Corrective Action Plans

Finding 1227585 (2025-008)

Material Weakness 2025

IL

HUD Housing Programs Subrecipient Monitoring Material Weakness § 200.303

Condition: Controls were not designed or implemented effectively to ensure: 1. Mortgage and escrow payments were made in accordance with the due dates and amounts specified in the executed mortgage note agreement. 2. Earnings are retained in the replacement reserve account 3. The Organization comple...

Condition: Controls were not designed or implemented effectively to ensure: 1. Mortgage and escrow payments were made in accordance with the due dates and amounts specified in the executed mortgage note agreement. 2. Earnings are retained in the replacement reserve account 3. The Organization completes the required financial reports in accordance with the applicable accounting basis, supported by underlying records representing the activity for the period reported. Planned Corrective Action: Management will design and implement internal controls to ensure compliance with mortgage escrow payments, reserve account funding, and quarterly financial reporting requirements, including a process to ensure that documentation of reviews is retained. Contact person responsible for corrective action: Louise Arzu, Vice President, Finance Anticipated Completion Date: 9/30/2026

View Audit 409598

Finding 1227584 (2025-007)

Material Weakness 2025

Humboldt Park Health, Inc.

IL

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Condition: The Organization did not submit the budget to HUD within 30 days of the start of its fiscal year. Planned Corrective Action: Management has implemented a new review and oversight process related to the process for the budget submissions in question to ensure timely submission on a go-forw...

Condition: The Organization did not submit the budget to HUD within 30 days of the start of its fiscal year. Planned Corrective Action: Management has implemented a new review and oversight process related to the process for the budget submissions in question to ensure timely submission on a go-forward basis. Contact person responsible for corrective action: Louise Arzu, Vice President, Finance Anticipated Completion Date: 9/30/2026

View Audit 409598

Finding 1227583 (2025-002)

Material Weakness 2025

Dubois County

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.1 § 200.303

FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Sandra L Morton Contact Phone Number and Email Address: 812-481-7000 slmorton@duboiscountyin.org Views of Responsible Officials: We disagree wi...

FINDING 2025-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Sandra L Morton Contact Phone Number and Email Address: 812-481-7000 slmorton@duboiscountyin.org Views of Responsible Officials: We disagree with the finding that the 2025 Annual P & E report current obligations were overstated by $8,300,967, which was the amount of cumulative obligations. Explanation and Reasons for Disagreement: We do not believe there was a systemic lack of effective internal controls or noncompliance throughout the audit period. We determined that the funds were fully obligated and reported the amount based on that interpretation, as was done on the previous reports submitted.

View Audit 409595

Finding 1227581 (2025-005)

Material Weakness 2025

Lemoyne-Owen College

TN

Student Financial Aid Subrecipient Monitoring Cash Management

Finding 2025-005 - Untimely Release of Title IV Credit Balances (Significant Deficiency): Condition - During testing of student account activity, we identified that fourteen (14) out of sixty (60) sampled students had Title IV created credit balances that remained on their accounts for more than 14 ...

Finding 2025-005 - Untimely Release of Title IV Credit Balances (Significant Deficiency): Condition - During testing of student account activity, we identified that fourteen (14) out of sixty (60) sampled students had Title IV created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. All refunds were eventually released to the students. Corrertive Action Plan The College experienced significant staff turnover within the business office. In addition, the College is undergoing conversion to a new Enterprise Resource Planning (ERP) system which affected its ability to complete some functions within a timely manner. A new bursar was hired in May 2026. Timely processing of student refunds was emphasized during her training. Going forward, student refunds will be released within 14 days after credit balances are reflected on student accounts." Completion Date - September 30, 2026 Responsible Party - Chief Financial Officer

View Audit 409592

Finding 1227571 (2025-001)

Material Weakness 2025

Association of University Technology Managers, Inc.

DC

Material Weakness Reporting Internal Control / Segregation of Duties

July 28, 2026 U.S. Department of Commerce 1401 Constitution Ave., NW Washington, D.C. 20230 Association of University Technology Managers, Inc. (the Association) and its affiliate AUTM Foundation, Inc. (the Foundation, and collectively, the Organization) respectfully submit the following corrective ...

