Corrective Action Plans

Finding 1153703 (2025-001)

Material Weakness 2025

ME

Reporting § 200.512

View of Responsible Official and Corrective Action The delay in the submission of the Data Collection Form was a direct result of the audit team moving to a new accounting firm and a miscommunication as to which firm was going to assist with the completion of the Data Collection Form. Management has...

View of Responsible Official and Corrective Action The delay in the submission of the Data Collection Form was a direct result of the audit team moving to a new accounting firm and a miscommunication as to which firm was going to assist with the completion of the Data Collection Form. Management has taken steps to ensure that the Data Collection Form for the year-ended June 30, 2025 will be submitted timely. Upon identifying the late submission, management immediately completed the submission of the 2024 Data Collection Form and reporting package on August 12, 2025.

View Audit 366840

Finding 1153477 (2025-002)

Material Weakness 2025

The Corporation of Gonzaga University

WA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Return of Title IV Funds Processing Recommendation: The University should enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported wit...

FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Return of Title IV Funds Processing Recommendation: The University should enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support the timeliness of federal compliance. Response: There is no disagreement with this audit finding. Action taken in response to finding: Some of the corrective actions noted in our response to finding 2025-001 also apply here. For example, quality assurance reports to identify students who withdraw from all classes in a part of term and the upcoming joint training and process mapping session with Student Financial Services and the Registrar’s Office will strengthen understanding of how enrollment status updates drive downstream compliance, including R2T4 processing. These steps will also ensure exceptions are addressed consistently and that communication channels between offices are clear. To address immediate gaps specific to R2T4 compliance, the Registrar’s Office has enhanced training regarding R2T4 compliance requirements related to recording withdrawals and enrollment changes in a timely, accurate and consistent manner. Additional quality checks are being implemented to confirm that withdrawal dates and status changes are entered accurately into the student information system so that R2T4 calculations are completed within federal timeframes. Together, these interventions are designed to ensure the timeliness and accuracy of R2T4 processing and compliance with federal requirements. We expect to have these corrective actions completed by September 12, 2025. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research

View Audit 366726

Finding 1153470 (2025-001)

Material Weakness 2025

The Corporation of Gonzaga University

WA

Student Financial Aid Special Tests & Provisions Reporting

FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status an...

FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis. Response: There is no disagreement with this audit finding. Action taken in response to finding: Gonzaga has already taken action and implemented quality assurance reports and monitoring to ensure all student changes (enrollment status and address changes) are reported timely. Additionally, to strengthen compliance going forward, Student Financial Services and the Registrar’s Office are partnering to conduct a joint annual training and process mapping session for key personnel. This session will provide an overview of enrollment reporting requirements, outline the steps needed when exceptions to normal policies occur, and evaluate processes to improve understanding of how decisions affect both upstream and downstream functions. The session will also focus on building a shared understanding of reporting processes, identifying gaps in procedures and knowledge, and establishing communication channels so that exceptions are addressed timely, consistently and appropriately. These actions are designed to enhance internal controls and ensure compliance of timely reporting between the system of record and the reporting system, and we expect to complete this training by September 12, 2025. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research

View Audit 366726

Finding 1153268 (2025-001)

Material Weakness 2025

B.r.l Housing Corporation

OH

HUD Housing Programs Reporting Special Tests & Provisions

Finding 2025-001 Delay in Deposit of Surplus Cash into Residual Receipts Account ___ : Comments on Findings and Recommendations: Surplus cash of $76,388 from FY 2024 was deposited into the Residual Receipts account 98 days after year-end, exceeding HUD's 60-day requirement by 38 days. Although the f...

