Corrective Action Plans

Finding 1171321 (2025-001)

Material Weakness 2025

Craven County

NC

Eligibility Internal Control / Segregation of Duties Questioned Costs

Board of Commissioners Administration Building Jason R. Jones, Chairman 406 Craven Street Dennis Bucher, Vice Chairman New Bern, NC 28560 Thomas F. Mark George S. Liner Fax 252-637-0526 Theron L. McCabe jveit@cravencountync.gov Ettienne “E.T.” Mitchell Beatrice R. Smith Administrative Staff Jack B. ...

Board of Commissioners Administration Building Jason R. Jones, Chairman 406 Craven Street Dennis Bucher, Vice Chairman New Bern, NC 28560 Thomas F. Mark George S. Liner Fax 252-637-0526 Theron L. McCabe jveit@cravencountync.gov Ettienne “E.T.” Mitchell Beatrice R. Smith Administrative Staff Jack B. Veit III, County Manager Commissioners 252-636-6601 Gene Hodges, Assistant County Manager Manager 252-636-6600 Nan Holton, Clerk to the Board Finance 252-636-6603 Amber M. Parker, Human Resources Director Human Resources 252-636-6602 Craig Warren, Finance Director None Reported. Finding 2025-001 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed completion date: April Rollins, Medicaid Program Manager Policy refresher training will be held by December 31, 2025. Refresher training for staff that files should be reviewed internally to ensure proper documentation is in place for eligibility determination. Workers will receive refresher training what files should contain and the importance of complete and accurate record keeping. Staff will have refresher training that all files include online verifications; documented resources of income and those amounts agree to information in NC FAST. The results found or documentation made in case notes should clearly indicate what actions were performed and the results of those actions. Second party reviews of at least or in excess of the state’s mandated 98 cases will be conducted quarterly. The second party review threshold for staff is 90%. Any errors will be discussed one on one by the supervisor with the employee to ensure the employee has a full understanding of policies and procedures. Supervisors will review error trends every quarter to determine if further group training is needed. The Learning Gateway trainings have also been completed in the past 180 days for all Medicaid staff will further assist with retaining staff. 12/31/2025 Corrective Action Plan For the Year Ended June 30, 2025 Section II - Financial Statement Findings Section III - Federal Award Findings and Questioned Costs 188

View Audit 384595

Finding 1171305 (2025-002)

Material Weakness 2025

City of Asheville

NC

Subrecipient Monitoring Questioned Costs Allowable Costs / Cost Principles

2026 HOME AUDIT 1. Establish Annual Monitoring Plan ● Action: Create a formalized Annual Monitoring Plan based on subrecipient risk assessments and total annual federal funding. ○ Tiered Oversight: ■ High Risk: Required on-site visits (or deep-dive virtual audits) ■ Medium/Low Risk: Desk reviews and...

2026 HOME AUDIT 1. Establish Annual Monitoring Plan ● Action: Create a formalized Annual Monitoring Plan based on subrecipient risk assessments and total annual federal funding. ○ Tiered Oversight: ■ High Risk: Required on-site visits (or deep-dive virtual audits) ■ Medium/Low Risk: Desk reviews and annual check-ins, sampling beneficiaries for eligibility. ■ Funding amount: Activities with $750,000 or more in federal funding (inclusive of all federal assistance) must undertake a single audit in addition to monitoring ● Completion Date: 2/27/2026 ● Responsible: Community Development Division Manager, Community Development Analysts ● Content: The plan will explicitly list which subrecipients are slated for which type of review each year. ● Documentation: Approved Annual Monitoring plan 2. Training and Capacity Building ● Action: All Community Development staff will undergo monitoring training ● Completion Date: 2/27/2026 ● Responsible: Community Development Manager, Community Development Analysts, Community Development Coordinator ● Content: Training will cover compliance requirements, identifying "red flags", confirming beneficiary eligibility, and internal monitoring Standard Operating Procedures and checklists. ● Documentation: Training logs and updated job aids. 3. Implementation & Execution ● Action: Initiate monitoring activities, prioritizing Higher Risk subrecipients identified in the initial assessment, and requesting single audits from subrecipients who received more than $750,000 in federal funding ● Completion Date: 6/30/2026 and on-going ● Responsible: Community Development Analysts, Community Development Coordinator ● Content: Analysts will produce written monitoring reports for each review following established policies and checklists for each program, which the Community Development Manager will sign off on. ● Documentation: Approved monitoring reports will be recorded and accessible for reference