July 28, 2026 U.S. Department of Commerce 1401 Constitution Ave., NW Washington, D.C. 20230 Association of University Technology Managers, Inc. (the Association) and its affiliate AUTM Foundation, Inc. (the Foundation, and collectively, the Organization) respectfully submit the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Blue & Company, LLC 250 West Main Street, Suite 2900 Lexington, Kentucky 40507 The finding from the schedule of findings and questioned costs (the Schedule) for the year ended December 31, 2025 is discussed below and is numbered consistently with the number assigned in the Schedule. Identifying Number: 2025-001 Finding: Material weakness related to consolidation of affiliate. In previous years the Association did not consolidate the assets, liabilities, net assets, revenues, and expenses of the Foundation with the financials of the Association. This was incorrect because, under Accounting Standards Codification (ASC) 958-810, the Association has a controlling financial interest in the Foundation—as its sole corporate member, with authority to appoint and remove all of the Foundation’s trustees—and an economic interest in the Foundation, so consolidation is required. The 2025 consolidated financial statements correct this, including a restatement of the beginning balance of net assets. Corrective Actions Taken or Planned: The issue occurred due to a misunderstanding of GAAP rules related to affiliated entities. Previously, management’s understanding was that common board members were the primary consideration for consolidation. The Organization has (1) consolidated the Foundation effective for the year ended December 31, 2025, with beginning net assets restated and intercompany balances eliminated; and (2) will implement a documented annual affiliated-entity assessment, performed as part of the year-end close, under which finance evaluates each related or affiliated entity against the ASC 958-810 criteria—controlling financial interest and economic interest—to determine whether consolidation is required. The assessment will be documented, reviewed and approved by the Senior Director of Finance, and reported to the Audit Committee. At this time, the Organization has no affiliated entity other than the Foundation, whose consolidation will be re-confirmed under this control each year. Estimated Completion Date: The correction is complete with the issuance of the 2025 consolidated financial statements; the recurring annual control is effective beginning with the December 31, 2026 year-end close. Responsible Personnel: Cody Embry, Senior Director of Finance, with oversight by the Audit Committee of the Board of Directors. If you have any questions or would like any additional information regarding these matters, please let us know and we will be happy to provide. Sincerely, L. Cody Embry, CPA Senior Director of Finance

View Audit 409589

Finding 1227566 (2025-001)

Material Weakness 2025

Association to Benefit Children

NY

Reporting Internal Control / Segregation of Duties

Finding Number:2025-001 Reporting – Noncompliance (Control Deficiency) Programs:U.S. Department of Health and Human Services, Head Start Cluster. Award Listing Number 93.600. Planned Corrective Action: Association to Benefit Children (ABC) acknowledges that the 2025 data collection form was not file...

Finding Number:2025-001 Reporting – Noncompliance (Control Deficiency) Programs:U.S. Department of Health and Human Services, Head Start Cluster. Award Listing Number 93.600. Planned Corrective Action: Association to Benefit Children (ABC) acknowledges that the 2025 data collection form was not filed timely. The planned correction plan is to file the 2025 data collection form upon the issuance of the Uniform Guidance financial statements and ensure that future data collection forms are filed timely. Person Responsible: Matthew Manger, Chief Financial Officer Expected Completion Date: August 2026

View Audit 409577

Finding 1227565 (2025-005)

Material Weakness 2025

Pojoaque Valley School District

NM

Reporting

Management concurred with the recommendation. The district will request an earlier start date for the audit and will work towards compiling all documentation needed for a timely audit. Responsible party : Michelle Ortiz

View Audit 409564

Finding 1227554 (2025-012)

Material Weakness 2025

Taos Municipal School District

NM

Reporting Internal Control / Segregation of Duties § 200.512

Recommendation We recommend that management enhance its internal control structure, including financial close and reporting, to ensure timely filing of future Single Audit reporting packages Management Response Corrective Action The federal program managers and the finance department will work on an...

Recommendation We recommend that management enhance its internal control structure, including financial close and reporting, to ensure timely filing of future Single Audit reporting packages Management Response Corrective Action The federal program managers and the finance department will work on an internal control system to improve the financial reporting of federal funds Due Date of Completion: June 30, 2027 Responsible Party(ies): Director of Finance, Director of Federal Programs

View Audit 409559

Finding 1227552 (2025-010)

Material Weakness 2025

Taos Municipal School District

NM

Cash Management Reporting School Nutrition Programs

Recommendation We recommend the District strengthen internal controls over the Child Nutrition Program reporting process by ensuring that all required documentation, including federal edit checks, Site Claim Reports by school, and evidence of supervisory review and approval of Meal Count Listings, i...