Finding 2025-001 Delay in Deposit of Surplus Cash into Residual Receipts Account ___ : Comments on Findings and Recommendations: Surplus cash of $76,388 from FY 2024 was deposited into the Residual Receipts account 98 days after year-end, exceeding HUD's 60-day requirement by 38 days. Although the full amount was deposited, the delay constituted noncompliance with HUD's timing rules. To address this, management will implement procedures to ensure surplus cash deposits are made within 60 days based on unaudited computations, track and schedule deposits in advance, formally request HUD approval if deferrals are necessary, and maintain documentation of all related communications and approvals for compliance purposes. Actions Taken or Planned on the Findings: This was paid on check # 9841 Working on an implementation program for the future. Completion Date: August 25, 2025 Finding Resolution Status: In-Process Contact Person: Controller: Don Trigg Accountant: Charley Hinkle

View Audit 366462

Finding 576208 (2025-001)

Material Weakness 2025

Freedom First Federal Credit Union

VA

Material Weakness Period of Performance Reporting

Management agrees with the finding and will establish the internal control recommendations outlined in the Schedule of Findings and Questioned Costs. Internal control procedures will be developed and implemented by September 2025.

View Audit 366124

Finding 576151 (2025-006)

Significant Deficiency 2025

Community Action of Southern Indiana

IN

Reporting

The Agency acknowledges this error and agrees with the recommendations. With the completion of this audit, the Agency will be caught up after completing four audits in an 18 month time period. This current audit will be submitted by the required deadline and the next regular audit is scheduled to be...

The Agency acknowledges this error and agrees with the recommendations. With the completion of this audit, the Agency will be caught up after completing four audits in an 18 month time period. This current audit will be submitted by the required deadline and the next regular audit is scheduled to begin shortly after the close of FY 25-26.

View Audit 366061

Finding 576149 (2025-005)

Material Weakness 2025

Community Action of Southern Indiana

IN

Reporting

The Agency acknowledges this error and agrees with the recommendations. It is the Agency's opinion that this finding is a direct outcome of the reconciliation issues outlined in Findings 001-003. As those deficiencies are addressed systemically, the accuracy of SF-425 reports will be restored and ma...

The Agency acknowledges this error and agrees with the recommendations. It is the Agency's opinion that this finding is a direct outcome of the reconciliation issues outlined in Findings 001-003. As those deficiencies are addressed systemically, the accuracy of SF-425 reports will be restored and maintained.

View Audit 366061

Finding 575725 (2025-001)

Significant Deficiency 2025

Frontier Nursing University, Inc.

KY

Internal Control / Segregation of Duties Reporting Matching / Level of Effort / Earmarking

Finding: The enrollment statuses in the National Student Loan Data System for students who took a Regular Academic Hiatus were incorrect during the time of their hiatus. Corrective Actions Taken or Planned: FNU will change the reported enrollment status of all students on a regular Academic Hiatus...

Finding: The enrollment statuses in the National Student Loan Data System for students who took a Regular Academic Hiatus were incorrect during the time of their hiatus. Corrective Actions Taken or Planned: FNU will change the reported enrollment status of all students on a regular Academic Hiatus (AH) from “Enrolled” to “Leave of Absence (LOA)” in the National Student Clearinghouse (NSC). Note that both status types indicate an enrolled status per NSC. To support this change, FNU will revise its internal procedures to ensure that students on a regular AH are coded as “Leave” in the Student Learning Management System. This status accurately reflects a temporary interruption in their program of study and aligns with enrollment reporting requirements. We will strengthen training for all staff involved in enrollment status reporting to ensure consistent understanding and proper implementation of the updated procedures. We believe these steps are important for improving the accuracy of our reporting and staying in compliance with federal student aid requirements. Estimated Completion Date: September 30, 2025 Responsible Personnel: Janice Ponstein, Director of Academic Records & Registrar

View Audit 365718

Finding 575602 (2025-004)

Significant Deficiency 2025

Village of Shelby

MI

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting

Finding 2025-004: Coronavirus State and Local Fiscal Recovery Funds Reporting Procedures Type of Finding: Control U.S. Department of Treasury Pass-through Entities: The Right Place, Inc. and Michigan Department of Treasury. Assistance Listing Number: 21.027 Award Numbers: COVID-19 Revitaliza...

