Corrective Action Plans

Finding 541025 (2024-003)

Significant Deficiency 2024

Elkhart and St. Joseph Counties Head Start Consortium

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

We will ensure all required federal reports have a documented, formal review of the reports before they are submitted to ensure the information submitted is accurate

View Audit 350620

Finding 540999 (2024-001)

Significant Deficiency 2024

Thomas Jefferson University

PA

Student Financial Aid Special Tests & Provisions Reporting

2024-001: Special Tests and Provisions – Student Financial Assistance Cluster Management’s view and corrective action plan Management concurs with the audit findings related to the disbursement of loan funds, verification of financial aid applications and return of Title IV funds. These findings are...

2024-001: Special Tests and Provisions – Student Financial Assistance Cluster Management’s view and corrective action plan Management concurs with the audit findings related to the disbursement of loan funds, verification of financial aid applications and return of Title IV funds. These findings are directly attributed to the challenge of maintaining staffing levels. The Student Financial Aid Office became fully staffed in March 2025. Management will implement enhanced controls and training are required within the Student Financial Aid office. Additionally, management concurs with the following audit findings pertaining to noncompliance with enrollment reporting requirements for 20 of the 25 sampled. Management will implement enhanced controls and additional dedicated resources are required within the Registrar’s Office in order to monitor and assure compliance with regulatory requirements. Additionally, efforts will be employed to monitor and confirm the timely and accurate submission of information from the National Student Clearinghouse to the NSLDS. Furthermore, the procedural and training enhancements of the Financial Aid and Registrar’s Offices, as well as their resource plans, will be reviewed and approved by the Office of Internal Audit. Implementation date: September 2025 Raelynn Cooter, PhD Vice Provost for Academic Infrastructure and Effectiveness.

View Audit 350613

Finding 540990 (2024-002)

Significant Deficiency 2024

Integrated Living, Inc.

KS

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

March 21, 2025 HUD Service Audit Director Kansas City, Kansas Integrated Living, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. SSC CPAs, P.A. 58525 SW 29th St, Suite 100 Topeka, Kansas 66614 Audit period: Year ended June 30, 2024 The findings ...

March 21, 2025 HUD Service Audit Director Kansas City, Kansas Integrated Living, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2024. SSC CPAs, P.A. 58525 SW 29th St, Suite 100 Topeka, Kansas 66614 Audit period: Year ended June 30, 2024 The findings from the June 30, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section I of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENT AUDIT 2024‐001 Internal Controls over Financial Statement Presentation (Material Weakness) Recommendation: The Board of Directors and management should review the impact of the current year adjustments on the financial reporting process. Once this review is complete, the Organization should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure conformity with U.S. GAAP. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2025. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024‐002 Written Procedures of Internal Control over Compliance (Significant Deficiency) Department of Housing and Urban Development Section 811 Supportive Housing for Person with Disabilities, Assistance Listing Number 14.181 Recommendation: The Organization should develop written policies for the internal control over compliance of federal awards. Action Taken (Unaudited): Management is in the process of updating its control procedures to include proper written policies for the internal control over compliance of federal awards John Griffin, CFO of COF Training Services, Inc. (Management Agent of Integrated Living, Inc.) is responsible for this corrective action. Anticipated completion date is June 30, 2025. If HUD has questions regarding this plan, please call Patrick Gardner at 785-242-5035. Sincerely yours, Patrick Gardner CEO, COF Training Services, Inc. (Management Agent of Integrated Living, Inc.)

View Audit 350594

Finding 540974 (2024-001)

Significant Deficiency 2024

Sheldon Terrace Supportive Housing Corporation Hud Proj. No. 017-Hd040

CT

Internal Control / Segregation of Duties Significant Deficiency

2024-001 Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Criteria or Specific Requirement: Department of Housing and Urban Development requires any surplus funds in the project funds account at the end of the fiscal year to be deposited in a federally insured account...

