Corrective Action Plans

Finding 1180959 (2025-022)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties § 200.303

Corrective action plan: FDCM/OI has developed a comprehensive action plan to modernize and increase our detection of fraud in the child care program. Part of this modernization will include increased and more “real-time” monitoring of Board collection efforts. FDCM/OI is partnering with our Informat...

Corrective action plan: FDCM/OI has developed a comprehensive action plan to modernize and increase our detection of fraud in the child care program. Part of this modernization will include increased and more “real-time” monitoring of Board collection efforts. FDCM/OI is partnering with our Information, Innovation, and Insight Division (I3) to develop new dashboards and reports based upon weekly uploaded PIRTS data. This will allow FDCM/OI to generate weekly reports of Board collection letter non-compliance. If a Board fails to issue collection letters in a timely fashion, FDCM/OI will send a report to the Board Executive Director notifying them of non-compliance. Boards are also now required to have a Fraud Point of Contact (POC) that will be FDCM/OI’s direct liaison with the Board for all fraud matters. Additionally, FDCM/OI is conducting weekly PIRTS trainings throughout February for Boards. Boards have been asked to submit up to 5 fact finders who will be responsible for fraud case entry and management. The Board POC is ultimately responsible for every case. FDCM/OI is also reviewing our collection letters as a part of this process and generating prosecution referrals for cases which meet our criteria. It is our belief this will underscore the seriousness of the collection letters and increase their effectiveness. Finally, FDCM/OI will ensure that all relevant controlling documents, e.g. a new Workforce Development Letter, and all previous guidance is updated with this information. Implementation date: February 27, 2026 Responsible person: Jason Stalinsky, Division Director, Division of Fraud Deterrence and Compliance Monitoring.

View Audit 392506

Finding 1180919 (2025-004)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

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

Corrective action plan: HHSC will run quarterly expenditure reports for this grant to monitor administrative earmarking thresholds. Implementation date: July 31, 2026 Responsible person: Roderick Swan, Associate Commissioner, Behavioral Health Services Operations

View Audit 392506

Finding 1180912 (2025-007)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Reporting Significant Deficiency § 200.303

Corrective action plan: HHSC implemented a final review by all agencies who receive SSBG funding and all HHSC staff. In the future, the federal funds office will coordinate efforts with the Federal Reporting personnel to ensure the amounts noted on the ACF-196 report are consistent with the amount o...

Corrective action plan: HHSC implemented a final review by all agencies who receive SSBG funding and all HHSC staff. In the future, the federal funds office will coordinate efforts with the Federal Reporting personnel to ensure the amounts noted on the ACF-196 report are consistent with the amount on the Post Expenditure Report. Implementation date: March 30, 2026 Responsible person: Racheal Kane, Director, Federal Funds Office

View Audit 392506

Finding 1180910 (2025-001)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

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

Corrective action plan: ITS will: • Work with HR and Security to analyze and validate the size and scope of the late submission of access termination requests for separated employees. Communicate the analysis results and recommendations on or before May 1, 2026. • Work with the Information Security ...

Corrective action plan: ITS will: • Work with HR and Security to analyze and validate the size and scope of the late submission of access termination requests for separated employees. Communicate the analysis results and recommendations on or before May 1, 2026. • Work with the Information Security Office for continuation of periodic reconciliation of HR data and network accounts. Schedule for reconciliation to be established on or before May 1, 2026. • Work with Human Resources to establish a schedule of periodic reconciliation for HR data and case management application accounts. Schedule for reconciliation to be established on or before May 1, 2026. • Review existing business process for offboarding separated employees and provided recommendations to HR for training and communication for staff. Recommendations to be provided by May 1, 2026. • Determine what technology solution may be needed by August 31, 2026, with consideration of effectiveness of mitigation actions, as noted above. Implementation dates: See Corrective action plan Responsible person: Angie Lindemann, Deputy Chief Information Officer

View Audit 392506

Finding 1180909 (2025-018)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Corrective action plan: Program staff will ensure that a formal review by the Team Lead and the Manager of Fiscal and Reporting is completed prior to submission. The Team Lead will initiate the process by obtaining the obligation amount from the LIHEAP Contract Specialist and entering the amount int...