Finding 2025-004: Coronavirus State and Local Fiscal Recovery Funds Reporting Procedures Type of Finding: Control U.S. Department of Treasury Pass-through Entities: The Right Place, Inc. and Michigan Department of Treasury. Assistance Listing Number: 21.027 Award Numbers: COVID-19 Revitalization and Placemaking Grant, COVID-19 American Rescue Plan Act Award Year End: June 30, 2026 and December 31, 2026 Specific Requirement: (L.) Reporting Recommendation: The Village should follow established procedures to require the documented review and approval of both RAP and ARPA grant reports by an individual with adequate skills, knowledge, and experience prior to submission. Action Taken: The Village is implementing a new procedure requiring that ARPA grant reports be reviewed and approved by a designated reviewer before submission in addition to RAP grant reports. The reviewer, who must possess the appropriate skills, knowledge, and experience relevant to the report's content, will ensure that the information is accurate, complete, and compliant with organizational standards and regulatory requirements. Responsible Person and Anticipated Completion Date: The Village Clerk/Treasurer will oversee the implementation of this plan by February 28, 2026. If the Michigan Strategic Fund has questions regarding this plan, please call Phillip Morse at 231-861-4401.

View Audit 365594

Finding 575564 (2025-001)

Significant Deficiency 2025

Village Cooperative of Le Sueur

MN

Reporting Internal Control / Segregation of Duties

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

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

View Audit 365551

Finding 575409 (2025-001)

Significant Deficiency 2025

Andrews University

MI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation and Enrollment Change Status’ submission calendar will be updated to reflect the necessary reporting timeline. The report will be completed after verification of graduation requirement...

Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation and Enrollment Change Status’ submission calendar will be updated to reflect the necessary reporting timeline. The report will be completed after verification of graduation requirements and credentialing are completed by the Academic Record’s Department. Additional training will be provided to all members within the department to ensure timely submissions.

View Audit 365458

Finding 574879 (2025-002)

Material Weakness 2025

Aspermont Small Business Development Center, Inc.

TX

Reporting Internal Control / Segregation of Duties

Views of responsible official and planned corrective actions: The financial personnel of the Organization will document their review and approval of all grant related expenditures. Any issues brought to the attention of the Organization staff have been addressed and corrective actions have been take...

Views of responsible official and planned corrective actions: The financial personnel of the Organization will document their review and approval of all grant related expenditures. Any issues brought to the attention of the Organization staff have been addressed and corrective actions have been taken where applicable.

View Audit 365136

Finding 574782 (2025-002)

None 2025

Houston Heights Towers

TX

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Audit Finding 2025-002: The regulatory agreement stipulates that all withdrawals from the Reserve for Replacement Account be supported by invoices and payments as proof of amounts expended. An invoice of $1,707 was duplicated while calculating the funds to be withdrawn from the Reserve for Replacem...

Audit Finding 2025-002: The regulatory agreement stipulates that all withdrawals from the Reserve for Replacement Account be supported by invoices and payments as proof of amounts expended. An invoice of $1,707 was duplicated while calculating the funds to be withdrawn from the Reserve for Replacement account . Response: Management agrees with the finding and has refunded $1,707 to the Reserve for Replacement Account on August 12, 2025.

View Audit 365069

Finding 574781 (2025-001)

None 2025

Houston Heights Towers

TX

HUD Housing Programs Reporting Equipment & Real Property Management

Audit Finding 2025-001: The regulatory agreement stipulates that all withdrawals exceeding $2,500 from the Reserve for Replacement Account need prior written consent of the lender. Several withdrawals totaling $108,111 for emergency repairs and improvements, to cover payroll, pay audit fees and for ...

Audit Finding 2025-001: The regulatory agreement stipulates that all withdrawals exceeding $2,500 from the Reserve for Replacement Account need prior written consent of the lender. Several withdrawals totaling $108,111 for emergency repairs and improvements, to cover payroll, pay audit fees and for other operating expenses were made from the Reserve for Replacement account without prior approval from the lender. Response: Management agrees with the finding, was aware of the requirement for prior approval and on April 30, 2025, and has obtained retroactive approval from the lender for the withdrawal of 108,111.

View Audit 365069

Finding 574780 (2025-002)

None 2025

Heights Towers Services Company

TX

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

Audit Finding 2025-002: During our testing of residual receipts account transactions, it was discovered that the Project had withdrawn $47,420 and transferred it back after 3 months. -Response: Management believed that including this expenditure in its request for withdrawal of funds from the reserv...

