Corrective Action Plans

Finding 540596 (2024-003)

Significant Deficiency 2024

OR

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

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU acknowledges at the time of the audit; management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract p...

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU acknowledges at the time of the audit; management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract portal as there is no repository or database available to schools. This submission was completed on March 17, 2025 and documentation was retained to support the submission. Name(s) of the contact person(s) responsible for corrective action: Daniel M. Tramuta, Interim Director of Financial Aid Planned completion date for corrective action plan: March 2025

View Audit 350358

Finding 540595 (2024-002)

Significant Deficiency 2024

Southern Oregon University

OR

Questioned Costs Student Financial Aid Eligibility

Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made. Explanation of disagreement with audit f...

Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU will review its policies and procedures for Direct Loan entrance counseling to ensure all students, including GRAD PLUS loan recipients, have completed their entrance counseling or previously completed counseling is retained within the student information system. Name(s) of the contact person(s) responsible for corrective action: Daniel M. Tramuta, Interim Director of Financial Aid Planned completion date for corrective action plan: April 2025

View Audit 350358 Questioned Costs: $1

Finding 540593 (2024-001)

Significant Deficiency 2024

Southern Oregon University

OR

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: Ther...

Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Student Records Specialist and University Registrar will be reviewing and revising policies and procedures related to enrollment reporting with the Clearinghouse data which then feeds into NSLDS. SOU will review calendar preparations, data collection, data submission and confirmation, error handling, file preparation documentation/instructions to identify breakdown in the process that lead to noncompliant reporting. SOU will increase monitoring of Clearinghouse data and also reach out to Clearinghouse to identify reports/tools that can assist with accurate and timely reporting. Name(s) of the contact person(s) responsible for corrective action: Rose Reinhart, Interim Registrar Planned completion date for corrective action plan: June 2025

View Audit 350358

Finding 540592 (2024-005)

Significant Deficiency 2024

Municipality of Vega Baja

PR

Matching / Level of Effort / Earmarking Cash Management Significant Deficiency

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit P...

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2024-005 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action : The ACUDEN agency has not yet closed the budget year 2023-2024. Therefore, even though the contract has ended, the remaining reimbursement from the agency has not been received. Therefore, the full closing report cannot be completed until this final amount is received. As a corrective measure for finding 2024-005, the Sub Director of Finance will establish an internal control system in which the processes and compliance with the submission of accounting reports for federal programs, including Child Care, will be periodically monitored. Implementation Date: Fiscal Year 2025-2026. Responsible Person: José A. Mathews Maisonet Program Accountant

View Audit 350357

Finding 540591 (2024-004)

Significant Deficiency 2024

Municipality of Vega Baja

PR

Subrecipient Monitoring Cash Management Reporting

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit P...

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2024-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: The ACUDEN agency has not yet closed the budget year 2023-2024. Therefore, even though the contract has ended, the remaining reimbursement from the agency has not been received. Therefore, the full closing report cannot be completed until this final amount is received. As a corrective measure for finding 2024-005, the Sub Director of Finance will establish an internal control system in which the processes and compliance with the submission of accounting reports for federal programs, including Child Care, will be periodically monitored. Implementation Date: Fiscal Year 2025-2026. Responsible Person: José A. Mathews Maisonet Program Accountant

View Audit 350357

Finding 540590 (2024-003)

Significant Deficiency 2024

Municipality of Vega Baja

PR

Subrecipient Monitoring Reporting Significant Deficiency § 200.302 § 200.328 § 200.329

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit P...

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2024-003 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: In the quarterly reports (QPR), accumulated expenses are reported up to the closing date of each quarter. These expenses are assigned to the quarter in which the contractor invoices the completed work. However, in some cases, the payment is made in the quarter following the one in which the invoice was issued. This discrepancy may cause the expenses not to be accurately reflected in the quarter they were reported during the audit process. This situation will be addressed prospectively, and expenses will be assigned to the quarter in which the payment is made. Implementation Date: Fiscal Year 2025-2026. Responsible Person: José A. Torres Otero Program Accountant

View Audit 350357

Finding 540538 (2024-007)

None 2024

New Mexico Department of Homeland Security & Emergency Management

NM

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Recommendation We recommend that the Department enhance its process for auditing packets submitted by subrecipients to ensure that all invoices are provided to support total costs. Management Response Corrective Action: We concur with this finding and the auditor's recommendation. The Department is...