Corrective action plan: Program staff will ensure that a formal review by the Team Lead and the Manager of Fiscal and Reporting is completed prior to submission. The Team Lead will initiate the process by obtaining the obligation amount from the LIHEAP Contract Specialist and entering the amount into the quarterly report. The Manager of Fiscal and Reporting will review and confirm the amount to be submitted. Implementation date: April 30, 2026 Responsible persons: Michael De Young, Director of Community Affairs Cathy Jung, Senior Manager of Finance and Reporting

View Audit 392506

Finding 1180907 (2025-017)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Cash Management Significant Deficiency Internal Control / Segregation of Duties § 200.303

Corrective action plan: The Department will enhance current procedures for the compilation and review of the Period 1 clearance pattern calculation in accordance with the Cash Management Improvement Act (CMIA) and as required in the Texas-State Agreement. The Manager of Accounting will use the State...

Corrective action plan: The Department will enhance current procedures for the compilation and review of the Period 1 clearance pattern calculation in accordance with the Cash Management Improvement Act (CMIA) and as required in the Texas-State Agreement. The Manager of Accounting will use the State Auditor Office’s template spreadsheet provided to agencies to calculate their annual Period 1 calculation and retain the worksheet as supporting documentation. The Director of Financial Administration will review the spreadsheet and calculation prior to CMIA certification. Implementation date: August 2026 Responsible persons: Jose Guevara, Director of Financial Administration Cristina Ortega, Manager of Accounting.

View Audit 392506

Finding 1180905 (2025-021)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Reporting Special Tests & Provisions Significant Deficiency § 200.303

Corrective action plan: Vendor System Safeguards: TWC's I3 (Department of Analytics & Evaluation), IT (Information Technology), and WFA (Workforce Automation) resources will require our WorkInTexas.com vendor, Geographic Solutions Inc (GSI), to implement additional system safeguards to prevent the d...

Corrective action plan: Vendor System Safeguards: TWC's I3 (Department of Analytics & Evaluation), IT (Information Technology), and WFA (Workforce Automation) resources will require our WorkInTexas.com vendor, Geographic Solutions Inc (GSI), to implement additional system safeguards to prevent the duplication of hour entries when extracting data from the WIT system and creating files. TWC resources will maintain oversight of the implementation and ongoing effectiveness of these safeguards. Joint Anomaly Detection: TWC's I3 (Department of Analytics & Evaluation), IT (Information Technology), and WFA (Workforce Automation) resources will require our WorkInTexas.com vendor, Geographic Solutions Inc (GSI), to establish automated validation checks to identify anomalies such as duplicate lines, unexpected variances, and irregular hour totals prior to ingesting vendor files into TWC systems. TWC resources will maintain oversight of the implementation and ongoing effectiveness of these validation checks. TWC IT Data Reconciliation: TWC IT (Information Technology) will enhance supervisory review vendor procedures to reconcile data received from third-party vendors against source records, verifying completeness and accuracy before supplying to I3 (Department of Analytics & Evaluation) for inclusion in federal reporting. Implementation date: December 31, 2026 Responsible persons: Greg Waugh, Director, Workforce Automation (WFA), TWC Richard Yashewski, Director, IT Maintenance & Operations, TWC Geoffrey Miller, Director, Department of Analytics & Evaluation (I3), TWC

View Audit 392506

Finding 1180899 (2025-010)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

Corrective action plan: HHSC will conduct an end-to-end review of the sanctions process to identify and implement any needed changes to the business process, training, or system. Implementation date: May 31, 2026 Responsible person: Carrie Robertson, Manager, Strategy and Innovation–Business Integra...

Corrective action plan: HHSC will conduct an end-to-end review of the sanctions process to identify and implement any needed changes to the business process, training, or system. Implementation date: May 31, 2026 Responsible person: Carrie Robertson, Manager, Strategy and Innovation–Business Integration and Support

View Audit 392506

Finding 1180893 (2025-008)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.329

Corrective action plan: HHSC has taken steps to improve the consistency and reliability of financial reporting related to Maintenance of Effort (MOE) expenditures, specifically, amounts reported on the ACF 204, submitted by HHSC Budget and the ACF 196R, submitted by HHSC Federal Reporting (FR). To a...

Corrective action plan: HHSC has taken steps to improve the consistency and reliability of financial reporting related to Maintenance of Effort (MOE) expenditures, specifically, amounts reported on the ACF 204, submitted by HHSC Budget and the ACF 196R, submitted by HHSC Federal Reporting (FR). To address potential discrepancies and strengthen internal controls, HHSC Federal Reporting has implemented and documented a formal reconciliation process. This process involves the following key components: • Implementation and documentation of a formal reconciliation process that compares all MOE expenditures for HHSC, TEA, and TWC reported on the ACF 204 to those reported on the ACF 196R before report submission. The process outlines specific steps for data cross-referencing and validation to ensure completeness and accuracy. • Research, resolve, and correct any discrepancies identified during the reconciliation process before the reports are finalized and submitted for management review. • Reinforcement of management review and documentation of the reconciliation between the ACF-204 and ACF-196R will be incorporated into the approval process prior to report certification. Implementation date: February 28, 2026 Responsible person: Alan Flynn, Manager, Federal Reporting

View Audit 392506

Finding 1180876 (2025-002)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

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

Corrective action plan: ITS Management will establish a formal, documented user access review program applicable to both privileged and non-privileged network users. Key actions include: 1. Policy Updates: Revise information technology access control policies and procedures to re-quire periodic (at ...