Recommendation We recommend the District strengthen internal controls over the Child Nutrition Program reporting process by ensuring that all required documentation, including federal edit checks, Site Claim Reports by school, and evidence of supervisory review and approval of Meal Count Listings, is prepared, reviewed, approved, and retained prior to submission of reimbursement claims. Management should also implement periodic monitoring procedures to ensure consistent compliance across all school sites. Management Response Corrective Action Beginning with the 2025–2026 school year, we have implemented a requirement that all kitchen managers complete a daily meal count form provided by the New Mexico Public Education Department (NMPED) in collaboration with the Student Success and Wellness Bureau (SSWB). This documentation ensures accountability and verifies that reimbursable meals are being served for both breakfast and lunch. Additionally, we are currently exploring the implementation of a software program to further strengthen meal count accountability. The Food Service Supervisor will be working closely with the District finance department to identify funding opportunities for the 2026–2027 school year. Due Date of Completion: June 30, 2026 Responsible Party(ies): Director of Federal Programs

View Audit 409559

Finding 1227530 (2025-001)

Material Weakness 2025

Watertown Housing Authority

NY

HUD Housing Programs Allowable Costs / Cost Principles Reporting

Name of Auditee: Watertown Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2025 CAP Prepared by: Shawn VanBrocklin, Assistant Executive Director Phone: (315) 782-1251 (A) Current Finding on the Schedule of Findings and Questioned Costs (1) Findi...

Name of Auditee: Watertown Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2025 CAP Prepared by: Shawn VanBrocklin, Assistant Executive Director Phone: (315) 782-1251 (A) Current Finding on the Schedule of Findings and Questioned Costs (1) Finding 2025-001 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will monitor all relevant dates and reporting timelines to ensure compliance with reporting guidelines. (c) Planned implementation date of corrective action - Completed by December 31, 2026.

View Audit 409557

Finding 1227528 (2025-005)

Material Weakness 2025

Regional School Unit #54 - Msad #54

ME

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Management Response/Corrective Action Plan: The District is aware of the requirement and has a plan to ensure all performance reports are submitted timely in the future.

View Audit 409539

Finding 1227522 (2025-003)

Material Weakness 2025

Regional School Unit #54 - Msad #54

ME

Reporting Internal Control / Segregation of Duties HUD Housing Programs

Management Response/Corrective Action Plan: The School Nutrition Department has implemented strengthened procedures by adding a separate count of meals served in the accounting department. These measures are intended to improve the accuracy claims submitted.

View Audit 409539

Finding 1227488 (2025-001)

Material Weakness 2025

Talmud Torah Darkei Avos - Monsey

NY

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.512

The Organization should implement an effective monitoring system to keep track of the compliance calendar, which includes financial reporting deadlines, and automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Orga...

The Organization should implement an effective monitoring system to keep track of the compliance calendar, which includes financial reporting deadlines, and automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. Additionally, the Organization should implement a system that will file documents in an organized manner and make them easily accessible to the Organization and auditors. Furthermore, the Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight.

View Audit 409525

Finding 1227485 (2025-001)

Material Weakness 2025

Wellpinit School District No. 49

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Corrective action the auditee plans to take in response to the finding: Wellpinit School District acknowledges the audit finding regarding the absence of a written methodology for allocating state and local funding and staffing to the high school grade span in compliance with Title I, Part A supplem...