Recommendation We recommend that the Department enhance its process for auditing packets submitted by subrecipients to ensure that all invoices are provided to support total costs. Management Response Corrective Action: We concur with this finding and the auditor's recommendation. The Department is working on obtaining the accounting, where an entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project was in compliance with the provisions of FEMA-State agreement The proper closing of the grants will be the focus of the Grants Unit to make sure the Department communicates and obtains the needed information from the recipients. Due Date of Completion: June 30, 2025 Responsible Party: Deputy Cabinet Secretary, Grants Unit Manager

View Audit 350283

Finding 540536 (2024-006)

Significant Deficiency 2024

New Mexico Department of Homeland Security & Emergency Management

NM

Reporting Subrecipient Monitoring Cash Management § 200.302 § 200.303

Recommendation We recommend the Department review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete. We recommend the Department implement effecti...

Recommendation We recommend the Department review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete. We recommend the Department implement effective processes and procedures to maintain the submitted reports and the documentation used to prepare the reports in the files of the Department. Management Response Corrective Action: The Department understands the issues and is continuing to take corrective action to improve reporting. In the past the Department has shifted its priority to onboarding across the Department, and we have onboarded a Grants Unit Manager to oversee the reporting requirements of all federal grants. The Grants Unit will focus on procedures to ensure the reporting requirements are met. A procedural checklist will be implemented to ensure that: 1. the recipient share section is completed, 2. that financial reports are submitted to the Department timely, and 3. all Performance Progress Reports as submitted. Due Date of Completion: June 30, 2025 Responsible Person(s): Deputy Cabinet Secretary, Grants Unit Manager

View Audit 350283

Finding 540513 (2024-008)

Significant Deficiency 2024

State of Hawaii, Department of Accounting and General Services

HI

Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency

Finding No: 2024-008 ALN No.: 17.258 Program Title: WIOA Adult Program 17.259 Program Title: WIOA Youth Activities 17.278 Program Title: WIOA Dislocated Worker Formula Grant (WIOA Cluster) Grant Award No.: AA347643L0 2022 AA347645P0 2022 Condition During the audit, it was noted that an excess 0.63% ...

Finding No: 2024-008 ALN No.: 17.258 Program Title: WIOA Adult Program 17.259 Program Title: WIOA Youth Activities 17.278 Program Title: WIOA Dislocated Worker Formula Grant (WIOA Cluster) Grant Award No.: AA347643L0 2022 AA347645P0 2022 Condition During the audit, it was noted that an excess 0.63% of funds were allocated for employment and training activities for adults and dislocated workers. The lead WIOA accountant who completed the close-out report at issue is no longer employed by DLIR. Corrective Action Plan Following the departure of the lead WIOA accountant who completed the subject closeout report, the Administrative Services Office (ASO) has heightened fiscal training and internal controls among its two new WIOA accountants to ensure that the federal award is managed in compliance with all terms and conditions of the award, including requirements pertaining to subrecipient earmarking, so no more than 15% of funds are expended towards the administrative costs category for the WIOA Title I Adult, Dislocated Worker, and Youth Programs. The Workforce Development Council (WDC) is also in the process of contracting with a selected vendor to develop in-depth, in-person fiscal training to be held in June 2025 that will support fiscal staff, including local areas’ fiscal staff, to better understand and navigate the financial management and budgeting for Workforce Innovation and Opportunity Act (WIOA) services. Person Responsible Lynn Araki-Regan Anticipated Date of Completion June 30, 2025

View Audit 350263

Finding 540428 (2024-002)

Significant Deficiency 2024

City of Pasadena

CA

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

Reference Number: 2024-002 Name of Contact Person: Armine Trashian, Controller Corrective Action: The City will implement recommendations and maintain all compliance-related documentation to ensure all necessary documents are maintained in accordance with ongoing compliance requirements. Proposed...

Reference Number: 2024-002 Name of Contact Person: Armine Trashian, Controller Corrective Action: The City will implement recommendations and maintain all compliance-related documentation to ensure all necessary documents are maintained in accordance with ongoing compliance requirements. Proposed Completion Date: June 30, 2025

View Audit 350245

Finding 540413 (2024-009)

Significant Deficiency 2024

Department of Human Services

HI

Eligibility Period of Performance Reporting

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: We are actively addressing this issue while highlighting the Division of Vocational Rehabilitation’s (“DVR’s”) high compliance rate of 98.3 percent. The...