Corrective action plan: ITS Management will establish a formal, documented user access review program applicable to both privileged and non-privileged network users. Key actions include: 1. Policy Updates: Revise information technology access control policies and procedures to re-quire periodic (at least annual) reviews of all network user access. 2. Standardized Process and Documentation: Implement a consistent, documented review process and maintain records in a centralized repository to ensure accountability and auditability. 3. Monitoring and Oversight: Implement oversight procedures to track completion of access re-views and remediation of identified issues, with reporting to IT and information security leadership to support governance. Implementation dates: 1. Policy and procedure updates: Expected completion by April 30, 2026 2. Standardized process and repository implementation: Expected completion by May 31, 2026 3. First completed annual review under the revised process: Expected completion by June 30, 2026 Responsible persons: Tara Mitchell, Director of IT Operations Sean Peterson, Chief Information Officer

View Audit 392506

Finding 1180872 (2025-016)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Corrective action plan: • IT will coordinate with HR on strengthening the separation process, to include HR running separation reports quarterly and sending to IT to cross check. Will perform regular scheduled meetings to discuss the separation process/issues. • IT is testing automatic scripts that ...

Corrective action plan: • IT will coordinate with HR on strengthening the separation process, to include HR running separation reports quarterly and sending to IT to cross check. Will perform regular scheduled meetings to discuss the separation process/issues. • IT is testing automatic scripts that will aid in the process and will be implemented this year. • IT will document quarterly access reviews which are already done. • IT will work on enhancing automation and controls; Will utilize AI to assist. Implementation date: May 2026 Responsible person: Chris Bunton, CIO, Texas Department of Agriculture

View Audit 392506

Finding 1180855 (2025-001)

Material Weakness 2025

Catawba County, North Carolina

NC

Significant Deficiency Internal Control / Segregation of Duties

Finding: 2025-001 Name of Contact Person: Karen Harrington, DSS Director Corrective Action/Management’s Response: Agency agrees with finding. Corrective Action taken/to be taken below: Corrective Action: The Department will strengthen internal controls related to workstation security to prevent unat...

Finding: 2025-001 Name of Contact Person: Karen Harrington, DSS Director Corrective Action/Management’s Response: Agency agrees with finding. Corrective Action taken/to be taken below: Corrective Action: The Department will strengthen internal controls related to workstation security to prevent unattended access to state systems. Effective immediately, all DSS employees with access to state eligibility systems are required to lock their workstation when away from their desk or log out of the system entirely. Implementation Steps: 1. Policy Reinforcement: DSS management will reissue written guidance to all staff reminding them of the requirement to lock or log out of workstations when unattended, consistent with the DSS Fiscal Manual and county IT security standards. 2. Mandatory Staff Acknowledgment: All DSS employees with state system access will complete a brief acknowledgment confirming understanding of workstation security requirements. 3. IT Controls: In coordination with the County IT Department, automatic screen-lock settings will be verified on all DSS workstations accessing state systems. 4. Monitoring and Verification: Supervisors will conduct periodic unannounced walkthroughs to verify compliance with workstation security requirements. Results will be documented and reviewed by DSS management. 5. Corrective Follow-Up: Any noncompliance identified will be addressed promptly through retraining and, if necessary, progressive disciplinary action. Responsible Party: DSS Director, DSS Program Managers, and County DSS Staff Anticipated Completion Date: Immediately upon issuance of this CAP; monitoring will be ongoing. Plan to Prevent Recurrence: Ongoing supervisory monitoring, documented compliance checks, and annual refresher training will be used to ensure continued adherence to workstation security requirements.

View Audit 392499

Finding 1180736 (2025-002)

Material Weakness 2025

Westminster College

MO

Student Financial Aid Reporting Significant Deficiency

Westminster College Corrective Action Plan (CAP) Federal Program: SFA Cluster, Finding 2025-002: Policies and Procedures Related to Withdrawals (significant deficiency) In accordance with 34 CFR 668-22 Treatment of Title IV Funds When a Student Withdrawals, Westminster College has implemented the fo...

