Corrective Action Plans

Finding 1191579 (2025-001)

Material Weakness 2025

OR

Reporting § 200.303 § 200.502 § 200.510

2025-001: Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Educational Stabilization Fund ASSISTANCE LISTING Numbers: 84.425C – Governor’s Emergency Education Relief Fund 84.425R – Emergency Assistance to Non-Public Schools 84.425U – Elementary and Secondary S...

2025-001: Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Educational Stabilization Fund ASSISTANCE LISTING Numbers: 84.425C – Governor’s Emergency Education Relief Fund 84.425R – Emergency Assistance to Non-Public Schools 84.425U – Elementary and Secondary School Emergency Relief Fund 84.425V – Emergency Assistance to Non-Public Schools Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Recommendation: We recommend that the University evaluate its cutoff procedures to ensure that federal costs are identified and reported in the correct fiscal year. We also recommend that the University evaluate its internal controls to ensure that federal awards are properly identified as such at inception. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OSU is implementing a campus-wide Administrative Modernization Program (AMP) to update technology, improve efficiencies, and ensure a comprehensive internal control environment. This modernization includes redesigning the university’s administrative and grant processes, including budget development, payroll lifecycle, employee recruitment, grant effort reporting, procurement, and others. A primary aspect of this optimization is a transition of the university’s enterprise resource planning (ERP) system from Banner to Workday effective July 1, 2026. To reflect this system transition, OSU’s actions in response to the finding will be taken in two stages: 1. For FY26, the Division of Research and Innovation (DRI) will run reports and screen for anomalies and mismatches of revenue type and fund type to identify awards with the correct federal fund when a federal program is identified with an ALN#. The screening will take place before the fiscal year end, allowing time for corrections to be made in Banner while the fiscal year is still active. 2. For FY27 and beyond, rather than a warning, critical custom validations will be required and established in Workday as follows: • Any award that uses an ALN# also must include the appropriate Fund and Revenue Category worktags on the award line • Any award with a federal sponsor or federal prime sponsor must have ALN# entered • Any award with a federal sponsor or federal prime sponsor must include the appropriate Fund and Revenue Category worktag on the award line Name of the contact person responsible for corrective action: Jennifer Creighton, Associate Vice President for Research Administration, Finance and Operations Planned completion date for corrective action plan: Corrective action to screen for anomalies and mismatches of revenue type and fund type in Banner to ensure awards are identified with the correct federal fund will occur by June 30, 2026. The establishment of custom validations in Workday to ensure identification of federal awards will occur and be ongoing with the new system implementation after July 1, 2026.

View Audit 395445

Finding 1191569 (2025-007)

Material Weakness 2025

PROJECT WORTHMORE

CO

Reporting § 200.510

Management will strengthen SEFA preparation and review procedures to ensure federal expenditures are complete, accurate, and properly reported in accordance with 2 CFR 200.510(b). • Reconciliation: Reconcile SEFA totals to the general ledger and grant-level records and resolve discrepancies. • Manag...

Management will strengthen SEFA preparation and review procedures to ensure federal expenditures are complete, accurate, and properly reported in accordance with 2 CFR 200.510(b). • Reconciliation: Reconcile SEFA totals to the general ledger and grant-level records and resolve discrepancies. • Management Review: Implement documented management review of the SEFA for completeness and accuracy prior to issuance.

View Audit 395436

Finding 1191568 (2025-006)

Material Weakness 2025

PROJECT WORTHMORE

CO

Internal Control / Segregation of Duties Questioned Costs HUD Housing Programs § 200.303

Management will implement a formal review and approval process for Federal reporting to ensure compliance with 2 CFR 200.303. • Review Process: Establish standardized procedures for preparation, review, and submission of Federal reports. • Roles and Responsibilities: Assign responsibility for prepar...

Management will implement a formal review and approval process for Federal reporting to ensure compliance with 2 CFR 200.303. • Review Process: Establish standardized procedures for preparation, review, and submission of Federal reports. • Roles and Responsibilities: Assign responsibility for preparation and independent review of reports. • Documented Approval: Require documented evidence of review and approval. • Supporting Documentation: Ensure all reported amounts are supported by underlying records and reconciliations. • Training: Prior to next Federal Grant requiring a single audit, provide training on Federal reporting requirements and internal control expectations.