2024-001 Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Criteria or Specific Requirement: Department of Housing and Urban Development requires any surplus funds in the project funds account at the end of the fiscal year to be deposited in a federally insured account within 60 days following the end of the fiscal year. Condition: As of June 30, 2024, Sheldon Terrace Supportive Housing Corporation has a surplus cash of $10,585. A residual receipt account is established but the required deposit was not made within 60 days following the end of the fiscal year. Questioned costs: None Context: We reviewed the surplus cash calculation noting that the Project has a surplus cash of $10,585 at the end of the fiscal year 24. Surplus cash should have been deposited within 60 days following the end of the fiscal year. Cause: This was an oversight by management. Effect: The required deposit was not made as required by the Department of Housing and Urban Development. Repeat Finding: No Recommendation: It is recommended that management Make the required deposit as soon as possible. Views of Responsible Officials: There is no disagreement with the audit finding. Action taken in response to finding: Required deposit will be made by March 31, 2025. Name of the contact person responsible for corrective action: Angela Westwood, CFO Planned completion date for corrective action plan: March 31, 2025.

View Audit 350582

Finding 540969 (2024-002)

Significant Deficiency 2024

Continuum of Care, Inc. and Affiliates

CT

Internal Control / Segregation of Duties Significant Deficiency

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Criteria or Specific Requirement: Department of Housing and Urban Development requires any surplus funds in the project funds account at the end of the fiscal year to be deposited in a federally insured account within 6...

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Criteria or Specific Requirement: Department of Housing and Urban Development requires any surplus funds in the project funds account at the end of the fiscal year to be deposited in a federally insured account within 60 days following the end of the fiscal year. Condition: As of June 30, 2024, Continuum Supportive Housing of West Hartford, Inc. has a surplus cash of $50,759. The required deposit into a residual receipt account was not made within 60 days following the end of the fiscal year. Questioned costs: None Context: We reviewed the surplus cash calculation noting that the Project has a surplus cash of $50,759 at the end of the fiscal year 24. Surplus cash should have been deposited within 60 days following the end of the fiscal year. Cause: This was an oversight by management. Effect: The required deposit was not made as required by the Department of Housing and Urban Development. Repeat Finding: No Recommendation: It is recommended that management make the required deposit as soon as possible. Views of Responsible Officials: There is no disagreement with the audit finding. Action taken in response to finding:. Required deposit will be made by March 31, 2025. Name of the contact person responsible for corrective action: Angela Westwood, CFO Planned completion date for corrective action plan: March 31, 2025.

View Audit 350577

Finding 540968 (2024-001)

Significant Deficiency 2024

Continuum of Care, Inc. and Affiliates

CT

Significant Deficiency Internal Control / Segregation of Duties

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Criteria or Specific Requirement: According to the client's internal control over payroll disbursements, hourly employees must maintain timesheets which are approved and signed by the property manager. Condition: Upon p...

Supportive Housing for Persons With Disabilities – Assistance Listing No. 14.181 Criteria or Specific Requirement: According to the client's internal control over payroll disbursements, hourly employees must maintain timesheets which are approved and signed by the property manager. Condition: Upon performing testing over payroll disbursements, we noted that there was no approval of the timesheet for the payroll disbursements tested. Questioned costs: None Context: The timesheet for 5 out of 5 payroll disbursements tested was not properly approved by the property manager. Cause: Turnover of property manager at the property management company and weaknesses in internal controls over payroll disbursements. Effect: There is no evidence of proper approval of payroll disbursement. Repeat Finding: Yes Recommendation: We recommend that management strengthen controls over review of payroll. Views of Responsible Officials: There is no disagreement with the audit finding. Action taken in response to finding: Although other controls assist to safeguard and mitigate compensation errors, the property manager will ensure that all time sheets are properly approved prior to payment, and if necessary the VP of Operations or the President of the managing agent will provide further assurance of internal controls through reviews. Name of the contact person responsible for corrective action: Angela Westwood, CFO Planned completion date for corrective action plan: May 30, 2025.

View Audit 350577

Finding 540959 (2024-012)

Significant Deficiency 2024

State of New Jersey

NJ

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

The Department of Human Services’ Division of Family Development (DHS/DFD) acknowledges the audit finding that 3 of the 40 sampled providers had not been inspected as required by program policy. DHS/DFD contracts with the Department of Children and Families’ Office of Licensing (“OOL”) as the regula...