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: We are actively addressing this issue while highlighting the Division of Vocational Rehabilitation’s (“DVR’s”) high compliance rate of 98.3 percent. The Vocational Rehabilitation Specialist (“VRS”) and the Vocational Rehabilitation Manager have been thoroughly informed about the correct data entries required for Service E (work experiences while in Service status). It’s essential to note that “competitive integrated employment” must not be selected for Service E status. Instead, staff should choose alternatives such as “internships, whether paid or unpaid,” or “transitional employment” to ensure accurate data recording and prevent the inclusion of data element 350. Additionally, “competitive integrated employment” requires the client to be actively employed in alignment with their employment goal outlined in their Individualized Plan for Employment with a stable employment value date entered in the employment record. To assist our staff in this process, the Aware-System Bulletin will include a clear reminder to verify both the employment status and the stable employment value date for each case. Instructions for using the managed layout edit checker will also be provided, equipping staff with the necessary tools to identify errors and make corrections independently. The VRS will ensure that the Service E or Employed status aligns appropriately with the appropriate employment categories. This corrective action reinforces best practices and significantly improves staff compliance with the accuracy of our data from DVR’s case management system. Completion Date: On going monitoring and training as needed. Responding Official(s): Lea Dias, Vocational Rehabilitation Administrator and R. Pascual-Kestner, Vocational Rehabilitation Assistant Administrator

View Audit 350226

Finding 540404 (2024-003)

Significant Deficiency 2024

Department of Human Services

HI

Special Tests & Provisions Significant Deficiency Equipment & Real Property Management

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: In addition to our Electronic Benefit Transfer (“EBT”) Management Evaluations of the Processing Centers, which occur on a rotational basis of once every...

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: In addition to our Electronic Benefit Transfer (“EBT”) Management Evaluations of the Processing Centers, which occur on a rotational basis of once every three years, the EBT Office will go out and visit in-person each Processing Center on Oahu, to do a spot check to ensure the Processing Centers are following the EBT Card Security Procedures on an annual basis. Also, for the Neighbor Island Processing Centers, the EBT Office will do a desk review of the DHS 1494, DHS 1495, and DHS 1050 forms and conduct a Teams Virtual Meeting with the Processing Center’s Supervisor(s) to ensure the EBT Card Security Procedures are being followed. In addition to EBT Management Evaluations, in person spot checks, and desk review with Virtual Team Meetings for Neighbor Island, the EBT Project Manager will make periodic reminder announcements for Processing Centers to adhere to the EBT Card Security Procedures at the monthly Joint Section Meetings to account for changes in staff that maybe new and not familiar with the EBT Card Security Procedures. Completion Date: June 2026 Responding Official(s): Sabrina Young, Benefit, Employment, and Support Services Division Electronic Benefit Transfer Project Manager

View Audit 350226

Finding 540401 (2024-014)

Significant Deficiency 2024

Department of Human Services

HI

Questioned Costs Eligibility Reporting

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Upon further review of the case, it was determined that the caseworker processed the case in “Manual Eligibility” mode which prevented the Kauhale On Line Eligibility Assistance System (“KOL...

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Upon further review of the case, it was determined that the caseworker processed the case in “Manual Eligibility” mode which prevented the Kauhale On Line Eligibility Assistance System (“KOLEA”) from terminating benefits. Another worker removed “Manual Eligibility” mode in January enabling KOLEA to process the case and send a termination notice. The worker should have processed the case and taken the case out of “Manual Eligibility” mode when case processing was complete. Corrective Action Taken or Planned: The “Eligibility Determination” training module will be updated to include additional instructions for Manual Actions in the Kauhale On Line Eligibility Assistance System (“KOLEA”). Workers will be instructed to seek guidance from a supervisor for next steps, before running a case manually. This training will be provided on April 30, 2025, to all supervisors and caseworkers and will include a Participant Guide and a summary of the change. To ensure that the training was effective, a query will be run of all cases that are set to “manual,” including the date in which the case was placed in manual. Med-QUEST Division (“MQD”) will review all identified cases to determine if the case should remain in manual for any legitimate eligibility reason. Completion Date: April 30, 2025 Responding Official(s): Lori Lei Aponte, Med-QUEST Division, Eligibility Branch Administrator

View Audit 350226 Questioned Costs: $1

Finding 540398 (2024-013)

Significant Deficiency 2024

Department of Human Services

HI

Questioned Costs Special Tests & Provisions Eligibility

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Department has engaged with a vendor to implement our new online provider enrollment system HOKU on August 3, 2020 and started the process to have al...