View Audit 395436

Finding 1191566 (2025-002)

Material Weakness 2025

Tasc, Inc.

IL

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.309

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND OTHER MATTERS U.S. Department of Justice 2025-002 Department of Justice Second Chance Act Community-based Reentry Program – Assistance Listing No. 16.812 Recommendation: We recommend that TASC follow its established procedures for chargi...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND OTHER MATTERS U.S. Department of Justice 2025-002 Department of Justice Second Chance Act Community-based Reentry Program – Assistance Listing No. 16.812 Recommendation: We recommend that TASC follow its established procedures for charging allowable expenses to the grant during the period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will follow established procedure to make sure costs are recorded in the proper period. Management will review the procedure with all accounting staff. Name(s) of the contact person(s) responsible for corrective action: Roy Fesmire, CFO Planned completion date for corrective action plan: June 30, 2026

View Audit 395434

Finding 1191554 (2025-008)

Material Weakness 2025

Leech Lake Tribal College

AZ

Questioned Costs Student Financial Aid Eligibility

Annual performance reports will be submitted on time as required by the funding agency. Management has developed a comprehensive listing of all reporting requirements and will utilize this information to ensure all reporting requirements are met.

View Audit 395432

Finding 1191550 (2025-006)

Material Weakness 2025

Leech Lake Tribal College

AZ

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.328

Annual performance reports will be submitted on time as required by the funding agency. Management has developed a comprehensive listing of all reporting requirements and will utilize this information to ensure all reporting requirements are met.

View Audit 395432

Finding 1191530 (2025-009)

Material Weakness 2025

City of Montgomery, Alabama

AL

Questioned Costs Subrecipient Monitoring Material Weakness § 200.303 § 200.328

Management concurs. The City will strengthen its policies and procedures over the grant reporting process to ensure that the review and approval of federal reports is documented. This will be implemented by September 2026.

View Audit 395426

Finding 1191504 (2025-001)

Material Weakness 2025

Housing Authority of the City of Annapolis

MD

HUD Housing Programs Special Tests & Provisions Eligibility

Corrective Action Plan: The Authority acknowledges the finding. Corrective actions to address the deficiencies are underway and include: Updating internal policies and procedures related to Housing Choice Voucher (HCV) program compliance, including tenant eligibility, income verification, rent reaso...

Corrective Action Plan: The Authority acknowledges the finding. Corrective actions to address the deficiencies are underway and include: Updating internal policies and procedures related to Housing Choice Voucher (HCV) program compliance, including tenant eligibility, income verification, rent reasonableness, utility allowance calculations, and documentation requirements; Providing targeted staff training on HUD HCV program requirements, including proper file documentation, income calculation, and timely completion of annual and interim recertifications; Implementing a mandatory file checklist to ensure all required documentation is obtained, reviewed, and verified prior to finalizing tenant certifications and rent determinations; Establishing a formal quality control process in which supervisory staff perform periodic file reviews to ensure compliance with HUD requirements and internal policies; Conducting a comprehensive review and cleanup of all HCV tenant files to identify and correct missing or incomplete documentation, including income verification, inspections, and rent calculations; Maintaining an audit trail of all verification documentation to ensure proper retention and support for tenant eligibility and rent determinations; Implementing tracking tools and system reports to monitor recertification due dates, inspection schedules, and file completion status to ensure timely compliance; Continuing engagement with third-party service provider, Quadel, to assist with tenant file documentation compliance, backlog recertifications, and rent calculation accuracy; Hiring and/or assigning additional staff, including HCV program leadership and specialists, to strengthen oversight, ensure timely processing of recertifications, and maintain compliance with HUD requirements.

View Audit 395422

Finding 1191503 (2025-003)

Material Weakness 2025

Western Illinois University

IL

Subrecipient Monitoring Cash Management Reporting § 200.303 § 200.305

Finding Number: 2025-003 - Inadequate Internal Control over Subrecipient Payments Condition: Western Illinois University (University) did not have adequate procedures in place to complete a timely disbursement of requested pass-through funds to subrecipients within the required time period. Planned ...