The Department of Human Services’ Division of Family Development (DHS/DFD) acknowledges the audit finding that 3 of the 40 sampled providers had not been inspected as required by program policy. DHS/DFD contracts with the Department of Children and Families’ Office of Licensing (“OOL”) as the regulatory authority to monitor and inspect licensed centers and family child care providers. In response to this finding, OOL has implemented internal measures to ensure that monitoring occurs on an annual basis. These measure include the use of the New Jersey Child Care Information System (NJCCIS). A subsequent inspection of licensed child care centers was conducted on September 13, 2024. Regarding the two other family child care providers, the Child Care Resource and Referral (“CCR&R”) works in conjunction with OOL to track health and safety inspections. However, CCR&R did not monitor the two family child care providers in 2023. Since then, monitoring has been carried out in 2024 which included a review of the annual training requirements for these providers. To enhance compliance with inspections, CCR&R has acquired updated software to improve its monitoring capabilities. Copies of the 2024 inspection reports can be provided upon request. The DFD’s Office of Child Care will develop internal controls and procedures to ensure that inspections are performed as required by program policy. COMPLETION DATE/ CONTACT PERSON December 31, 2025 Andrea Breitwieser 609-588-4503 Andrea.Breitwieser@dhs.nj.gov

View Audit 350571

Finding 540948 (2024-008)

Significant Deficiency 2024

State of New Jersey

NJ

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

The Division of Aging Services (DoAS) hired a fiscal staff member in June of 2024. Responsibilities include the timely and accurate submission of FFATA reports. We are confident that with the additional staff we will be able to comply with managing FFATA reporting requirements and timely submissions...

The Division of Aging Services (DoAS) hired a fiscal staff member in June of 2024. Responsibilities include the timely and accurate submission of FFATA reports. We are confident that with the additional staff we will be able to comply with managing FFATA reporting requirements and timely submissions. COMPLETION DATE/ CONTACT PERSON June 30, 2025 Hetal Bhatt (609) 438-4586 Hetal.Bhatt2@dhs.nj.gov Mary Kurfuss (609) 564-2623 Mary.kurfuss@dhs.nj.gov

View Audit 350571

Finding 540945 (2024-006)

Significant Deficiency 2024

State of New Jersey

NJ

Special Tests & Provisions Cash Management Significant Deficiency § 200.303

The New Jersey Department of Transportation (NJDOT) has finalized its Utility Accommodation Policy (UAP) to align with federal requirements. The UAP follows the formal state regulatory process, and it was re-adopted on June 6, 2023, with technical changes. The UAP remains to be in full form and effe...

The New Jersey Department of Transportation (NJDOT) has finalized its Utility Accommodation Policy (UAP) to align with federal requirements. The UAP follows the formal state regulatory process, and it was re-adopted on June 6, 2023, with technical changes. The UAP remains to be in full form and effect. In compliance with the federal rules, the UAP is being amended to incorporate provisions for Broadband and Telecommunications and Video Surveillance. The amended language has been reviewed and approved by Federal Highway Administration (FHWA). The UAP is progressing through the formal regulatory process. The policy is expected to be published on April 7, 2025. A 60-day public comment period will follow, allowing stakeholders to provide feedback. Once the public comment period is completed, the revised UAP will be implemented immediately to ensure compliance. The DOT will continue to monitor the implementation and ensure that all utility accommodation actions align with the newly approved policy. COMPLETION DATE/ CONTACT PERSON & PHONE# Anticipated Completion Date: TBD but no later than December 30, 2025 Vince Martorana (609) 963-1825 Vince.Martorana@dot.nj.gov James Lepri (609) 963-1837 James.Lepri@dot.nj.gov

View Audit 350571

Finding 540940 (2024-004)

Significant Deficiency 2024

State of New Jersey

NJ

Reporting Matching / Level of Effort / Earmarking Significant Deficiency § 200.303

The New Jersey Department of Labor and Workforce Development (DLWD) continues to monitor workloads for both first payment and non-monetary time lapse measurements. Identity verification remains an issue with a segment of the claim population, and delays with claimants completing their ID verificat...