View Audit 384579

Finding 1171162 (2025-003)

Material Weakness 2025

Arizona Christian University

AZ

Questioned Costs Student Financial Aid Eligibility

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure the Stafford loans are awarded within the annual and aggregate limits. Explanation of disagreement with audit finding: T...

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure the Stafford loans are awarded within the annual and aggregate limits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the time the Subsidized Direct Loan was initially awarded, the student was classified as grade level one and was correctly awarded $3,500. Subsequently, the student’s grade level increased; however, the Direct Loan award was not adjusted accordingly. The Office of Financial Aid relies on email notifications to identify students with grade-level changes, and the notification for this student was inadvertently missed. In response to this error, the Office of Financial Aid implemented additional monitoring controls. A report was developed to identify all students with changes in grade level and is now generated and provided weekly by the Office of the Registrar to the Office of Financial Aid. A designated Financial Aid Advisor has been assigned responsibility for reviewing this report and adjusting Direct Loan awards as necessary to ensure accuracy. As an additional preventative measure, the Director of Financial Aid will verify student grade level and corresponding Direct Loan eligibility prior to disbursement. The Office of Financial Aid will also conduct periodic reviews to confirm that Direct Loan awards consistently and accurately align with students’ grade levels.

View Audit 384567

Finding 1171157 (2025-002)

Material Weakness 2025

Arizona Christian University

AZ

Questioned Costs Student Financial Aid Reporting

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding:...

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The withdrawal dates applied in the Return to Title IV (R2T4) calculations were based on the dates students were administratively withdrawn by the Office of the Registrar. Upon identification of the audit finding, the Office of Financial Aid conducted a comprehensive review of the affected R2T4 calculations and made the necessary corrections. Any balances resulting from these errors were subsequently written off. Additionally, the Director of Financial Aid completed a full file review for the applicable award year to assess the accurate inclusion of scheduled break days. During this review, two additional students were identified whose R2T4 calculations did not include the appropriate number of break days. The calculations for these students were corrected, and the resulting balances were written off. No further errors were identified. As part of the corrective action, the Office of Financial Aid has hired an additional Financial Aid Advisor dedicated to the review and completion of R2T4 calculations. Furthermore, the Director of Financial Aid has implemented a secondary review process for all completed R2T4 calculations to ensure accuracy and compliance. The Office of Financial Aid has also reviewed the Financial Aid Handbook and applicable Code of Federal Regulations (CFR) related to R2T4 calculations to reinforce adherence to regulatory requirements. Name(s) of the contact person(s) responsible for corrective action: Angel Faast and Laura Silva Planned completion date for corrective action plan: 12/17/2025

View Audit 384567

Finding 1171152 (2025-001)

Material Weakness 2025

Arizona Christian University

AZ

Questioned Costs Student Financial Aid Reporting

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There i...

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: : In November 2024, the Associate Director of Institutional Research (ADIR) and Associate VP of Institutional Effectiveness (AVPIE) created a tool for scheduling, tracking, and reviewing the status and completion of National Student Clearinghouse submissions. The audit finding occurred before this tool was in place, and since its implementation, late reporting has been reduced, and the corrective action plan has been successful Name(s) of the contact person(s) responsible for corrective action: Jeff Phillips and Eric Tompkins Planned completion date for corrective action plan: November 1, 2024

View Audit 384567

Finding 1171138 (2025-001)

Material Weakness 2025

Episcopal Community Services of the Diocese of Pennsylvania

PA

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

Finding 2025-001: ECS provides out-of-school time programming to youth to improve life skills, increase academic engagement and prepare youth for higher education and employment. ECS is required to maintain and submit attendance records as part of this program. Attendance records were not maintained...