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Department has engaged with a vendor to implement our new online provider enrollment system HOKU on August 3, 2020 and started the process to have all providers re register their information in the new online system. Most providers were given a deadline to do this by December 31, 2023 and if missed they would be terminated in 2024. There are a few providers who did not re register by December 31, 2023, and these were primarily providers of exclusive or specific services who refused to enroll into HOKU. Not enrolling these providers will have a disruptive impact to the service delivery experience and greatly increase the costs to the program, by risking the Department having to send additional patients to the mainland to get the specialized medical care needed. The Department will be terminating these remaining providers by December 31, 2025. Additionally, the Department is planning to apply for an 1115 demonstration waiver amendment in 2025, to waive the 42 CFR 455.414 provider enrollment requirements for these few providers with exclusive services. Completion Date: December 31, 2025 Responding Official(s): Marvin Malohi, Med-QUEST Division, Supervising Contracts Specialist

View Audit 350226 Questioned Costs: $1

Finding 540397 (2024-012)

Significant Deficiency 2024

Department of Human Services

HI

Questioned Costs Special Tests & Provisions Eligibility

Views of Responding Officials: The Department does not agree with this finding. According to 45 CFR section 205.55, it states, “…the State agency will request through the Income Eligibility and Verification System (“IEVS”)…”. However, the policy does not specify the State agency must “properly us...

Views of Responding Officials: The Department does not agree with this finding. According to 45 CFR section 205.55, it states, “…the State agency will request through the Income Eligibility and Verification System (“IEVS”)…”. However, the policy does not specify the State agency must “properly use IEVS information to evaluate benefit amounts…” as notated in this finding under “Effect.” Unless IEVS provides the necessary information for the applicable benefit month(s) used to determine a TANF applicant’s or recipient’s (“client”) eligibility, information obtained through IEVS will only validate whether a household received an income source, after the fact, but will not verify the dollar amount. Hard-copy verification is obtained from the client to verify income source and dollar amount, for the applicable benefit months, to determine eligibility in accordance with §17 676-51, Hawaii Administrative Rules. For example, if a client applied for TANF on February 28, 2025, and the department processes the application on March 20, 2025 (current month), verification of the household’s income received in February 2025 and received thus far in March 2025, must be obtained to determine eligibility for the month of application (February 2025) and subsequent months (based on projected income). Data obtained from IEVS are not current; therefore, if the information obtained from IEVS is used to determine eligibility, then we would violate our own administrative policy (i.e., §17 676-51, Hawaii Administrative Rules). For example, wage information through SWICA becomes available on a quarterly basis. The most current SWICA information available would have been for quarter ending December 31, 2024, for an application received on February 28, 2025, that was processed on March 20, 2025. Eligibility determination would have been improperly made if SWICA information from IEVS was applied. Corrective Action Taken or Planned: The department will continue to conduct IEVS check. The information obtained will only be used to validate a source of income reported by the applicant/client IF the information is applicable. Completion Date: On going Responding Official(s): Catherine Scardino, Benefit, Employment, and Support Services Division Temporary Assistance for Needy Families Program Administrator

View Audit 350226 Questioned Costs: $1

Finding 540396 (2024-011)

Significant Deficiency 2024

Department of Human Services

HI

Questioned Costs Special Tests & Provisions Eligibility

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Temporary Assistance for Needy Families (“TANF”) Program Office will collaborate with the division’s Staff Development Office to develop “refresher” ...

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Temporary Assistance for Needy Families (“TANF”) Program Office will collaborate with the division’s Staff Development Office to develop “refresher” training modules on the Benefit, Employment, and Support Services Division (“BESSD”) Learning Academy. Each training module will focus on a specific topic of concern. To monitor staff’s completion of the training modules and their progress, each module will include a quiz or test at the end that staff will be required to complete and pass (e.g., pass equates to a score of 80% and higher). The TANF Program Office and the Staff Development Office began discussions on February 26, 2025. Completion Date: December 31, 2025 Responding Official(s): Catherine Scardino, Benefit, Employment, and Support Services Division Temporary Assistance for Needy Families Program Administrator

View Audit 350226 Questioned Costs: $1

Finding 540343 (2024-001)

Significant Deficiency 2024

City of San Diego

CA

Procurement, Suspension & Debarment Subrecipient Monitoring HUD Housing Programs

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact t...

