal awards. • Contract Kick-Off Meetings and Cross-Department Alignment – Before the end of FY26, Finance, Grants, and Contract Compliance will implement contract kick-off meetings for new awards and significant contract amendments to align on billing requirements, approved indirect cost rates, effective dates, and other critical compliance information and ensure consistent communication across departments. • Documentation of Important Communications – Before the end of FY26, VOAWW will implement guidance for documentation of important communications with funders that have a single audit impact. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

View Audit 396088

Finding 1201508 (2025-003)

Material Weakness 2025

Volunteers of America Western Washington and Subsidiary

WA

Allowable Costs / Cost Principles Questioned Costs § 200.303

2025-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles We acknowledge BDO’s finding regarding an unallowable cost that was initially charged to the Home Investment Partnerships Program. Although the error was able to be rectified, the initial error indicated that internal controls...

2025-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles We acknowledge BDO’s finding regarding an unallowable cost that was initially charged to the Home Investment Partnerships Program. Although the error was able to be rectified, the initial error indicated that internal controls did not prevent or detect the unallowable charge at the time of posting. To strengthen internal controls over allowable costs and ensure expenditures charged to federal programs comply with Uniform Guidance and program-specific requirements, VOAWW will implement the following corrective actions: Strengthened Review of Allowable Costs Before the end of FY26, the Finance Department will enhance its invoice review procedures for all programs. This strengthened review will include verification of: • Allowability under 2 CFR §200 Subpart E • Program specific requirements • Contract terms and approved budgets • Supporting documentation for each cost Review steps will be documented to ensure a clear audit trail. Training for Staff on Federal Allowable Cost Requirements Beginning in FY26, Finance, Grants, and Contract Compliance staff responsible for coding, approving, or reviewing federal expenditures will receive training on: • Allowable cost principles under 2 CFR §200.403–.405 • Program specific cost restrictions • Documentation standards • The importance of internal controls over federal expenditures Before the end of FY26, VOAWW will implement internal controls to ensure that allowability determinations are made internally by trained staff prior to charging costs to federal awards. Centralized Federal Award Compliance Reference By the end of FY26, Contract Compliance will maintain a centralized compliance reference for all federal programs, including allowability rules, program specific restrictions, and documentation requirements. Finance staff will reference this tool during invoice review to ensure consistent application of federal requirements. These corrective actions will strengthen VOAWW’s internal controls over allowable costs, reduce the risk of unallowable expenditures being charged to federal programs, and ensure compliance with Uniform Guidance and HUD program requirements. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

View Audit 396088

Finding 1201504 (2025-001)

Material Weakness 2025

Hardee County District School Board

FL

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The District appreciates the opportunity to respond to the audit finding regarding inconsistencies between Title I rank order and the allocation of funds based on low-income student percentages for the 2024-2025 fiscal year. Our review indicates that the variance in allocations resulted from a budge...

The District appreciates the opportunity to respond to the audit finding regarding inconsistencies between Title I rank order and the allocation of funds based on low-income student percentages for the 2024-2025 fiscal year. Our review indicates that the variance in allocations resulted from a budget decision to provide additional Title I funding to Bowling Green Elementary to support after-school programming, without fully accounting for per-pupil allocation. Historically, Bowling Green Elementary has served one of the highest concentrations of students from low-income families in the District, and the additional allocation was intended to ensure continuity of extended learning opportunities for students with significant academic need. While this decision was grounded in student need, the District recognizes that the additional funds were not fully reconciled with updated poverty data and required rank-order calculations. The District has demonstrated compliance with rank and serve requirements in prior years; however, to prevent recurrence, we are strengthening our internal controls. Beginning immediately, the District will implement a structured monthly review of Title I school allocations involving the Title I Program Specialist, the Finance Director, and the Deputy Superintendent to ensure that the 2025-2026 allocations align with current poverty data and PSES calculations. Additionally, the District will seek guidance from the Florida Department of Education Title I Office to confirm that our procedures fully meet all regulatory expectations. The District is confident that these corrective actions will ensure full compliance in 2025-2026 moving forward and will strengthen the integrity of our allocation processes.

View Audit 396085

Finding 1201503 (2025-001)

Material Weakness 2025

City of Newton, Massachusetts

MA

Questioned Costs Cash Management Reporting

Child Nutrition Cluster, ALN’s 10.553 & 10.555 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Explanation of disagreement with audit...

Child Nutrition Cluster, ALN’s 10.553 & 10.555 Recommendation: We recommend the review and approval process over monthly claims for reimbursement be strengthened to enhance the prevention of discrepancies between the claim for reimbursement and underlying data. Explanation of disagreement with audit finding: Management agrees with the finding. Action taken in response to finding: Newton operated the National School Lunch Program (NSLP) during the Extended School Year (ESY) for the first time during the summer 2024, which created a reporting challenge. Students from across the district's 23 schools attended ESY in seven (7) schools/sites, but their school-year home schools could not be changed in the Student Information System (Aspen). Therefore, student meal counts reported to their home school on the FP9 but had to be reported on the DESE School Report for the ESY school/site they attended. Given the system interface complexities, some counts had to be manually entered, for which two (2) meal counts were incorrectly entered for breakfast versus lunch. Given that the district did not operate the School Breakfast Program (SBP) and did not serve breakfast, these two (2) manual errors were counted as lunch counts when entered for the School Report. The total meal count did match on the FP9 and School Report. For this inconsistency, the correct action should have been to manually update these two counts in the Point of Sale system (Mosaic) so that the two breakfast counts reflected correctly as lunch counts. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: Newton was able to set conditional parameters in Aspen for ESY 2025 so that the student meal counts reported to their ESY school/site versus their home school, so this reporting issue was corrected the following summer.

View Audit 396079

Corrective Action Plans

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