Finding 2025-001: ECS provides out-of-school time programming to youth to improve life skills, increase academic engagement and prepare youth for higher education and employment. ECS is required to maintain and submit attendance records as part of this program. Attendance records were not maintained and submitted for one of the sites tested. During our testing of nine monthly attendance records, we noted attendance records for one selection could not be provided. The sample was not intended to be, and was not, a statistically valid sample. 2025-001 Recommendation: We recommend the Organization implement a process and related controls related to review, approval and submission of attendance records of at the site. Contracted slots utilized should be based on actual attendance and related documentation maintained by the Organization to support those amounts. Action Taken: Management agrees with the finding and has taken corrective action by adopting review, approval and submission processes to support contracted slots utilized. Moreover, the site in question was closed and the staff responsible were terminated. These actions and controls were completed and placed in service, respectively, during the year ended June 30, 2025, but were not conducted for the entire year. Date of Completion: January 14, 2026

View Audit 384543

Finding 1171132 (2025-001)

Material Weakness 2025

Pacific House, Inc.

CT

Questioned Costs Subrecipient Monitoring Reporting

Pacific House and Subsidiaries has transitioned to a new CPA firm and is working closely with them to ensure the Data Collection Form is timely submitted for the fiscal year ended June 30, 2025 and in future.

View Audit 384518

Finding 1171099 (2025-002)

Material Weakness 2025

Northeast Ohio Medical University

OH

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding Number: 2025-002 Anticipated Completion Date: 10/07/2025 Responsible Contact Person: Katherine Miranda, University Registrar Kelly Burt, Assistant Registrar Records Management and Reporting Michele Bergman, Assistant Registrar, Records Management and Reporting Planned Corrective Action: The ...

Finding Number: 2025-002 Anticipated Completion Date: 10/07/2025 Responsible Contact Person: Katherine Miranda, University Registrar Kelly Burt, Assistant Registrar Records Management and Reporting Michele Bergman, Assistant Registrar, Records Management and Reporting Planned Corrective Action: The Offices of the Registrar and Admission Operations reviewed the case, reviewed the proper student record protocol, and added a reporting checkpoint to review for dually enrolled students before submitting enrollment reports to the National Student Clearinghouse (NSC). Once NSLDS is updated with NSC data, the Office of the Registrar will work with Office of Financial Aid to confirm NSLDS is accurate for the dually enrolled students.

View Audit 384492

Finding 1171041 (2025-001)

Material Weakness 2025

Louisville Metro Housing Authority

KY

HUD Housing Programs Questioned Costs Subrecipient Monitoring

Finding Reference: 2025-001 Description of Finding: HUD regulations require certifications to be completed and entered timely to ensure accurate calculation of Housing Assistance Payments (HAP), Total Tenant Payment (TTP) and utility reimbursements. Per 24 CFR section 982.516, the Authority must ree...

Finding Reference: 2025-001 Description of Finding: HUD regulations require certifications to be completed and entered timely to ensure accurate calculation of Housing Assistance Payments (HAP), Total Tenant Payment (TTP) and utility reimbursements. Per 24 CFR section 982.516, the Authority must reexamine family income and composition at least once every two years and adjust the tenant rent and housing assistance payment as necessary using the documentation from third party verification. Of the 60 Moving to Work files tested, the following items were noted: • 40 instances of certifications not completed timely • 6 instances where the file did not contain income support • 3 instances where housing quality standards inspections were not completed within the last 2 years • 1 instance in which a rent comparison was not completed for a new move in Statement of Concurrence or Nonconcurrence: Louisville Metro Housing Authority agrees with Cherry Bekaert in reference to audit finding 2025-001. Corrective Action: LMHA continues to work through issues around the proper and timely processing of program certifications to support accurate Housing Assistance Payments, Total Tenant Payments and utility reimbursements. Currently, recertifications are processed on a biennial basis schedule, through a three-tiered system outlined in our updated MTW plan. This will address timeliness of recertification while also ensuring compliance and review of supporting documentation. Please note the following rules tied to LMHA’s three-tiered recertification system: 1) When the family is zero income, they will go to an annual recertification. 2) When family is working, (enrolling in KTAP (Kentucky Transitional Assistance Program), receiving Child Support, and other similar sources of income) they will go to a biennial recertification. 3) When a family has fixed income, (receiving Social Security, Supplemental Security Income, and/or Pension payments), they will go to a triennial recertification. The HCV Team is also working with Yardi (ERP system) to maximize the reporting and monitoring of the recertification schedule. The manager initiates the tracking for needed processing and possible termination of participants. With the three-tiered system, staff will be able to review all tenant information closely during recertifications to ensure proper housing assistance payments. Additionally, to improve sufficient controls and internal monitoring, the HCV Team is partnering with the Compliance Team to review tenant files for errors and improper supporting documentation.