Finding Number: 2025-003 - Inadequate Internal Control over Subrecipient Payments Condition: Western Illinois University (University) did not have adequate procedures in place to complete a timely disbursement of requested pass-through funds to subrecipients within the required time period. Planned Corrective Action: The University is committed to developing a comprehensive plan to ensure compliance with payment of pass-through funds policies and procedures. Contact person responsible for corrective action: Mary Pat Wolhford Anticipated Completion Date: 06/30/2026

View Audit 395418

Finding 1191494 (2025-001)

Material Weakness 2025

Western Illinois University

IL

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

Finding Number: 2025-001 - Inadequate Internal Control over Student Enrollment Reporting Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. Planned Corrective Action: The University is implementing...

Finding Number: 2025-001 - Inadequate Internal Control over Student Enrollment Reporting Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. Planned Corrective Action: The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported. Contact person responsible for corrective action: Roberta Smith/Sarah Lawson Anticipated Completion Date: 06/30/2027

View Audit 395418

Finding 1191481 (2025-003)

Material Weakness 2025

Housing Authority of the City of Westwego, Louisiana

LA

Reporting Questioned Costs HUD Housing Programs § 200.303 § 200.516

FINDING 2025 003 — MATERIAL WEAKNESS (INTERNAL CONTROL OVER COMPLIANCE) — GRANT ACCOUNTING AND CLOSE PROCESS AFFECTING MAJOR FEDERAL PROGRAMS — (PROGRAMS: ALN 14.872 AND ALN 97.036) Cross reference: This finding is directly related to Financial Statement Finding 2025 001. Contact Person: Cantrese Wi...

FINDING 2025 003 — MATERIAL WEAKNESS (INTERNAL CONTROL OVER COMPLIANCE) — GRANT ACCOUNTING AND CLOSE PROCESS AFFECTING MAJOR FEDERAL PROGRAMS — (PROGRAMS: ALN 14.872 AND ALN 97.036) Cross reference: This finding is directly related to Financial Statement Finding 2025 001. Contact Person: Cantrese Wilson Jones, Executive Director Corrective Action Planned: Corrective actions for this compliance finding will be addressed through the same improvements outlined in Finding 2025 001, including: 1. Adoption of a documented monthly and year end closing calendar. 2. Timely reconciliation of all grant related accounts. 3. Enhanced supervisory review and documentation of compliance related reporting, including SEFA preparation. 4. Strengthening internal controls to ensure grant activity is recorded in the proper period. Anticipated Completion Date: June 30, 2026 Management Response: Management concurs with the finding and will implement the corrective measures beginning FY 2026.

View Audit 395397

Finding 1191480 (2025-002)

Material Weakness 2025

Housing Authority of the City of Westwego, Louisiana

LA

Procurement, Suspension & Debarment Cash Management Reporting

FINDING 2025 002 — SIGNIFICANT DEFICIENCY — UNIQUE ENTITY IDENTIFIER (UEI) DISCREPANCY Contact Person: Cantrese Wilson Jones, Executive Director Corrective Action Planned: The Authority will continue coordinating with SAM.gov/GSA to correct the mismatch between the UEI and the legal entity name. Per...

FINDING 2025 002 — SIGNIFICANT DEFICIENCY — UNIQUE ENTITY IDENTIFIER (UEI) DISCREPANCY Contact Person: Cantrese Wilson Jones, Executive Director Corrective Action Planned: The Authority will continue coordinating with SAM.gov/GSA to correct the mismatch between the UEI and the legal entity name. Periodic verification procedures will be implemented to ensure UEI information remains accurate across federal systems. Management will maintain correspondence records with the federal service desk until the issue is fully resolved. Anticipated Completion Date: This matter is dependent on federal agency processing timelines; however, the Authority anticipates completion by September 30, 2026, subject to SAM.gov/GSA resolution. Management Response: Management acknowledges the repeat issue and remains actively engaged with SAM.gov/GSA to finalize the correction.

View Audit 395397

Finding 1191479 (2025-001)

Material Weakness 2025

Housing Authority of the City of Westwego, Louisiana

LA

Material Weakness Reporting Internal Control / Segregation of Duties

FINDING 2025 001 — MATERIAL WEAKNESS — CONTROLS OVER GRANT ACCOUNTING, YEAR END CLOSING, AND FINANCIAL REPORTING Contact Person: Cantrese Wilson Jones, Executive Director Corrective Action Planned: The Housing Authority will implement a formal, documented monthly and year end closing calendar that i...