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact that the FSRS.gov system has since been retired and integrated into the SAM.gov system acknowledges the need for reducing duplicate recording in favor of an integrated system. Staff’s understanding of the process was in line with available guidance currently still posted on HUD’s website (https://www.hud.gov/sites/dfiles/CPD/documents/CPD_FSRS_Learning_Session_Final_8.26.21.pdf). The City of San Diego did not receive notification of the FSRS deadline from HUD for Fiscal Year (FY) 2024. With regard to the dates entered in the FSRS.gov system, the agreements’ effective dates cover the entire fiscal year, and the awards were approved by our City Council to be in effect for the full fiscal year. Hence, staff entered the date July 1, 2023. Management accepts that going forward, dates should be entered based on the date the agreements are fully executed. Management agrees to include specific FFATA training and procedures in all CDBG manuals and checklists including procedures for compliance, if and when federal agency communication is late or lacking. Implementation Date: The conditions described above have already been corrected. FFATA training and procedures will be implemented within 30 days. Contact: Michele Marano Assistant Deputy Director, Community Development Economic Development Department City of San Diego Email: mmarano@sandiego.gov Phone: 619.236.6381

View Audit 350217

Finding 540332 (2024-002)

Significant Deficiency 2024

People Incorporated of Virginia and Affiliates

VA

Reporting HUD Housing Programs Significant Deficiency

Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards Condition: During the audit, Wipfli LLP noted there were certain federal grants received from pass-through entities that were inadvertently excluded from the Schedule of Expenditures of Federal Awards. Management’s Res...

Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards Condition: During the audit, Wipfli LLP noted there were certain federal grants received from pass-through entities that were inadvertently excluded from the Schedule of Expenditures of Federal Awards. Management’s Response PINC management acknowledges that some funds were inadvertently excluded from the Schedule of Expenditures of Federal Awards due to a combination of a recent CFO leadership transition and an outdated accounting system. However, these issues were not a result of fraud or misuse of funds, and the discrepancies were quickly addressed without any negative impact on the financial statements or audit timeline. The company is actively working to implement a new accounting system with an improved grants module to prevent similar issues in the future. These proactive steps reflect our commitment to compliance, financial accuracy, and continuous improvement in reporting processes. Contact Person Responsible for Corrective Action: Joshua Pevarnik, VP & CFO Anticipated Completion Date: Ongoing and by 6/30/2025

View Audit 350213

Finding 539714 (2024-012)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Reporting Significant Deficiency

Finding Reference: 2024-012 - SFA Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has established a formalized procedure, effective immediately, to ensure the accurac...

Finding Reference: 2024-012 - SFA Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has established a formalized procedure, effective immediately, to ensure the accuracy and compliance of the annual Fiscal Operations Report and Application to Participate (FISAP). As part of this process, a FISAP Review Committee will be created to oversee the review of the FISAP and all supporting documentation at least three weeks before the official submission deadline. The FISAP will be prepared by the Executive Director of Student Financial Aid Services and Scholarships, who will also gather and compile all necessary supporting documentation. This completed report, along with all relevant data, will then be submitted to the FISAP Review Committee for thorough examination. The committee will verify the accuracy of all figures and ensure that the supporting documents meet FISAP compliance requirements. Submission of the FISAP will only proceed once the FISAP Review Committee has reached a consensus confirming the accuracy and completeness of the report. This structured review process will help safeguard against errors, enhance compliance, and ensure that JSU meets all federal reporting standards. Estimated Completion Date: September 1, 2025

View Audit 350191

Finding 539713 (2024-011)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Allowable Costs / Cost Principles HUD Housing Programs Significant Deficiency § 200.1 § 200.302 § 200.307

Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of ...

Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of the program. UMMC will make efforts to ensure that all practices and policies are clearly documented and evaluated periodically. Estimated Completion Date: June 30, 2025

View Audit 350191

Finding 539685 (2024-003)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

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

Finding Reference: 2024-003 - SFA COD Reporting (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU reconciles Pell and federal direct student loans to COD monthly. The reconciliation is done timely, and ASU will continue to reconcile and pr...