Corrective action the auditee plans to take in response to the finding: Wellpinit School District acknowledges the audit finding regarding the absence of a written methodology for allocating state and local funding and staffing to the high school grade span in compliance with Title I, Part A supplement not supplant requirements. At the time of the audit, the District operated under a partial exemption and believed it was appropriately following guidance from the Office of Superintendent of Public Instruction (OSPI). However, the District did not fully understand that a written methodology was still required for the non-exempt high school grade span. While allocation decisions were made using consistent practices, they were not formally documented in a manner that demonstrates compliance with federal requirements. To address this finding, the District is implementing the following corrective actions: 1. Development and Adoption of a Written Methodology The District is developing a formal, written methodology for allocating state and local funds and staffing to its high school grade span. The methodology will: • Allocate resources based on objective, neutral criteria such as student enrollment, program offerings, and staffing ratios • Ensure each high school receives the state and local resources it would otherwise receive if it were not receiving Title I, Part A funds • Clearly document that Title I status is not considered in the allocation process This methodology will be formally adopted and applied beginning with the next annual budget development cycle. 2. Strengthening Internal Controls The District is establishing internal control procedures to ensure compliance with supplement not supplant requirements, including: • Annual documentation of allocation formulas and staffing decisions • Review and approval of allocations by the Business Manager prior to budget adoption • Maintenance of supporting documentation demonstrating consistent application of the methodology 3. Training and Capacity Building District leadership and business office staff will participate in training on Title I, Part A fiscal requirements, including supplement not supplant provisions and documentation standards, utilizing guidance provided by OSPI and federal program resources. 4. Ongoing Monitoring and Oversight The Business Manager will be responsible for monitoring implementation and ensuring compliance by: • Conducting annual reviews of allocation practices • Verifying that documentation is complete and audit-ready • Updating the methodology as needed to reflect changes in enrollment, programming, or regulatory guidance 5. Implementation Timeline The written methodology and internal control procedures will be finalized prior to the development of the upcoming fiscal year budget and fully implemented for that cycle. Documentation supporting compliance will be retained annually.

View Audit 409521

Finding 1227481 (2025-003)

Material Weakness 2025

Art Academy of Cincinnati

OH

Student Financial Aid Subrecipient Monitoring Eligibility

Condition: During testing of Student Financial Assistance (SFA) eligibility and awarding, the Institution did not consistently apply federal requirements related to Cost of Attendance (COA), financial need determination, and award packaging. Specifically: • One student was awarded aid in excess of t...

Condition: During testing of Student Financial Assistance (SFA) eligibility and awarding, the Institution did not consistently apply federal requirements related to Cost of Attendance (COA), financial need determination, and award packaging. Specifically: • One student was awarded aid in excess of the federally allowable COA. • One student’s COA was overstated, which resulted in the student being potentially overawarded. • Six student’s were awarded the incorrect COA based on the grade level reported on the Institutional Student Information Record (ISIR). However, there is no code for year 4 on the ISIR, which resulted in the students receiving year 3 COA. • Two students received aid in excess of their calculated financial need, and the Institution did not maintain documentation supporting the adjustments or exceptions. • One student was enrolled at three quarter time during the fall semester and full time during the spring semester; however, the student received three quarter time Pell Grant disbursements for both semesters, resulting in an underpayment for the spring term and inaccurate Pell reporting. These errors demonstrate inconsistent application of federal awarding rules and insufficient review of eligibility and enrollment status changes. Views of Responsible Officials: AAC officials concur with the audit finding and acknowledge that the identified errors resulted from inconsistencies in the application of federal Student Financial Assistance awarding requirements and insufficient review of student eligibility, Cost of Attendance calculations, financial need determinations, and enrollment status changes. Management has reviewed each of the identified student files and is taking appropriate corrective action, including recalculating awards, making any required adjustments or corrections, and updating reporting where necessary. The AAC has also evaluated the circumstances surrounding the use of Cost of Attendance budgets, including the limitation of the Institutional Student Information Record (ISIR), which does not include a separate code for fourth-year undergraduate students. Procedures are being revised to ensure that staff apply the appropriate institutional Cost of Attendance budget regardless of the ISIR grade level code and that any manual adjustments are adequately documented. Corrective Action Plan: To strengthen internal controls, the AAC will implement enhanced review procedures for financial aid packaging, Cost of Attendance determinations, financial need calculations, enrollment status changes, and Pell Grant disbursements prior to disbursement. In addition, financial aid personnel will receive refresher training on federal awarding requirements, documentation standards, and exception processing. Management believes these corrective actions will improve compliance with federal regulations and reduce the likelihood of similar errors in future award years. Responsible Party: Executive Director of Administration and Finance Completion Date: The corrective action will be developed and implemented during the 2025-2026 fiscal year and will continue to be implemented in the 2026-2027 fiscal year.

View Audit 409518

Finding 1227468 (2025-004)

Material Weakness 2025

City of Albany, Georgia

GA

Reporting Internal Control / Segregation of Duties

Management will implement a process to ensure expenditures/expenses and related balances are properly stated in a timely manner.

View Audit 409493

Finding 1227463 (2025-003)

Material Weakness 2025

City of Albany, Georgia

GA

Reporting Internal Control / Segregation of Duties

Management will implement a process to ensure revenues and related balances are properly stated in a timely manner.