FINDING 2025 001 — MATERIAL WEAKNESS — CONTROLS OVER GRANT ACCOUNTING, YEAR END CLOSING, AND FINANCIAL REPORTING Contact Person: Cantrese Wilson Jones, Executive Director Corrective Action Planned: The Housing Authority will implement a formal, documented monthly and year end closing calendar that includes required reconciliation deadlines, supervisory review steps, and documentation standards. Grant activity will be reconciled monthly, and financial reporting schedules will be completed prior to auditor arrival. Internal review procedures will be strengthened to ensure the timeliness and accuracy of journal entries, reconciliations, and SEFA related information. Anticipated Completion Date: June 30, 2026 Management Response: Management concurs with the finding. The Authority will implement a structured closing calendar and improve grant related reconciliations beginning in FY 2026.

View Audit 395397

Finding 1191477 (2025-005)

Material Weakness 2025

Montcalm Community College

MI

Student Financial Aid Questioned Costs Special Tests & Provisions

Student Credit Balance Exceeding Fourteen Days Auditor Description of Condition and Effect. During our testing, we identified one instance in which a student’s credit balance remained outstanding beyond the required 14‑day timeframe. As a result of this condition, the College was not in compliance w...

Student Credit Balance Exceeding Fourteen Days Auditor Description of Condition and Effect. During our testing, we identified one instance in which a student’s credit balance remained outstanding beyond the required 14‑day timeframe. As a result of this condition, the College was not in compliance with the Uniform Guidance requirements governing the timely disbursement of student credit balances. Auditor Recommendation. We recommend the College implement procedures to ensure all voided refunds are reviewed and resolved within the fourteen day period to ensure there are no credit balances that are unaddressed. Corrective Action. The College is strengthening its procedures to ensure student credit balances are processed, refunded, or returned within the federally required 14‑day timeframe. When a student requests a stop payment, hold, or void, the student must now email both the Business Office and Financial Aid Office from their official MCC student email account. Requests must include the type of action needed and the reason for it. The Directors of Accounting and Financial Aid, or designated authorized personnel, review and approve each request before any action is taken. The Business Office then issues the stop payment, hold, or void in accordance with internal procedures, while Financial Aid returns funds to the appropriate agency when applicable. For internal staff‑initiated stop or void actions, employees must email the Directors with justification explaining why the request is being initiated by staff rather than the student. Both offices collaborate to determine appropriate action, ensure the disbursement is adjusted, coordinate the timing of any required return of funds, and communicate updates to the student. These procedures ensure all credit balance transactions are processed within the 14‑day limit and are documented consistently to maintain federal compliance. Responsible Person. Scott Kemmer-Slater, Director of Accounting and Jennifer Simson, Director of Financial Aid, jointly. Anticipated Completion Date. June 30, 2026

View Audit 395393

Finding 1191467 (2025-003)

Material Weakness 2025

Montcalm Community College

MI

Questioned Costs Student Financial Aid Reporting

Fiscal Operations Report and Application to Participate (FISAP) Reporting Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items (information on eligible aid applicants) identified in the com...

Fiscal Operations Report and Application to Participate (FISAP) Reporting Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items (information on eligible aid applicants) identified in the compliance supplement as critical information. As a result, the College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Auditor Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. Corrective Action. The College is improving its documentation and retention processes to ensure all information used in preparing the annual FISAP report is fully supported and available for review. Moving forward, all data underlying the eight key line items identified in the compliance supplement will be saved, documented, and stored in a consistent and accessible manner. Information obtained from other departments will be retained in its original format, and any data extracted from PowerFAIDS or related systems will be saved at the time of report preparation. By implementing these documentation and retention procedures as standard operating practice, the College ensures FISAP submissions are accurate, verifiable, and compliant with federal audit requirements. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026

View Audit 395393

Finding 1191462 (2025-002)

Material Weakness 2025

Montcalm Community College

MI

Eligibility Questioned Costs Student Financial Aid

Ineligible Student Received Title IV Funding Auditor Description of Condition and Effect. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed...