Finding Reference: 2024-003 - SFA COD Reporting (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU reconciles Pell and federal direct student loans to COD monthly. The reconciliation is done timely, and ASU will continue to reconcile and provide evidence of review. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships; Ms. Lakesha Tubbs, Registrar; Adrienne Walls, Bursar Corrective Action Planned: In previous years, Jackson State University has extended the purge and registration dates to better serve a high number of students from underrepresented communities and low-income backgrounds, ensuring that they have the opportunity to complete the enrollment process. However, this practice has led to inaccurate reporting of enrollment dates. Moving forward, Jackson State University will work with new, continuing, and readmit students beginning in April 2025 through the start of the Fall 2025 semester on August 18, 2025, to ensure all enrollment materials are completed before the beginning of each term. As part of this effort, Jackson State University has redesigned its new student orientation process with the goal of ensuring students are completely registered before arriving on campus for the fall semester. Within this new model, a dedicated position has been created for First-Time Freshmen to establish proactive outreach and education regarding costs to students and families. The redesigned orientation process places a strong emphasis on First-Time Freshmen, guaranteeing they receive the necessary guidance and support to successfully transition into college life. Additionally, the university will enforce enrollment deadline dates to prevent inaccurate enrollment data and eliminate errors in disbursement records. In addition to enhancing the student enrollment process, JSU is also taking steps to strengthen financial accountability. Furthermore, Jackson State University’s Financial Aid Office, in coordination with its Business Office, will begin holding regularly scheduled reconciliation meetings at the end of each month. These meetings will ensure that the amounts disbursed on both sides align and that figures from both departments match what has been drawn down and either paid out or returned to the U.S. Department of Education Common Origination and Disbursement (COD). Both departments will also utilize an institutional reconciliation document to add another layer of control and prevent errors. These strategic improvements reflect Jackson State University’s ongoing commitment to compliance, operational efficiency, and student success. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The internal control procedures will initiate a reconciliation of disbursement dates against COD data. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (UMMC) Responsible Official: Davita Weary, Director of Student Financial Aid Corrective Action Planned: Reconciliations will be reviewed with Kelly Dismuke, Director of Finance Operations, on a monthly basis. Estimated Completion Date: March 26, 2025 Finding Reference: 2024-003 - SFA COD Reporting (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: USM reconciles Pell and DL monthly. Copies of reconciliations are saved in a shared drive and can be made available upon request. The reconciliations will be reviewed on a monthly basis by the Financial Aid Assistant Director (Alanna McDonald) and Director (David Williamson), and the Bursar (Barbara Madison) when necessary. Estimated Completion Date: March 17, 2025

View Audit 350191

Finding 539678 (2024-008)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: The Jackson State University Division of Financial Aid has implemented a co...

Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: The Jackson State University Division of Financial Aid has implemented a comprehensive training initiative to strengthen compliance, improve accuracy, and enhance staff proficiency in federal student aid verification. As of May 7, 2024, ongoing training has commenced for all financial aid staff on the 2024-2025 verification process and required documentation. Additionally, beginning April 4, 2025, the department will launch continuous training on verification procedures and Federal Student Aid compliance to ensure staff remains informed of regulatory updates and best practices. To further enhance accuracy and accountability, the department will collaborate with the Department of Information Technology (IT) to develop internal error reports that proactively identify discrepancies in student records. An internal checklist will also be implemented to ensure that each student selected for verification by the U.S. Department of Education has submitted all required documentation. This checklist must be reviewed and signed off by the Executive Director of Student Financial Aid Services and Scholarships before final processing. As part of the department’s transition to a more automated verification process, JSU will integrate Campus-Logic, powered by Ellucian, to streamline operations and reduce manual errors. Comprehensive training sessions will be conducted to ensure financial aid staff are proficient in using the platform. Additionally, an internal checklist within Campus-Logic will be established to facilitate structured review and compliance tracking. A final verification review will be conducted by the Executive Director of Student Financial Aid Services and Scholarships to uphold accuracy and federal compliance, ultimately mitigating errors and improving audit outcomes. Estimated Completion Date: December 19, 2025 Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The verification process will ensure all student data is accurate and corrected by staff. Estimated Completion Date: September 30, 2025

View Audit 350191

Finding 539677 (2024-006)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

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

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver ...