The New Jersey Department of Labor and Workforce Development (DLWD) continues to monitor workloads for both first payment and non-monetary time lapse measurements. Identity verification remains an issue with a segment of the claim population, and delays with claimants completing their ID verification has a direct bearing on first payment and non-monetary time lapse. DLWD will continue to work on improving communications around the importance of timely verifying ID and provide assistance to claimants that may be struggling with this process. DLWD has been working with USDOL to expand identity verification options and expects the new process to be in full production by June 30, 2025. It will allow claimants to report to any USPS Post Office for an in-person ID verification. This additional in-person option to complete ID verification provides greater flexibility for claimants to complete this requirement, especially those that struggle with the digital verification process that DLWD currently uses. We expect the new process to have a positive impact on time lapse scores and overall improvement for these metrics. Most recent time lapse figures showed that for the period November 2024 through February 2025, combined non-monetary time lapse exceeded the 80% ALP for each month. COMPLETION DATE/ CONTACT PERSON June 2025 Ronald Marino - DLWD (609) 292-2810 Ronald.Marino@dol.nj.gov

View Audit 350571

Finding 540938 (2024-003)

Significant Deficiency 2024

State of New Jersey

NJ

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

The New Jersey Department of Labor and Workforce Development (DLWD) has policies and procedures in place that ensure that internal controls over RESEA include retention of documentation of each participant’s eligibility. All required Reemployment Services and Eligibility Assessment (RESEA) forms are...

The New Jersey Department of Labor and Workforce Development (DLWD) has policies and procedures in place that ensure that internal controls over RESEA include retention of documentation of each participant’s eligibility. All required Reemployment Services and Eligibility Assessment (RESEA) forms are collected from the participant and reviewed to determine UI eligibility by staff that are trained in RESEA and UI policy. Staff are required to upload all participant documentation into our online case management system where the information is available to staff indefinitely. DLWD will continue to provide training to staff to ensure that all participants are provided services in a timely manner and that all documentation is uploaded into our case management system. Corrective actions will be fully implemented as of June 30, 2025. COMPLETION DATE/ CONTACT PERSON June 30, 2025 Baden Almonor (609) 777-1042 Baden.Almonor@dol.nj.gov

View Audit 350571

Finding 540936 (2024-002)

Significant Deficiency 2024

State of New Jersey

NJ

Questioned Costs Eligibility Internal Control / Segregation of Duties § 200.303

The New Jersey Department of Labor and Workforce Development (DLWD) has reviewed the controls in place for the Pandemic Unemployment Assistance (PUA) and Federal Pandemic Unemployment Compensation (FPUC) programs that expired with payments for CWE 9/4/21. The system controls in place for FPUC con...

The New Jersey Department of Labor and Workforce Development (DLWD) has reviewed the controls in place for the Pandemic Unemployment Assistance (PUA) and Federal Pandemic Unemployment Compensation (FPUC) programs that expired with payments for CWE 9/4/21. The system controls in place for FPUC continues to require that an underlying UI/PUA payment must first be issued before any FPUC payment could be generated. Similar controls were in place for any PUA payments, where claimants have to choose a valid pandemic related reason for being unemployed before any PUA payment could be issued. These controls, before any CARES Act related payment could be issued, were in place for the duration of the CARES Act program. No PUA or FPUC payment should be issued without these requirements being met. We will continue to enforce these controls. COMPLETION DATE/ CONTACT PERSON September 30, 2024 Ronald Marino - DLWD (609) 292-2810 Ronald.Marino@dol.nj.gov

View Audit 350571 Questioned Costs: $1

Finding 540931 (2024-001)

Significant Deficiency 2024

Community Service Society of New York

NY

Subrecipient Monitoring Reporting Significant Deficiency

Community Service Society (the Society) requires its subrecipients to submit their financial and progress program reports fifteen days after the end of the reporting period. This is done so that the Society can review the underlying documentation in those reports to ensure that proper payments are m...

Community Service Society (the Society) requires its subrecipients to submit their financial and progress program reports fifteen days after the end of the reporting period. This is done so that the Society can review the underlying documentation in those reports to ensure that proper payments are made to the subrecipients and, in turn, proper and timely reports are filed by the Society with the State of New York. There are instances when, because of delays in receipt of information from the subrecipients, or information from the subrecipients needs to be revised, reports are submitted late to the State of New York. The Society notifies the State of New York when reports will be submitted late. In addition, the Society is working with its subrecipients to improve their reporting procedures, as well as the timeliness and accuracy of their reports. This will result in the Society improving the timeliness of its reporting to the State of New York.