View Audit 384423

Finding 1170981 (2025-001)

Material Weakness 2025

Watkins Glen Central School District

NY

Questioned Costs Cash Management Eligibility

Corrective Action Plan: The School District is committed and will be diligent in preparing meals with high quality products. Regular cooked meals and expanded menu choices will be prepared which will result in an increase in expenses. There has been unpredictability with the increase of certain good...

Corrective Action Plan: The School District is committed and will be diligent in preparing meals with high quality products. Regular cooked meals and expanded menu choices will be prepared which will result in an increase in expenses. There has been unpredictability with the increase of certain goods, and we expect this to continue into the 2025-2026 fiscal year as well. The School District also participates in the Community Eligibility Provision (CEP) which provides free breakfast and lunch to every student within the School District. Salaries for School Lunch employees have also been increasing year after year due to the increase of minimum wage in New York State. The minimum wage is expected to increase to $16.00 per hour and entry level wages have increased per contract. The School District does have a practice of transferring BOCES aid gained from the cost of the BOCES management contract to the School Lunch Fund; the aid will not be transferred in upcoming years. The School District has devised a NYSED approved plan to expend the excess funds in the School Lunch Fund through appropriating a substantial amount of fund balance to be planned for and used for the cafeteria and kitchen within the next planned capital project. We are currently in the planning phase of our next capital project with a vote anticipated during the 2025-2026 fiscal year. If needed, we will examine other avenues to ensure we do not exceed the allowable limit of cash at year end.

View Audit 384367

Finding 1170971 (2025-001)

Material Weakness 2025

Talbot Bernard Senior Housing Corporation

MA

Questioned Costs HUD Housing Programs

Responsible Official Jeffrey Caputi Plan Detail A calculation was made of the underfunding through December 2025, which amounted to 130,132. The funds were transferred from the operating account to the replacement reserve account making the reserve fully funded as of December 19, 2025. Anticipated C...

Responsible Official Jeffrey Caputi Plan Detail A calculation was made of the underfunding through December 2025, which amounted to 130,132. The funds were transferred from the operating account to the replacement reserve account making the reserve fully funded as of December 19, 2025. Anticipated Completion Date: December 19, 2025.

View Audit 384349

Finding 1170939 (2025-002)

Material Weakness 2025

Jewish Family Services, Inc.

WI

Subrecipient Monitoring Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.319 § 200.320 § 200.326 § 200.516

Criteria or Specific Requirement: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which re...

Criteria or Specific Requirement: Nonfederal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Views from Responsible Officials: Management agrees with the finding. Management has established written policies and procedures for procurement. Management confirmed policies and procedures were followed and monitored during the construction of the project. Written policies and procedures were completed after year-end. Contact Person: John Jacques Date of Completion: November 14, 2025

View Audit 384246

Finding 1170906 (2025-002)

Material Weakness 2025

United Social and Mental Health Services, Inc. and Subsidiaries

CT

Cash Management Questioned Costs Significant Deficiency § 200.302 § 200.303 § 200.305

Recommendation The Organization should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding No Action Taken A new federal cash draw down form has been created that will ensure all cash draw downs are reviewed and approved by the CEO. If there are ...

Recommendation The Organization should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding No Action Taken A new federal cash draw down form has been created that will ensure all cash draw downs are reviewed and approved by the CEO. If there are any question regarding this plan, please e-mail Diane Manning at dvdlmanning@usmhs.org.