Westminster College Corrective Action Plan (CAP) Federal Program: SFA Cluster, Finding 2025-002: Policies and Procedures Related to Withdrawals (significant deficiency) In accordance with 34 CFR 668-22 Treatment of Title IV Funds When a Student Withdrawals, Westminster College has implemented the following Corrective Action Plan: Name of Contact Person: Dr. Annette Roberts, Assistant Dean of Institutional Research and Registrar Specific Corrective Action: Management has developed written policies and procedures to document the steps put in place to ensure that changes in student status are reported in a timely manner. A critical excerpt from that language is included below: After receiving post-notification from EIPC, the Registrar contacts faculty to confirm the student’s last date of attendance. Using this information, the Registrar determines the withdrawal date, exit date, and records these in Jenzabar. The Registrar then notifies Financial Aid, the Business Office, Institutional Research, Residence Life, Advancement, and IT/Help Desk. Institutional Research subsequently pulls the data from Jenzabar and cross references it with the notifications from these offices, once verified. Institutional Research submits the finalized data to the National Student Clearinghouse. Anticipated Completion Date: The Corrective Action Plan

View Audit 392416

Finding 1180710 (2025-002)

Material Weakness 2025

National University of Natural Medicine

OR

Student Financial Aid Subrecipient Monitoring Allowable Costs / Cost Principles § 200.516

Finding 2025-002 Reporting Department’s Response: Management agrees with this finding. Corrective Action: This issue arose during the onboarding of students admitted through a teach-out arrangement with a closing institution. Because these students entered under program structures that differed from...

Finding 2025-002 Reporting Department’s Response: Management agrees with this finding. Corrective Action: This issue arose during the onboarding of students admitted through a teach-out arrangement with a closing institution. Because these students entered under program structures that differed from NUNM’s standard enrollment models, some of the information initially received did not align with NUNM’s financial aid packaging assumptions. In two cases, cost of attendance calculations reflected full-time status when the program design required three-quarter-time treatment. While the situation was limited to a small number of students within a unique population, management recognizes that our internal coordination processes did not sufficiently account for the complexity of the teach-out transition. In particular, clearer confirmation of enrollment status and program structure should have occurred before aid was packaged and originated. Management is strengthening procedures for any future teach-out, transfer, or non-standard admissions cohorts to ensure accurate and compliant packaging from the outset. Going forward, NUNM will implement the following controls: • A standardized handoff process from Admissions to Financial Aid for special populations that documents program structure, term length, and expected enrollment level prior to packaging. • A secondary review requirement for initial aid awards for new program types or cohorts before loans are originated. • Regular cross-functional checkpoints between Admissions and Financial Aid during the setup of non-standard programs. Management views this experience as an opportunity to improve coordination and compliance during periods of institutional transition and is committed to maintaining strong controls over Title IV packaging and cost of attendance calculations. Contact: Jerry Bores Anticipated Completion Date: Immediately

View Audit 392354

Finding 1180655 (2025-003)

Material Weakness 2025

Ascentria Community Services, Inc.

MA

Significant Deficiency Internal Control / Segregation of Duties

U.S. Department of Health and Human Services U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organization review controls in place to ensure payroll expenses are approved and maintain evidence of approval. Explanation of disagreement with au...

U.S. Department of Health and Human Services U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organization review controls in place to ensure payroll expenses are approved and maintain evidence of approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is reviewing standard operating procedures with the program staff. All expenses will be supported with proper approvals. Management will perform periodic reviews to ensure expenses have evidence of approval. Name(s) of the contact person(s) responsible for corrective action: Christopher Paris, Senior Director of Finance Planned completion date for corrective action plan: June 30, 2025 and Ongoing

View Audit 392325

Finding 1180654 (2025-002)

Material Weakness 2025

Ascentria Community Services, Inc.

MA

Period of Performance Significant Deficiency Internal Control / Segregation of Duties

U.S. Department of State U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organization review controls in place to ensure expenses are approved and maintain evidence of approval. Explanation of disagreement with audit finding: There is no dis...

U.S. Department of State U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organization review controls in place to ensure expenses are approved and maintain evidence of approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is reviewing standard operating procedures with the program staff. All expenses will be supported with proper approvals. Management will perform periodic reviews to ensure expenses have evidence of approval. Name(s) of the contact person(s) responsible for corrective action: Christopher Paris, Senior Director of Finance Planned completion date for corrective action plan: June 30, 2025 and Ongoing

View Audit 392325

Finding 1180653 (2025-001)

Material Weakness 2025

Ascentria Community Services, Inc.