View Audit 409493

Finding 1227459 (2025-007)

Material Weakness 2025

The Institute of World Politics

DC

Internal Control / Segregation of Duties Material Weakness Reporting § 200.512

Identifying Number: 2025-007 Data Collection Form (DCF) Late Filing Finding: The Institute did not submit the fiscal year 2024 Data Collection Form (DCF) and related reporting package to the Federal Audit Clearinghouse within the required time frame. Corrective Actions Taken or Planned: Management a...

Identifying Number: 2025-007 Data Collection Form (DCF) Late Filing Finding: The Institute did not submit the fiscal year 2024 Data Collection Form (DCF) and related reporting package to the Federal Audit Clearinghouse within the required time frame. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with Uniform Guidance reporting requirements: 1. Establish Formal Single Audit Reporting Procedures • The Institute will develop and maintain written procedures governing the annual Single Audit reporting process, including the preparation, review, approval, and submission of the Data Collection Form and reporting package. Procedures will clearly identify filing deadlines, responsible personnel, required approvals, and submission requirements. 2. Assign Responsibility and Accountability • Management will formally designate responsibility for coordinating the annual audit reporting process, including monitoring auditor requests, gathering required documentation, preparing the Data Collection Form, obtaining management approvals, and ensuring timely submission to the Federal Audit Clearinghouse. 3. Implement an Audit and Compliance Calendar • The Institute will establish a compliance calendar that includes all critical audit and federal reporting deadlines. Key milestones will include audit preparation activities, auditor request completion, draft financial statement review, issuance of the auditor's reports, Data Collection Form preparation, management certification, and FAC submission deadlines. 4. Strengthen Management Review Controls • Management will implement documented review procedures for the reporting package and Data Collection Form prior to submission. Review controls will verify the accuracy, completeness, and timeliness of information reported and ensure compliance with Uniform Guidance requirements. 5. Monitor Audit Requests and Submission Readiness • A tracking mechanism will be implemented to monitor the status of auditor requests, outstanding items, and reporting package preparation throughout the audit process. Periodic status meetings will be conducted to identify potential delays and ensure timely resolution of open items. 6. Maintain Evidence of Filing and Review • The Institute will retain documentation supporting preparation, review, approval, and submission of the Data Collection Form and reporting package, including filing confirmations, management approvals, submission receipts, and related correspondence. 7. Ongoing Oversight and Compliance Monitoring • Senior management will periodically review compliance with federal reporting deadlines and monitor the effectiveness of implemented controls. Any compliance issues identified will be evaluated and addressed promptly to prevent future late filings. Responsible Officials: • Executive Vice President – Ariane Sweeney • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Director of Financial Aid – Dr. Thelbert Snowden Anticipated completion date: The Institute will implement formal reporting procedures, deadline tracking tools, management review controls, and accountability measures by December 31, 2026. These procedures will be incorporated into all future Single Audit reporting cycles.

View Audit 409492

Finding 1227456 (2025-004)

Material Weakness 2025

The Institute of World Politics

DC

Allowable Costs / Cost Principles Material Weakness Reporting

Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records Finding: - During our testing of the Student Financial Assistance Cluster, we noted that the Institute did not perform monthly reconciliations between its intern...

Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records Finding: - During our testing of the Student Financial Assistance Cluster, we noted that the Institute did not perform monthly reconciliations between its internal records and COD system data. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen controls over COD reporting and reconciliation activities. 1. Implementation of Monthly Reconciliation Procedures • The Institute will establish formal monthly reconciliation procedures requiring comparison of: o COD system data to internal financial aid records; o Student financial aid records to the student information system; and o COD activity to the general ledger and related financial reporting records. • The reconciliation process will be designed to verify that all aid originated, disbursed, adjusted, and reported to the Department of Education is complete and accurate. 2. Development of Written Policies and Procedures • Management will develop and maintain formal written policies and procedures governing COD reconciliation activities. These procedures will identify responsible personnel, reconciliation timelines, required documentation, review expectations, and procedures for investigating and resolving discrepancies. 3. Timely Investigation and Resolution of Differences • Any discrepancies identified during the reconciliation process will be reviewed, documented, and resolved timely. Management will maintain documentation explaining the nature of reconciling items, corrective actions taken, and the date of resolution. 4. Documentation and Retention Requirements • The Institute will maintain completed reconciliation workpapers each month, including supporting reports, reconciliations performed, explanations of variances, and documentation of corrective actions taken. Reconciliation records will be retained in accordance with federal record retention requirements. 5. Management Review and Approval • Completed reconciliations will be reviewed by supervisory personnel independent of the preparation process. Evidence of review will be documented through signed and dated approvals, electronic workflow approvals, or other documentation demonstrating that reconciliations were reviewed for completeness and accuracy. 6. Staff Training • Financial Aid and Finance personnel responsible for COD reporting and reconciliation activities will receive training regarding Department of Education requirements, reconciliation procedures, documentation standards, and internal control responsibilities. 7. Ongoing Monitoring and Compliance Oversight • Management will perform periodic monitoring of reconciliation activities to ensure procedures are operating effectively and reconciliations are completed on a timely basis. Compliance results and any significant reconciliation issues will be communicated to senior management and tracked through resolution. Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records (Continued) Responsible Officials: • Director of Financial Aid 0 Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Executive Vice President – Ariane Sweeney Anticipated completion date: Formal reconciliation procedures, documentation standards, and management review controls will be fully implemented by December 31, 2026. Monthly reconciliations will be performed and documented on an ongoing basis thereafter.