View Audit 384191

Finding 1170887 (2025-002)

Material Weakness 2025

Hood College of Frederick, Maryland and Affiliates

MD

Questioned Costs Student Financial Aid Allowable Costs / Cost Principles § 200.303

Corrective Action Plan Finding Number: 2025-002 – Return of Title IV Funds Controls Finding: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Corrective Action Planned Given the size of the Financial Aid Office, the College will implement comp...

Corrective Action Plan Finding Number: 2025-002 – Return of Title IV Funds Controls Finding: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Corrective Action Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure R2T4 calculations are accurate, timely, and compliant with federal regulations. Effective immediately, the College will implement the following controls: 1. Standardized R2T4 Processing All R2T4 calculations will be performed using the Department of Education Common Origination & Disbursement (COD) system to ensure consistent application of federal formulas. Official withdrawal dates will be confirmed using Registrar records prior to calculation. 2. Independent Post-Calculation Review Each R2T4 calculation will be reviewed by an individual other than the preparer, where feasible, or through supervisory review when staffing is limited. The review will confirm the accuracy of withdrawal dates, days attended, calculation inputs, and Title IV funds included. 3. Coordination and Reconciliation The Office of Financial Aid will coordinate with Student Accounts to ensure R2T4 results are applied correctly to the student account and that returned funds are processed within required timelines. 4. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained for each R2T4 calculation. A simple R2T4 review checklist or log will be maintained. 5. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to ensure R2T4 calculations and reviews are completed accurately and timely. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: Implemented effective August 1, 2025 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been identified. While formal independent review controls were not documented during the audit period, there were no identified R2T4 compliance issues, late returns, or calculation errors. The corrective actions above are intended to formalize review processes and further reduce compliance risk.

View Audit 384186

Finding 1170880 (2025-001)

Material Weakness 2025

Hood College of Frederick, Maryland and Affiliates

MD

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid § 200.303

Corrective Action Plan Finding Number: 2025-001 – Enrollment Reporting Controls – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to NSLDS for student enrollment status changes. Corrective Actions Planned Given the size of the F...

Corrective Action Plan Finding Number: 2025-001 – Enrollment Reporting Controls – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to NSLDS for student enrollment status changes. Corrective Actions Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure accurate and timely enrollment reporting while maintaining operational efficiency. Effective immediately, the College will implement the following controls: 1. Continued Use of the National Student Clearinghouse (NSC) The College will continue to rely on the National Student Clearinghouse as its third-party servicer for enrollment status reporting to NSLDS. 2. Independent Post-Submission Review On a monthly basis, the Office of Financial Aid will review NSC enrollment reporting confirmation files to verify that enrollment status changes were submitted to NSLDS accurately and within the required 60-day timeframe. This review will be performed by an individual other than the primary preparer, where feasible, or through supervisory review when staffing is limited. 3. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained. A simple enrollment reporting review log will be maintained to document compliance. 4. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to confirm controls are operating as intended. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: February 1, 2026 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been initiated. While formal independent review controls were not documented during the audit period, there were no identified instances of late enrollment reporting or inaccurate enrollment status submissions to NSLDS. The corrective actions above are intended to formalize controls and ensure sustained compliance with federal requirements.

View Audit 384186

Finding 1170872 (2025-002)

Material Weakness 2025

Bucks County Community College

PA

Questioned Costs Subrecipient Monitoring Material Weakness

Finding 2025-002: Reporting (Material Weakness, repeat finding) U.S. Treasury Department – COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Statement of Condition: During testing one of the College’s quarterly ARPA expenditure reports was submitted to Bucks County after the de...