View Audit 350570

Finding 540878 (2024-002)

Significant Deficiency 2024

City of Waltham, Massachusetts

MA

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency

Moving forward all Time & Efforts Records for federal grant funded positions will be on a single schedule (December and June) of each calendar year and tracked by each program department with support from administrative assistants. All forms will be collected electronically and remain on file in one...

Moving forward all Time & Efforts Records for federal grant funded positions will be on a single schedule (December and June) of each calendar year and tracked by each program department with support from administrative assistants. All forms will be collected electronically and remain on file in one central location in the Finance Department through Grants. This process was begun last year and worked well, but we learned that we need to include a mechanism for ensuring that staff complete Time and Effort forms upon their departure if they leave their role/the district prior to the December or June collection dates. We are working with HR to make sure that this is part of the exit process for any federally-funded staff.

View Audit 350527 Questioned Costs: $1

Finding 540829 (2024-001)

Significant Deficiency 2024

Newbern Housing Authority

TN

Questioned Costs Cash Management HUD Housing Programs

2024-001 FINDING: Excess Reimbursement Requested (Public Housing Capital Fund - ALN 14.872) – Significant Deficiency and Noncompliance Person responsible for Implementing the Corrective Action: The Board of Commissioners and David Jones Anticipated Completion Date of Corrective Action: June 30, ...

2024-001 FINDING: Excess Reimbursement Requested (Public Housing Capital Fund - ALN 14.872) – Significant Deficiency and Noncompliance Person responsible for Implementing the Corrective Action: The Board of Commissioners and David Jones Anticipated Completion Date of Corrective Action: June 30, 2025 Planned Corrective Action: The Authority will work on ensuring requests for reimbursement of capital funds will have supporting documentation and management will take measures to ensure duplicate requests aren't made for a single invoice.

View Audit 350466 Questioned Costs: $1

Finding 540826 (2024-004)

Significant Deficiency 2024

Muncie Community Schools

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.302 § 200.303 § 200.328

FINDING 2024-004 – COVID-19 – Education Stabilization Fund – Reporting Context: The School Corporation was required to submit one Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that t...

FINDING 2024-004 – COVID-19 – Education Stabilization Fund – Reporting Context: The School Corporation was required to submit one Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported for the reports covering the FY23 time period ($4,934,473) did not agree to the underlying expenditure records ($4,801,053) for the period of July 1, 2022 through June 30, 2023. Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: 765-747-5222 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all ESSER reports include accurate information that agree to the underlying disbursement records. Anticipated Completion Date: Next ESSER reports due in FY25

View Audit 350456

Finding 540746 (2024-001)

Significant Deficiency 2024

Interfaith Residence D/b/a Doorways and Related Entities

MO

Subrecipient Monitoring HUD Housing Programs Reporting

Finding 2024-001 Personnel Responsible for Corrective Actions: Megan Robinson, Chief Financial Officer and Carrie Bagwell, Director of Government Grants and Compliance Anticipated Completion Date: February 2025 Corrective Action Plan: Management recognized the need for additional staff capacity t...

Finding 2024-001 Personnel Responsible for Corrective Actions: Megan Robinson, Chief Financial Officer and Carrie Bagwell, Director of Government Grants and Compliance Anticipated Completion Date: February 2025 Corrective Action Plan: Management recognized the need for additional staff capacity to administer all required duties and hired an Outstate Program and Grants Manager on February 1, 2025 to focus on these tasks. The position is overseen by the Director of Government Grants and Compliance, who is knowledgeable about the service and reporting requirements of this program. Additionally, starting in February 2025, the team implemented bi-monthly meetings to update the Chief Financial Officers on progress and timely filing of all grants related reporting to ensure all deadlines are met.