Ineligible Student Received Title IV Funding Auditor Description of Condition and Effect. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed both attempted courses. Despite the lack of demonstrated academic improvement following the appeal, the student was awarded Title IV funding in the Spring 2024–2025 semester based on the appeal granted during the 2022–2023 academic year. As a result of this condition, one student received Title IV funding that who was not eligible based on the criteria outlined in the College's satisfactory academic policy (SAP). Auditor Recommendation. We recommend the College implement a formal review process to verify that students who were previously dismissed and granted an appeal in a prior academic year have demonstrated the required academic improvement before receiving subsequent Title IV funding, or alternatively, obtain a new appeal determination. Corrective Action. Management acknowledges this finding and is implementing strengthened Satisfactory Academic Progress (SAP) review procedures to ensure students who previously appealed an academic dismissal are properly evaluated before receiving Title IV funding. The Financial Aid Office is now working closely with the Registrar to ensure both Title‑IV and non‑Title‑IV students undergo appropriate SAP monitoring. Information Technology is developing a report that identifies students by financial‑aid track status, allowing Financial Aid to review aid‑receiving students while the Registrar evaluates all others. Students who require SAP follow‑up are contacted by the appropriate office, and SAP appeal forms are reviewed under updated criteria to ensure students demonstrate academic improvement before additional aid is awarded. These steps ensure the College remains compliant with federal SAP requirements and prevents ineligible students from receiving Title IV funds. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026

View Audit 395393

Finding 1191457 (2025-003)

Material Weakness 2025

Metro Technology Center

OK

Student Financial Aid Reporting

Finding 2025-003 Finding Summary: Some discrepancies were noted between the District and NSLDS. One student's data was not updated within the allowable time period. Responsible Individuals: Melissa Thornton, Financial Aid Manager Corrective Action Plan: We have worked within the department to ensure...

Finding 2025-003 Finding Summary: Some discrepancies were noted between the District and NSLDS. One student's data was not updated within the allowable time period. Responsible Individuals: Melissa Thornton, Financial Aid Manager Corrective Action Plan: We have worked within the department to ensure proper reporting on the financial aid systems. Anticipated Completion Date: July 1, 2026

View Audit 395391

Finding 1191374 (2025-005)

Material Weakness 2025

Langston University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness § 200.303

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal...

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal TEACH Grant Program – Assistance Listing No. 84.379 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement additional procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2022 audit report in November 2023. While procedures had previously been implemented to address this issue, additional measures are being taken to ensure full compliance. The University will implement additional udates to its NSLDS reporting processes to ensure needed submissions are reported timely and accurately. Respective staff will receive additional training to ensure proper reporting to NSLDS occurs. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid; Mr. Heath Burge, Assistant Vice President for Strategic Enrollment and Advising Services; and Mrs. Jeanese Outlaw-Gunter, University Registrar Planned completion date for corrective action plan: April 2026

View Audit 395389

Finding 1191223 (2025-002)

Material Weakness 2025

University of Pikeville

KY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR 685.309(b). Condition: During our testing of 40 students for NSLDS enrollment, we noted eight...

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR 685.309(b). Condition: During our testing of 40 students for NSLDS enrollment, we noted eight students' enrollment effective date was the commencement date instead of the last day of the term. One student's graduation status was not reported to the NSLDS and one student's graduation was not certified to the NSLDS within the 60-day requirement. Cause: The University did not have controls in place to ensure students' classification were being properly reported to the NSLDS or reported in a timely manner. Effect: There were ten student status changes that were either not reported, not reported accurately, or not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus, students were subsequently not placed into loan repayment status in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to the NSLDS. In addition, we recommend that the University submit roster files on a regular basis. Corrective Actions Taken or Planned: We agree with this finding and recommendation. The Director of Institutional Research will report the last day of the term for NSLDS reporting. Responsible Parties: Margaret Sidle, Director of Institutional research Completion Date: March 4, 2026

View Audit 395369

Finding 1191222 (2025-001)

Material Weakness 2025

University of Pikeville

KY

Student Financial Aid Reporting

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.22(a). Condition: During our testing of six official withdrawals, we noted one instance where the U...