Finding 2025-002: Reporting (Material Weakness, repeat finding) U.S. Treasury Department – COVID-19 Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027) Statement of Condition: During testing one of the College’s quarterly ARPA expenditure reports was submitted to Bucks County after the deadline per the grant agreements. The report tested was submitted 20 days late. Criteria: The College is a subrecipient of ARPA funding from Bucks County. The grant agreements state the College must submit quarterly expenditure reports to the County 11 days after the end of the quarter (calendar year). Cause: The College did not have adequate controls in place to ensure the timely filing of expenditure reports. Effect: Failure to comply with ARPA reporting requirements could jeopardize future federal funding. Recommendation: We recommend that the College reconcile, review, and submit reports in a timely manner based on grant agreements. Questioned Costs: This finding does not result in questioned costs. View of responsible officials and planned corrective actions: Management agrees with the finding. The College has strengthened the process to ensure the timely and accurate reconciliation, review, and submission of expenditure reports consistent with the requirements of all grant agreements. The College’s Grant Office has created a Grant Project Management Platform to track compliance requirements for all grants including timely invoicing and reporting. This platform provides a dashboard and reminder functions for deadline monitoring. The Grants Manager participates in weekly meetings with the Executive Director, Research, Assessment, Data Analytics, & Reporting, to review deadlines and facilitate the timely and accurate completion of all tasks related to grant compliance. Name(s) of Contact Person(s) Responsible for Corrective Action: Elana Felberg, Grants Manager Anticipated Completion Date: January 31, 2026

View Audit 384165

Finding 1170869 (2025-001)

Material Weakness 2025

Junior College District of East Central Missouri

MO

Student Financial Aid Questioned Costs Reporting

Janaury 16, 2026 U.S. DEPARTMENT OF EDUCATION East Central 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. Chris Hoelzer, Vice President of Finance & Administration E...

Janaury 16, 2026 U.S. DEPARTMENT OF EDUCATION East Central 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. Chris Hoelzer, Vice President of Finance & Administration East Central College 1964 Prairie Dell Road Union, MO 63084 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 finding 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 conducted a comprehensive review of all student accounts potentially impacted by the incorrect academic calendar dates and identified 52 students whose Return of Title IV (R2T4) calculations required review. As a result of this reveiw, the Financial Aid Office determined that 41 students required a return of Title IV funds to the U.S. Department of Education. The total amount of funding returned was $12,590. The Financial Aid Office corrected the R2T4 calculations, updated the academic calendar dates in the financial aid system, and processed the required returns of Title IV funds. To prevent recurrence, the College has implemented internal procedures to ensure academic calendar dates are reviewed and verified in the financial aid system before performing R2T4 calculations for each award year. Anticipated Completion Date: Fall semester 2025 and ongoing. Sincerely, Chris Hoelzer Vice President of Finance & Administration

View Audit 384161

Finding 1170859 (2025-001)

Material Weakness 2025

University of Wyoming

WY

Student Financial Aid Questioned Costs Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions - The University’s Office of Student Financial Services agrees with the recommendation and will ensure that Return of Title IV (R2T4) calculations and applicable returns of funds for all students who officially or unofficially withdraw ar...

Views of Responsible Officials and Planned Corrective Actions - The University’s Office of Student Financial Services agrees with the recommendation and will ensure that Return of Title IV (R2T4) calculations and applicable returns of funds for all students who officially or unofficially withdraw are completed within required regulatory time frames. To strengthen internal controls related to R2T4 processing, the Office of Student Financial Services under the direction of the Director of Student Financial Services has taken and will continue the following actions: • Reinforce and update R2T4 procedures to clearly document regulatory timelines, roles, and responsibilities, and to include defined ongoing monitoring practices. These updated procedures incorporate periodic review of R2T4 activity to ensure continued compliance. • Enhance the existing internal tracking mechanism to support timely completion of R2T4 calculations and fund returns. This enhancement includes the ability to generate reports that identify upcoming deadlines, completed actions, and any items requiring follow-up. • Provide refresher training to staff within the Office of Student Financial Services and partner offices involved in R2T4 processing, with emphasis on compliance requirements, timelines, documentation standards, and shared accountability across offices. • Incorporate a secondary review process as part of the existing R2T4 procedure. A designated secondary reviewer within the Office of Student Financial Services will confirm the accuracy and timeliness of each R2T4 calculation and associated fund return, with completion of the review documented within the tracking system. These corrective actions will be implemented upon review and approval and will be effective beginning Spring 2026.