View Audit 350444

Finding 540741 (2024-001)

Significant Deficiency 2024

City of Columbia, Missouri

MO

Reporting Significant Deficiency

The Department of Public Health and Human Services (PHHS) will create the proper processes and procedures to track reporting requirements and document internal review and approvals prior to report submissions. The Grant Administrator will create the proper processes and procedures to track reporting...

The Department of Public Health and Human Services (PHHS) will create the proper processes and procedures to track reporting requirements and document internal review and approvals prior to report submissions. The Grant Administrator will create the proper processes and procedures to track reporting requirements and completed submissions, and notify departments of upcoming submission deadlines. Contact Person: Matthew Lue, Director of Finance. Ancipated Completion Date: This will be accomplished for the fiscal year 2025 year-end.

View Audit 350428

Finding 540711 (2024-001)

Significant Deficiency 2024

Jobpath, Inc.

AZ

Subrecipient Monitoring Reporting Significant Deficiency

We identified the issue and the employee responsible was removed. As of July 1, 2024 the Data systems and Eligibility Manager is responsible for reporting with the added oversight and sign off from the Director of Operations.

View Audit 350398

Finding 540698 (2024-003)

Significant Deficiency 2024

McKendree University

IL

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

2024-003 Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants – 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 Loans – Assistance Listing No. 84.268...

2024-003 Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants – 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 Loans – Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants– Assistance Listing No. 84.379 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The McKendree University Financial Aid Office has an automated daily process for notifying COD of all federal aid disbursements after a disbursement is made to a student’s account. This process also includes a step for checking the COD website for any rejected files to confirm that students were correctly reported within a day of loan and TEACH grant disbursements occurring, well within the 15-day required notification time frame. Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025

View Audit 350395

Finding 540697 (2024-002)

Significant Deficiency 2024

McKendree University

IL

Matching / Level of Effort / Earmarking Eligibility Significant Deficiency § 200.303

2024-002 Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants – 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 Loans – Assistance Listing No. 84.268...

2024-002 Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants – 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 Loans – Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants– Assistance Listing No. 84.379 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the Federal Student Aid handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Part of the weekly procedure for federal loan and TEACH grant disbursements includes Loan Disbursement Notifications to all students immediately after the loan is disbursed to a student’s account. This process now includes a step for a second check of the loan disbursements to ensure that all loan and TEACH grant disbursements have been sent the notified via campus and external email. Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025

View Audit 350395

Finding 540696 (2024-001)

Significant Deficiency 2024

McKendree University

IL

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency § 200.303

UNITED STATES DEPARTMENT OF EDUCATION 2024-001 Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants – 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...

UNITED STATES DEPARTMENT OF EDUCATION 2024-001 Student Financial Assistance Cluster Federal Supplemental Educational Opportunity Grants – 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 Loans – Assistance Listing No. 84.268 Teacher Education Assistance for College and Higher Education Grants– Assistance Listing No. 84.379 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their Written Information Security Program includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While significant progress has been made towards GLBA compliance, there was not time to fully implement the corrective action plan prior to June 30, 2024 given the timing of the audit completion. An Information Security Governance Committee has been established and one of the key responsibilities of the committee is to review the Written Information Security Program (WISP) against GLBA requirements to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Christine Tweedy, CIO & Director of IT Planned completion date for corrective action plan: June 30, 2025

View Audit 350395

Finding 540693 (2024-001)

Significant Deficiency 2024

Families First, Inc.

GA

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Grantee Response and Corrective Action Plan: The CFO met with both the Director of Parenting and Adoption Support Services and the Access and Visitation Program Supervisor to discuss the finding and improve the invoice process. The preparation of the invoice is a team effort and involves at a minimu...

Grantee Response and Corrective Action Plan: The CFO met with both the Director of Parenting and Adoption Support Services and the Access and Visitation Program Supervisor to discuss the finding and improve the invoice process. The preparation of the invoice is a team effort and involves at a minimum seventy-five documents and attachments per invoice. To minimize the risk of omitting required documentation, the Director or designated staff will review the invoice package prior to submission to the funder and an invoice checklist task will be developed and completed. Contact person(s) responsible for corrective action: Schwanna C. Lakine The anticipated completion date is June 30, 2025.