Audit Finding 2025-002: During our testing of residual receipts account transactions, it was discovered that the Project had withdrawn $47,420 and transferred it back after 3 months. -Response: Management believed that including this expenditure in its request for withdrawal of funds from the reserve for replacement account was sufficient. Management also promptly replaced the funds taken temporarily from the residual receipts account, once they received the funds from the reserve for replacement account controlled by the lender. In the future, management will make sure to obtain prior approval from HUD before making any withdrawals from the residual receipts account.

View Audit 365067

Finding 574779 (2025-001)

None 2025

Heights Towers Services Company

TX

HUD Housing Programs Reporting

Audit Finding 2025-001: During our testing of reserve for replacement account transactions, it was discovered that the Project had made deposits of an insufficient amount each month for 22 months through September 2024. -Response: The reserve for replacement account is controlled by the lender and ...

Audit Finding 2025-001: During our testing of reserve for replacement account transactions, it was discovered that the Project had made deposits of an insufficient amount each month for 22 months through September 2024. -Response: The reserve for replacement account is controlled by the lender and when the lender discovered the deficiency during the year ended May 31, 2025 a lumpsum amount was drafted from the Project's monthly payment to cover the shortfall. In future, Management will inform the lender of changes to the monthly required deposit to the reserve for replacement account made by HUD.

View Audit 365067

Finding 574031 (2025-001)

Significant Deficiency 2025

Lutheran Social Services of the South, Inc.

TX

Reporting

Grant accountants will review all new grant awards for reporting schedules at their inception to ensure that off-cycle reporting requirements are included in the calendar, and review that the reports are available in the Payment Management Services (PMS) system monthly and include all known reports ...

Grant accountants will review all new grant awards for reporting schedules at their inception to ensure that off-cycle reporting requirements are included in the calendar, and review that the reports are available in the Payment Management Services (PMS) system monthly and include all known reports due. Grants Manager will review the calendar monthly to ensure that it is maintained with accurate information and the reporting steps are being addressed.

View Audit 364616

Finding 572937 (2025-002)

Significant Deficiency 2025

Csi Residential, Inc.

CT

Questioned Costs HUD Housing Programs Reporting

Deposits required by HUD were not made during fiscal year 2025 to the reserve fund. Recommendation: CLA Recommends the Project enforce procedures that ensure deposits are made timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned i...

Deposits required by HUD were not made during fiscal year 2025 to the reserve fund. Recommendation: CLA Recommends the Project enforce procedures that ensure deposits are made timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management has made the missing deposit as of March 31, 2025. Name of the contact person responsible for corrective action: Laurie Rudman, Senior Vice President, CFO Planned completion date for corrective action plan: March 31, 2025

View Audit 363778 Questioned Costs: $1

Finding 572935 (2025-001)

Significant Deficiency 2025

Csi Residential, Inc.

CT

HUD Housing Programs Reporting Significant Deficiency

The Project had not timely reviewed the bank reconciliations for July 2024. Recommendation: CLA Recommends the Project review bank reconciliations timely and formerly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to fin...

The Project had not timely reviewed the bank reconciliations for July 2024. Recommendation: CLA Recommends the Project review bank reconciliations timely and formerly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management has retroactively reviewed all bank reconciliations that were not reviewed by the former management team as of March 31, 2025. Name of the contact person responsible for corrective action: Laurie Rudman, Senior Vice President, CFO Planned completion date for corrective action plan: March 31, 2025

View Audit 363778

Finding 572429 (2025-001)

Significant Deficiency 2025

Regis University

CO

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding 2025-001 Personnel Responsible for Corrective Action: Deborah Vinnola, Registrar Anticipated Completion Date: September 30, 2025 Corrective Action Plan: The Office of the Registrar has put into place a more detailed corrective action plan regarding the finding of delayed enrollment and non...