View Audit 384150

Finding 1170839 (2025-001)

Material Weakness 2025

Partners for Community Development, Inc.

WI

Questioned Costs Cash Management Significant Deficiency

The Organization will review the processes in place over unpaid invoices to ensure invoices are paid within 30 days of receipt.

View Audit 384137

Finding 1170833 (2025-001)

Material Weakness 2025

Laceleaf Corporation

OR

Questioned Costs Eligibility HUD Housing Programs

Management will monitor tenant recertifications to ensure that they are being completed in a timely manner. The following measures will be implemented: • Centralized tracking by the Housing Manager on a monthly basis to monitor the recertification timeline for each unit. This will include tracking t...

Management will monitor tenant recertifications to ensure that they are being completed in a timely manner. The following measures will be implemented: • Centralized tracking by the Housing Manager on a monthly basis to monitor the recertification timeline for each unit. This will include tracking the 120, 90, 60, and 30 day reminders to be sent to tenants in advance of the recertification effective dates. • Automated reminders will be provided on a monthly basis by the third party vendor that processes HAP billings to the Housing Manager and site managers, in order to ensure that they are aware of any recertification deadlines. • Additional training will be provided for all staff members involved in the recertification process.

View Audit 384123

Finding 1170824 (2025-001)

Material Weakness 2025

West Ohio Food Bank

OH

Questioned Costs Subrecipient Monitoring Eligibility

CFDA 10.565 Commodity Supplemental Food Program Name of Contact Person: Shelly Neeley, Program Specialist Corrective Action: Eligibility requirements regarding the Commodity Supplemental Food program (CSFP) are recognized by West Ohio Food Bank (WOFB) and WOFB continues making internal controls a to...

CFDA 10.565 Commodity Supplemental Food Program Name of Contact Person: Shelly Neeley, Program Specialist Corrective Action: Eligibility requirements regarding the Commodity Supplemental Food program (CSFP) are recognized by West Ohio Food Bank (WOFB) and WOFB continues making internal controls a top priority in the program’s operation. There are currently 1,800 applications processed through WOFB and 43 site locations for CSFP. These include those applicants on the active list and the wait list as well as those who may not qualify for the program. During the auditing process, there were 11 participants that did not have a current/updated application on file yet received a distribution. To ensure that all applications are renewed within a twelve-month period, and that the recipients without a valid application on file do not receive distributions until a valid, up-to-date application has been obtained, WOFB has begun to implement and will continue implementing the following internal control procedures. WOFB will continue to update/renew all applications each March to have all expiration dates within the same month each year. The master spreadsheet has also been updated to include parameters that will flag an upcoming expiration date. This will assist the senior sites in knowing more timely who needs a renewal application at their location. In addition, Pantry Trak/Fresh Trak is being updated and revised. I have been working closely with Mid-Ohio in revising the CSFP portion to better meet the needs of the program at WOFB. The ultimate goal is to use the Pantry Trak system to log and track all CSFP information electronically. This too will increase the accuracy of the data. As an additional audit of accuracy WOFB will conduct an internal audit monthly by randomly pulling a sampling of 3 percent (48) of the 1,600 CSFP recipients to verify the accuracy of the applications on file. Proposed Completion Date: The processes implemented will be ongoing. As the Pantry Trak program tool continues to improve its use for tracking and logging, use for CSFP will increase.

View Audit 384099

Finding 1170788 (2025-004)

Material Weakness 2025

Solen Public School District No. 3

ND

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.430

Contact Person David Drapeaux Corrective Action Plan This finding was resolved in FY2025 through a joint agreement between the District and NDDPI. The questioned costs of $86,171, that were discovered during a separate NDDPI monitoring process, were all returned to the state before the beginning of ...