View Audit 409492

Finding 1227455 (2025-003)

Material Weakness 2025

The Institute of World Politics

DC

Student Financial Aid Reporting Special Tests & Provisions

Identifying Number: 2025-003: Special Test-National Student Loan Data System (NSLDS) Enrollment Reporting Noncompliance. Finding - Instances of noncompliance have been identified where student enrollment changes were not reported to the NSLDS within the 60-day requirement. Corrective Actions Taken o...

Identifying Number: 2025-003: Special Test-National Student Loan Data System (NSLDS) Enrollment Reporting Noncompliance. Finding - Instances of noncompliance have been identified where student enrollment changes were not reported to the NSLDS within the 60-day requirement. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions: 1. Development of Formal Written Procedures • The Institute will develop and maintain formal written policies and procedures governing NSLDS enrollment reporting. These procedures will clearly define reporting requirements, timelines, responsible personnel, supervisory review responsibilities, and documentation retention requirements to ensure compliance with Department of Education regulations. 2. Establishment of Reporting Calendars and Tracking Controls • Management will implement a formal reporting calendar and tracking mechanism to monitor NSLDS reporting deadlines. The tracking process will identify enrollment status changes requiring reporting and ensure all submissions occur within the required 60-day timeframe. 3. Enhanced Monitoring and Reconciliation Procedures • The Institute will perform periodic reconciliations between student enrollment records and NSLDS submissions to verify that all enrollment status changes have been reported accurately and timely. Any discrepancies identified during reconciliation will be investigated and corrected promptly. 4. Documented Review and Approval Process • Management will require documented evidence of supervisory review for each NSLDS submission. Review documentation will include dated approvals, electronic workflow approvals, or other evidence demonstrating that submissions were reviewed for completeness, accuracy, and timeliness prior to certification. 5. Staff Training and Cross-Training • Financial Aid personnel responsible for enrollment reporting will receive training on NSLDS reporting requirements and internal control procedures. Cross training will be implemented to ensure coverage during staff absences and reduce the risk of reporting delays due to personnel changes. 6. Ongoing Compliance Monitoring • Management will conduct periodic reviews of NSLDS reporting performance and maintain monitoring documentation to verify ongoing compliance with federal requirements. Any exceptions identified will be addressed through corrective action and management follow-up. 7. Oversight and Accountability • The Director of Financial Aid and senior administration will review compliance monitoring results periodically and track remediation efforts until the finding has been fully resolved. Management will maintain documentation supporting the operation of controls and timely reporting activities. Responsible Officials • Director of Financial Aid – Dr Thelbert Snowden • Executive Vice President – Ariane Sweeney • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Registrar (as applicable) – Adele Hartswick Anticipated completion date: The Institute will implement formal policies, reporting calendars, monitoring controls, reconciliation procedures, and review documentation requirements by December 31, 2026. Ongoing compliance monitoring and periodic review activities will continue thereafter.

View Audit 409492

Finding 1227454 (2025-002)

Material Weakness 2025

The Institute of World Politics

DC

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance Finding: We noted that controls identified by management over all material compliance requirements lack sufficient documentation to conclude application of controls is in place. Corrective Actions Taken or Planned: Mana...

Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance Finding: We noted that controls identified by management over all material compliance requirements lack sufficient documentation to conclude application of controls is in place. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions: 1. Development of Written Policies and Procedures • The Institute will perform a comprehensive review of all applicable Student Financial Assistance compliance requirements and develop formal written policies and procedures documenting the processes and controls for each material compliance area. Procedures will include the individual responsible, required documentation, review requirements, and retention standards. 2. Documentation of Internal Controls • Management will establish standardized control documentation requirements for all compliance activities. Evidence of review and approval will be maintained through signatures, initials, electronic approvals, checklists, reconciliations, or other documented support sufficient to demonstrate that controls were performed and reviewed. 3. Compliance Monitoring Checklists • The Institute will implement compliance monitoring checklists covering all direct and material compliance requirements identified in the audit, including: o Cash Management o Reporting o Student Eligibility o Student Disbursements o Credit Balance Processing o NSLDS Reporting o Gramm-Leach-Bliley Act Information Security Requirements • The checklists will be completed and reviewed periodically to provide evidence of compliance and supervisory oversight. 4. Training and Cross-Training • Financial Aid and Administrative personnel will receive training on federal student aid compliance requirements, documentation expectations, and internal control responsibilities. Cross training will be performed to mitigate risks associated with employee turnover and ensure continuity of operations. 5. Management Review and Oversight • Management will implement periodic supervisory reviews of compliance activities and supporting documentation to verify controls operating as designed. Results of compliance monitoring activities and any identified deficiencies will be reported to senior administration, and corrective actions will be tracked to completion. 6. Annual Compliance Review • The Institute will conduct an annual review of Student Financial Assistance policies, procedures, and internal controls to ensure continued compliance with Department of Education regulations, Uniform Guidance requirements, and changes in federal program requirements. Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance (Continued) Responsible Officials: • Executive Vice President – Ariane Sweeney • Director of Financial Aid – Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Compliance and Information Security Personnel, as applicable Anticipated completion date: The written policies and procedures, compliance monitoring tools, and documentation standards will be fully implemented by December 31, 2026. Ongoing monitoring, training, and annual reviews will continue thereafter.

View Audit 409492

Finding 1227453 (2025-001)

Material Weakness 2025

Columbia Borough School District

PA

Subrecipient Monitoring Cash Management Reporting § 200.303

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will...

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will prepare the monthly SNP Claim for Reimbursement Summary report and compile all supporting meal count documentation. 2. Prior to submission, the Administrative Assistant to the Director of Food Services or another designated individual independent of the preparation process will: a. Review the claim for mathematical accuracy; b. Verify meal counts against supporting documentation; c. Confirm claims are submitted within required timelines; and 3. Evidence of the review and approval will be documented through: a. Signature or electronic approval on the reimbursement summary report; and b. Retention of supporting documentation in accordance with federal and state record retention requirements. 4. A written standard operating procedure (SOP) outlining these review and approval responsibilities will be developed and communicated to applicable personnel. The Business Manager will periodically monitor compliance with the procedure to ensure controls remain effective.

View Audit 409490

Finding 1227450 (2025-001)

Material Weakness 2025

Search for Common Ground

DC

Reporting Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.302 § 200.303

We will strengthen our controls around reporting of expenses on consolidated SEFA report for our subsidiary and related organizations. We will exclude expenses that exceed the total budget and recommend posting adjustments in the books so that these are not included in grant expenses.

View Audit 409488

Finding 1227383 (2025-008)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Cash Management Allowable Costs / Cost Principles Material Weakness

The organization will develop a procedure for the review and approval of adjusting journal entries, and attaching supporting documentation ensuring entries are being charged to the correct funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: Octob...

The organization will develop a procedure for the review and approval of adjusting journal entries, and attaching supporting documentation ensuring entries are being charged to the correct funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: October 31, 2026

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Finding 1227381 (2025-006)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.331

The auditor compares being a beneficiary to being a sub-recipient instead of is the secondary institution a contractor or a sub-recipient. The organization agrees that policies and procedures should be put in place in the event that funds are going to be passed-through. In addition, the organization...

The auditor compares being a beneficiary to being a sub-recipient instead of is the secondary institution a contractor or a sub-recipient. The organization agrees that policies and procedures should be put in place in the event that funds are going to be passed-through. In addition, the organization feels that it was able to show the funds that were passed-through to the contractor. Responsible Individual: Chief Financial Officer– Scott Korba Estimated Completion Date

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Corrective Action Plans

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