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.22(a). Condition: During our testing of six official withdrawals, we noted one instance where the University incorrectly treated a student as withdrawn for Return of Title IV (R2T4) purposes. The student was enrolled in both modules for the Fall term, earned six credit hours in the first module and subsequently withdrew during the second module. The University reported the student as withdrawn to the National Student Loan Data System (NSLDS) and performed a R2T4 calculation using the total days of both modules in the denominator of the R2T4 calculation. However, since the student successfully completed six credit hours in the first module, which exceeds the coursework required for the University's definition of half time enrollment, the student should not have been classified as withdrawn nor had a R2T4 calculation performed. Upon further analysis from management, there were an additional five students that were enrolled in modules, earning half-time enrollment, who were reported as withdrawn to the NSLDS and a R2T4 calculation was erroneously completed for them. Cause: This error occurred due to inadequate internal controls over identifying withdrawal status for students enrolled in module courses, specifically related to assessing whether completed coursework met or exceeded the half-time enrollment threshold prior to performing an R2T4 calculation or reporting them as withdrawn to the NSLDS. Effect: The provisions of 34 CFR 668.22(a) were not followed and thus a total of six students had a R2T4 calculation erroneously performed. Six students were also erroneously reported as withdrawn to the NSLDS. Questioned Costs: There were no questioned costs associated with this finding Recommendation: We recommend that the University strengthen its internal controls related to R2T4 calculations by: (a) implementing a system control to evaluate whether or not completed module coursework meets the half-time threshold before classifying a student as withdrawn, (b) providing additional training to financial aid staff on withdrawal determinations and performing an R2T4 calculation for students enrolled in modules, and (c) performing a supervisory review of all R2T4 calculations related to module students. Corrective Actions Taken or Planned: We agree with this finding and recommendation. After further review of R2T4 rules for module programs, the University of Pikeville will no longer perform R2T4’s on any student that has met the Exemption rules per FSA handbook, Vol 5, Chapter 1, “R2T4 Withdrawal Exemptions”. Responsible Parties: Daniel Donner, Director of Financial Aid Completion Date: March 4, 2026

View Audit 395369

Finding 1191215 (2025-002)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Reporting Internal Control / Segregation of Duties § 200.510

Finding Reference 2025-02 Corrective Action Plan: The Designated Office responsible for processing federal funds received through state agencies will deliver to the Finance Office a transaction list and a reconciliation of the disbursements made during the fiscal year. The Finance Office will review...

Finding Reference 2025-02 Corrective Action Plan: The Designated Office responsible for processing federal funds received through state agencies will deliver to the Finance Office a transaction list and a reconciliation of the disbursements made during the fiscal year. The Finance Office will review all transactions recorded during the current fiscal year and will prepare an accrual entry. These transactions will be reconciled against the transactions recorded during the subsequent fiscal year to confirm that funds were recorded in the appropriate fiscal period. The review and recording of these transactions will be completed during the final phase of the accounting closing process and prior to delivery of the Trial Balance to the external auditors. Responsible: Ms. Maria Del R. Ramos Ocasio, Accounting and Finance Manager Planned Implementation Date: In process. Expected to be completed on or before September 30, 2026.

View Audit 395336

Finding 1191208 (2025-002)

Material Weakness 2025

Concordia University Chicago

IL

Questioned Costs Student Financial Aid Reporting

2025-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with au...

2025-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) All enrollment reporting was submitted to the National Student Clearinghouse in a timely manner. The delay occurred during the National Student Clearinghouse’s processing and submission to NSLDS. 2) The Office of the Registrar will work with the Office of Financial Aid to learn more about NSLDS compliance requirements and gain a better understanding of their relationship with the National Student Clearinghouse. 3) The Office of the Registrar will work with the National Student Clearinghouse to confirm the submitted reporting schedule for academic year 2026 – 2027 complies with and meets their expectations and will adjust (if needed). 4) The Office of the Registrar will continue to work with the Enrollment Offices to remind them that students who are not enrolled (and not on leave of absence, graduated, and/or deceased) must be marked as withdrawn based on external reporting compliance requirements. 5) The Office of the Registrar continues to work with IT (Banner Team) to improve reporting to capture students who are not enrolled (and not on leave of absence, graduated, and/or deceased) to be marked as withdrawn to comply with the National Student Clearinghouse and NSLDS compliance reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Ingrid Sorensen, Katarzyna Rodriguez Planned completion date for corrective action plan: June 30, 2026

View Audit 395330

Finding 1191196 (2025-001)

Material Weakness 2025

South Suburban College - Community College District #510

IL

Student Financial Aid Reporting

Finding 2025-001: Controls and Noncompliance Over Reporting - Pell Common Origination and Disbursement; Fiscal Operations Report and Application to Participate Management's Response: The College acknowledges this finding and has implemented the corrective actions outlined below to reinforce establis...