Contact Person David Drapeaux Corrective Action Plan This finding was resolved in FY2025 through a joint agreement between the District and NDDPI. The questioned costs of $86,171, that were discovered during a separate NDDPI monitoring process, were all returned to the state before the beginning of the 2025 audit. This issue is resolved. Completion Date 05/08/25

View Audit 384048

Finding 1170762 (2025-001)

Material Weakness 2025

Metropolitan Community College

MO

Student Financial Aid Questioned Costs Special Tests & Provisions

Enrollment information was not submitted within the required timeframe by the College. Personnel Responsible for Corrective Action: Dena Norris, Associate Vice Chancellor of Student Financial Services, and Tara Dettmer, Director of Financial Aid – Fiscal Operations Anticipated Completion Date: Corre...

Enrollment information was not submitted within the required timeframe by the College. Personnel Responsible for Corrective Action: Dena Norris, Associate Vice Chancellor of Student Financial Services, and Tara Dettmer, Director of Financial Aid – Fiscal Operations Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2026. Views of Responsible Officials and Planned Corrective Action Plan: Despite best efforts by the College to correct the errors in enrollment reporting, the College experienced turnover among staff, and as a result, was unable to shift staffing resources or quickly hire replacement staff to correct the finding. Metropolitan Community College (MCC) is in the process of hiring additional staff dedicated to enrollment and compliance reporting. MCC will make a random selection of 10-15 students each month to verify data was correctly transmitted to National Student Clearinghouse (NSC). A secondary check of these students will be done to ensure the data is also transmitted to the National Student Loan Data System (NSLDS). MCC will also ensure error reports and other data issues are resolved in a timely manner to ensure reporting of students is completed within the regulatory timeframe. Due to the implementation of a new Enterprise Resource Planning system MCC is also validating and correcting any submission errors.

View Audit 383985

Finding 1170658 (2025-003)

Material Weakness 2025

Detroit Housing Commission

MI

HUD Housing Programs Questioned Costs Subrecipient Monitoring

Condition: The Commission did not submit the required financial and performance reports promptly. Planned Corrective Action: The Capital Team Project Manager continues to reconcile HUD’s EPIC and ELOCC systems with Yardi monthly to ensure timely filing of capital projects' closeouts. This tracking c...

Condition: The Commission did not submit the required financial and performance reports promptly. Planned Corrective Action: The Capital Team Project Manager continues to reconcile HUD’s EPIC and ELOCC systems with Yardi monthly to ensure timely filing of capital projects' closeouts. This tracking critical spreadsheet, created by the Lead Performance Officer, will trigger key reporting dates for the DHC Capital Fund Program to remain in compliance with HUD reporting deadlines. At a minimum, monthly, this critical spreadsheet is distributed to the Supervisor of Capital and the Lead Performance Officer to ensure compliance. However, this was on the radar and continues the process of cleaning older items for corporate hygiene. As of December 2025, this was closed out and approved in EPIC by HUD. Contact person responsible for corrective action: Michael Edwards, Capital Asset & Skilled Trades Supervisor Anticipated Completion Date: 12/31/2025

View Audit 383877

Finding 1170657 (2025-002)

Material Weakness 2025

Detroit Housing Commission

MI

Subrecipient Monitoring HUD Housing Programs Questioned Costs

Condition: The Commission did not complete fiscal year 2025 recertifications. Planned Corrective Action: Staff have been retrained on the compliance requirements under the standards of the HCV Program through the oversight of the Rental Assistance Department Manager and Continued Occupancy Superviso...

Condition: The Commission did not complete fiscal year 2025 recertifications. Planned Corrective Action: Staff have been retrained on the compliance requirements under the standards of the HCV Program through the oversight of the Rental Assistance Department Manager and Continued Occupancy Supervisor. The Department Manager and Supervisor continue to utilize all Yardi monitoring reports to ensure the Department is operating in accordance with industry standards. Reporting is be done and monitored monthly to meet set goals. Weekly, Department Manager has review the certification pipeline to ensure compliance and follow up with the Housing Specialist to ensure compliance and meeting set weekly and monthly goals and metrics. We continue to work in accordance with HUD rules and regulations where Annual Recertification processes are concerned. Per HUD communication provided to us, as of June 30, 2025, HCV is 100% compliant with HUD recertification requirements. Contact person responsible for corrective action: Felicia Burris, HCV Program Manager Anticipated Completion Date: 7/1/2025

View Audit 383877

Corrective Action Plans

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