View Audit 350393

Finding 540603 (2024-001)

Significant Deficiency 2024

Grand Rapids Housing Commission

MI

HUD Housing Programs Eligibility Significant Deficiency

GRHC Response & Corrective Action Plan The GRHC does not dispute the finding and acknowledges the deficiencies identified. Due to staff shortages and turnover, GRHC experienced challenges in maintaining consistent file management, eligibility determinations, and recertifications in strict complian...

GRHC Response & Corrective Action Plan The GRHC does not dispute the finding and acknowledges the deficiencies identified. Due to staff shortages and turnover, GRHC experienced challenges in maintaining consistent file management, eligibility determinations, and recertifications in strict compliance with HUD requirements. However, prior to the auditor’s testing that resulted in this finding, the GRHC had already begun discussing strategies to address these issues. Recognizing the need for stronger internal controls and process improvements, the GRHC initiated a plan to enhance file management, compliance monitoring, and process reviews. This plan includes: Process Mapping of Critical Functions to standardize workflows, ensure consistency, and eliminate inefficiencies. Digitization of forms to improve efficiency and reduce errors. Electronic document signing to streamline tenant file processing. Internal control checklists to ensure completeness and accuracy before file submission. Quality control (QC) review of all files by a manager before final submission to ensure compliance with HUD regulations. Strategies for these improvements began in August 2024 and are scheduled for full implementation by July 2025. GRHC leadership has been actively monitoring these efforts and meeting regularly to ensure progress toward compliance. Corrective Actions & Implementation Plan Corrective Action Responsible Group Completion Date Status Process mapping of critical workflows to ensure standardized procedures for eligibility and recertifications. Policy and Program Feb 2025 Completed Implement digitization of forms to streamline eligibility and recertification processes. Policy and Program 30-Apr-25 In Progress Introduce electronic document signing to enhance efficiency and reduce processing time. Policy and Program /IT 30-Apr-25 In Progress Develop and enforce internal control checklists for eligibility and recertifications. Policy and Program/IT 31-May In Progress Provide staff training on new processes and HUD compliance requirements. Policy and Program 30-Apr-25 Planned Conduct internal audits to evaluate the effectiveness of the new controls before manager QC begins. Policy and Program 30-Jun-25 Planned Require manager-level QC review of all tenant files before submission. Program Managers 01-Jul-25 Planned Implement a formal backup plan to ensure timely eligibility processing during staff absences or workload surges. ED/Program Directors 01-July-25 Planned Regular reporting to GRHC leadership on the status of tenant file compliance improvements. ED/Policy and Program Ongoing Planned Expected Outcome Full compliance with HUD requirements for eligibility and recertifications. Improved internal controls to prevent future deficiencies. A sustainable QC system for ongoing compliance monitoring. Monitoring & Follow-Up The Policy and Program Implementation Manager will oversee corrective actions and provide bi-weekly progress updates. The Executive Director will present the Corrective Action Plan at the next board meeting. Contact Person: Jose L. Capeles Title: Policy and Program Planning and Implementation Manager Date: 03/28/2025

View Audit 350376

Finding 540600 (2024-001)

Significant Deficiency 2024

University of Pittsburgh of the Commonwealth Sys. of Higher Education

PA

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

Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Year: Funding periods between July 1, 2023 through June 30, 2024 Compliance Requirement: Eligibility Finding Type: Noncompliance and Signi...

Finding 2024-001 Federal Agency: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.268 Federal Award Year: Funding periods between July 1, 2023 through June 30, 2024 Compliance Requirement: Eligibility Finding Type: Noncompliance and Significant Deficiency The School of Dental Medicine did not have a report to identify students with a federal loan aggregate related issue. The Office of Admissions and Financial Aid had a report for students in the undergraduate and graduate careers (excluding the Dental Medicine professional Primary Academic Program). The Office of Admissions and Financial Aid added the School of Dental Medicine staff as a recipient on this report to assist them in identifying students with an ISIR code indicating students that are approaching or have already exceeded the Federal Direct Loan aggregate limits for review. Since September 2024, the School of Dental Medicine has been receiving and reviewing the Aggregate Overpay Checklist report. Name of the contact person: Michelle Jackson Completion date: Already completed, September 2024

View Audit 350369 Questioned Costs: $1

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