Finding 2025-001: Controls and Noncompliance Over Reporting - Pell Common Origination and Disbursement; Fiscal Operations Report and Application to Participate Management's Response: The College acknowledges this finding and has implemented the corrective actions outlined below to reinforce established policies and procedures. This will ensure the institution submits disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within the required 15-day timeframe. Corrective Action Plan: 1. Control Process South Suburban College has established an internal control process to ensure that all records are submitted in a timely manner. The Financial Aid Director and Manager now have access to be promptly notified of updates the Colleague software system. Notifications were previously accessible only to the IT Department. 2. System Upgrade South Suburban College is in the process of transitioning to new software by March 2026. Once the new software is in place, the South Suburban College ‘s IT department may no longer need to update the Colleague system to support the submission of Pell Grant disbursements. The transition to the new system is expected to streamline the process and improve reporting accuracy with automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual. 3. Ongoing Monitoring and Training Regular system audits will continue to be conducted to ensure that personnel are well-informed and that policies are consistently followed. The retaining of documentation to support amounts within the FISAP has been implemented. The Financial Aid Department will also continue to monitor the COD site for compliance and address any discrepancies promptly. Anticipated Date of Completion Note the audit found the error to be remedied as of Spring 2025. However, with these corrective actions, South Suburban College is committed to ensuring that Pell Grant disbursements are reported accurately and submitted in compliance with federal regulations within the specified 15-day window. Name of Contact Person: Yolanda Freemon Director of Financial Aid yfreemon@ssc.edu ext.5845

View Audit 395329

Finding 1191192 (2025-003)

Material Weakness 2025

Unified School District No. 321

KS

Reporting § 200.502

2025-003 Prparation of and internal controls over SEFA preparation (Material Weakness). Federal Agency: U.S. Department of Education. Program Name: Child Nutrition Cluster; Education Stabilization Fund. Assisstance Listing Number: 10.553,10.555, 10.559; 84.425. Award Period: June 30, 2025. RECOMMEND...

2025-003 Prparation of and internal controls over SEFA preparation (Material Weakness). Federal Agency: U.S. Department of Education. Program Name: Child Nutrition Cluster; Education Stabilization Fund. Assisstance Listing Number: 10.553,10.555, 10.559; 84.425. Award Period: June 30, 2025. RECOMMENDATION: The Board of Education and managment shoudl review the financial reporting process. Once this review is cimplete, the District should then perform a risk assessment to determine the best way to implement appropriate intnernal controls over financial reporting to ensure that the District prepares the schedule in conformity with Uniform Guidance. Action Taken (unauditied): managment plans to have the Board Clerk and the Board Treasurer complete the Schedule of Expenditures together and to ensure that the correct expenses are being reported.

View Audit 395323

Finding 1191187 (2025-004)

Material Weakness 2025

Eastern Michigan University

MI

Reporting

Condition: Federal programs must be grouped into clusters only when specifically designated by the Office of Management and Budget (OMB). Planned Corrective Action: Additional review procedures have been implemented to prevent SEFA classification errors. Specifically, the Sponsored Research Accounti...

Condition: Federal programs must be grouped into clusters only when specifically designated by the Office of Management and Budget (OMB). Planned Corrective Action: Additional review procedures have been implemented to prevent SEFA classification errors. Specifically, the Sponsored Research Accounting Manager now conducts a detailed review of the award documentation prior to SEFA categorization. Furthermore, a verification step has been added to the grant set-up checklist, performed by Sponsored Research Accounting staff, to ensure accurate classification of all awards prior to inclusion in SEFA reporting. Contact person responsible for corrective action: Joel Clendenin, Grants Manager Anticipated Completion Date: 6/30/2026

View Audit 395317

Corrective Action Plans

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