Finding 2025-001 Personnel Responsible for Corrective Action: Deborah Vinnola, Registrar Anticipated Completion Date: September 30, 2025 Corrective Action Plan: The Office of the Registrar has put into place a more detailed corrective action plan regarding the finding of delayed enrollment and non-enrollment reporting to NSLDS through NSC. The Office of the Registrar has adjusted the Degree Verify submission from every 45 days to every 30 days to NSC to ensure graduation dates are reported in a more timely fashion for NSLDS within the required 60 days for financial aid. Starting Summer 2025, the Office of the Registrar has begun inactivating academic programs for students who have not had registration activity within the last two to three academic years to ensure that they are not reported as enrolled to NSC/NSLDS. NSC Enrollment Reporting will continue to be submitted every 30 days and the Office of the Registrar has worked to review the reporting criteria using terms and not semesters to better report active enrollment in current courses. The Ellucian Graduation Application form and process is in the final stages of testing which will eliminate completely the need to add a pseudo course with a future date after the student’s current program has been inactivated or graduated. The Office of the Registrar will be more proactive with the colleges for identifying students who have not graduated within the six year (undergraduate), four year (graduate) and certificate time frames by working with the appropriate dean’s offices. This should eliminate those students who have completed their coursework; close to completing their coursework but were never reviewed by their advisor/program for graduation. Since Regis uses the end date of the last course completed, the Office of the Registrar will work with advising units to review the lists to increase a better reporting of degree completion.

View Audit 363564

Finding 570974 (2025-001)

Significant Deficiency 2025

Village Cooperative of Hutchinson

MN

Reporting Internal Control / Segregation of Duties

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

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

View Audit 361899

Finding 570847 (2025-001)

Significant Deficiency 2025

Cornish College of the Arts and Cornish Foundation

WA

Student Financial Aid Reporting Significant Deficiency

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the 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: The student that was incorrectly coded as FWS funds, the funds were immediately reclassified as institutional aid. Since Cornish, did not draw down all FWS funding, it did not impact the G5 drawdown and no needs needed to be returned. Going forward, a higher-level review will be conducted for students with high SAI and low need to ensure that no need-based funds, if not eligible, are in the packaging. This review, will take place after the initial counselor review, but before a student can begin working in the FWS program. This third check will ensure that these types of files are again reviewed in a timely manner and no over awards will happen in the future. Name(s) of the contact person(s) responsible for corrective action: Sara Drummond Planned completion date for corrective action plan: June 16th, 2025

View Audit 361771

Finding 568853 (2025-001)

Significant Deficiency 2025

Realife Cooperative of Bloomington

MN

Reporting Internal Control / Segregation of Duties

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

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

View Audit 360579

Finding 1166569 (2024-016)

Material Weakness 2024

State of California

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

The Child Care and Development Division is working towards compliance with federal requirements for license-exempt health and safety monitoring with an anticipated completion date of July 1, 2029, assuming additional resources are secured. This plan has been outlined in Appendix A of the Federal Fis...

The Child Care and Development Division is working towards compliance with federal requirements for license-exempt health and safety monitoring with an anticipated completion date of July 1, 2029, assuming additional resources are secured. This plan has been outlined in Appendix A of the Federal Fiscal Year 2025-27 State Plan for California with Administration of Children and Families (State Plan). The State Plan can be provided upon request. Estimated Implementation Date: July 1, 2029 Contact: • Jeff Fowler, Child Care Administration Bureau Chief • Central Operations Branch • Child Care and Development Division • California Department of Social Services

View Audit 377562

Finding 1166567 (2024-015)

Material Weakness 2024

State of California

CA

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

The difference in reporting deadlines between the ACF-696 and SEFA reports will consistently result in a known discrepancy. To address this, as of September 2025, CDSS started conducting year-end reconciliations between the two reports to validate and confirm these discrepancies. Estimated Implement...

The difference in reporting deadlines between the ACF-696 and SEFA reports will consistently result in a known discrepancy. To address this, as of September 2025, CDSS started conducting year-end reconciliations between the two reports to validate and confirm these discrepancies. Estimated Implementation Date: March 2026 Contact: • Daniel During, Federal Reporting Section Chief • Accounting and Fiscal Systems Branch • Finance and Accounting Division • California Department of Social Services

View Audit 377562

Corrective Action Plans

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