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver credit balance to students. The contract with the servicer should have been uploaded to the Dept of Ed database. Since the audit finding, the contract has been uploaded. ASU will upload the contract timely going forward. Estimated Completion Date: Effective Immediately Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (MVSU) Responsible Official: Mrs. Brittney Manuel-Carpenter, Account Receivable Supervisor Corrective Action Planned: MVSU acknowledged the findings of reference 2024-06 SFA-Special Test- Using a Servicer to Deliver Title IV Credit Balances. MVSU acknowledges that the servicer contract is uploaded to the Department of Education database and is available for viewing. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: University will contact the Department of Education Cash Management to correct the URL link. While the link was broken on the Cash Management site it was active on the USM Business Services website: https://www.usm.edu/business-services/refunds.php and is continually maintained on their site. Estimated Completion Date: April 1, 2025

View Audit 350191

Finding 539676 (2024-004)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

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

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that...

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that addresses all 7 required elements of the GLBA regulations: • Review GLBA Requirements: Conduct a thorough review of the Gramm-Leach-Bliley Act (GLBA) regulations to understand the 7 required elements. - Completed • Gap Analysis: A gap analysis has been performed to identify missing elements in the current information security program. - Completed • Program Development: Develop and implement policies and procedures to address the identified gaps. This includes administrative, technical, and physical safeguards. - In Progress • Training: Provide training to staff on the new policies and procedures to ensure compliance and proper implementation. - Planning • vCISO Support: Leverage the expertise of the newly hired virtual Chief Information Security Officer (vCISO) to guide the development and implementation of the information security program. - In Progress 2. Conduct a Comprehensive Risk Assessment to identify and address significant gaps in the risk assessment process: • Risk Assessment Framework: Establish a risk assessment framework that aligns with GLBA requirements. - In Progress • Identify Risks: Identify potential risks to the confidentiality, integrity, and availability of customer information. – In Progress • Evaluate Controls: Assess the effectiveness of existing controls and identify areas for improvement. – In Progress • Mitigation Plan: Develop a risk mitigation plan to address identified vulnerabilities and implement appropriate controls. - Planning • vCISO Support: Utilize the vCISO's expertise to ensure a thorough and effective risk assessment process. – In Progress 3. Monitoring and Continuous Improvement to ensure ongoing compliance and continuous improvement of the information security program: • Regular Audits: Conduct regular audits to ensure compliance with GLBA regulations and the effectiveness of the information security program. – Planning • Feedback Mechanism: Establish a feedback mechanism to gather input from staff and stakeholders on the effectiveness of the program. - Planning • Update Policies: Periodically review and update policies and procedures to address emerging threats and changes in regulations. – In Progress • vCISO Support: Engage the vCISO in monitoring and continuous improvement efforts to maintain high standards of information security. – In Progress 4. Reporting and Accountability to ensure accountability and transparency in the implementation of the corrective action plan: • Assign Responsibility: Assign responsibility for the implementation of the corrective action plan to a dedicated team or individual. - Planning • Progress Reports: Provide regular progress reports to senior management and stakeholders on the implementation of the corrective action plan. - Planning • Documentation: Maintain thorough documentation of all actions taken to address the identified issues. - Planning • vCISO Support: Include the vCISO in reporting and accountability processes to ensure expert oversight and guidance. – In Progress By following this corrective action plan and leveraging the expertise of the vCISO, MVSU can address the deficiencies in its information security program and risk assessment process, ensuring compliance with GLBA regulations and protecting customer information effectively. Estimated Completion Date: November 30, 2025

View Audit 350191

Finding 539670 (2024-010)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Questioned Costs Eligibility Significant Deficiency

Finding Reference: 2024-010 - Eligibility (Board Office) Responsible Official: Dr. Casey Prestwood, Associate Commissioner for Academic and Student Affairs Corrective Action Planned: An evaluation form was developed and implemented to be used with each applicant review as a checklist of requirements...

Finding Reference: 2024-010 - Eligibility (Board Office) Responsible Official: Dr. Casey Prestwood, Associate Commissioner for Academic and Student Affairs Corrective Action Planned: An evaluation form was developed and implemented to be used with each applicant review as a checklist of requirements. In addition, there is a second layer of review of all approved applicants’ eligibility prior to requesting disbursement of funds. An outside CPA firm was contracted in May 2024 to perform the second layer of review of each approved applicant before disbursement, to review all disbursement prior to that date in the current grant cycle, and to provide guidance on internal controls. An additional staff person to assist with grant awarding and programmatic operations was hired in August 2024. Estimated Completion Date: August 2024

View Audit 350191 Questioned Costs: $1

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