MA

Significant Deficiency Internal Control / Segregation of Duties

U.S. Department of Health and Human Services and U.S Department of State Refugee and Entrant Assistance State/Replacement Designee Administered Programs Assistance Listing No. 93.566 U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organizati...

U.S. Department of Health and Human Services and U.S Department of State Refugee and Entrant Assistance State/Replacement Designee Administered Programs Assistance Listing No. 93.566 U.S. Refugee Admissions Program - Assistance Listing No. 19.510 Recommendation: It is recommended that the Organization review controls in place to ensure expenses are approved and maintain evidence of approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is reviewing standard operating procedures with the program staff. All expenses will be supported with proper approvals. Management will perform periodic reviews to ensure expenses have evidence of approval. Name(s) of the contact person(s) responsible for corrective action: Christopher Paris, Senior Director of Finance Planned completion date for corrective action plan: June 30, 2025 and Ongoing

View Audit 392325

Finding 1180592 (2025-024)

Material Weakness 2025

Nevada System of Higher Education

NV

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of the preparer, will review and sign off on each report. This revi...

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 392299

Finding 1180574 (2025-020)

Material Weakness 2025

Nevada System of Higher Education

NV

Allowable Costs / Cost Principles Reporting Significant Deficiency

Activities Allowed or Unallowed and Allowable Costs/Cost Principles Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN’s Office of Grants and Contracts Po...

Activities Allowed or Unallowed and Allowable Costs/Cost Principles Responses CSN – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; CSN’s Office of Grants and Contracts Post-Award Management has advised the grant’s principal investigator (PI) to review expenses and avoid this issue in the future. CSN Office of Grants & Contracts Post-Award Management will continue to advise the departments that expenses associated with canceled events will be removed from the grant, unless the sponsor allows the costs to remain on the grant. ● How compliance and performance will be measured and documented for future audit, management and performance review. CSN Office of Grants and Contracts Post-Award Management will maintain communication with PIs and employees to identify any costs associated with canceled events and ensure only necessary and reasonable costs are charged to the grant. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Office of Grants and Contracts Post-Award manager is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 392299

Finding 1180527 (2025-017)

Material Weakness 2025

Nevada System of Higher Education

NV

Cash Management Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Cash Management Responses WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of du...

Cash Management Responses WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 392299

Finding 1180523 (2025-016)

Material Weakness 2025

Nevada System of Higher Education

NV

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Reporting § 200.303

Allowable Costs/Cost Principles Responses GBC accepts the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o GBC maintains evidence of review and approval of the payroll expenses in questi...

Allowable Costs/Cost Principles Responses GBC accepts the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; o GBC maintains evidence of review and approval of the payroll expenses in question. GBC is very willing to enhance internal controls to provide for documented review and approval for terminated employees charged to the grant program. o GBC has strengthened internal controls over payroll expenditures charged to federal grants to ensure documented review and segregation of duties, particularly for terminated employees. o Documented evidence of review and approval will be retained within the payroll/grants file to ensure a clear audit trail. o Human Resources and Grants Accounting staff have been reminded of federal documentation requirements specific to grant-funded payroll expenditures. ● How compliance and performance will be measured and documented for future audit, management and performance review. o Quarterly internal reviews of payroll expenditures charged to federal grants, with specific review of terminated employees. o Retention of documented approval evidence in electronic grant files. o Review during annual fiscal year-end grant reconciliations. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and Director of Business Operations are responsible for oversight of grant compliance. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 392299

Finding 1180487 (2025-014)

Material Weakness 2025

Nevada System of Higher Education

NV

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management Staff, independent of preparer, will review each subaward report required. The review ...

Reporting Responses UNR – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Management Staff, independent of preparer, will review each subaward report required. The review process will include verifying that all subaward information required by FFATA is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify the information in each report is accurate. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Pre Award Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 392299

Finding 1180483 (2025-011)

Material Weakness 2025

Nevada System of Higher Education

NV

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

Reporting Responses TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Two additional layers of review have been added to ensure that every RFR/Invoice is reviewed. On...

Reporting Responses TMCC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Two additional layers of review have been added to ensure that every RFR/Invoice is reviewed. On 4/14/25 an extra invoice review was added to Workday ensuring that they have to go through a review by someone other than the creator. During this step, the attachments including RFR and the approval email by the controller is also reviewed for accuracy. The Grant Accountant also established a log in August of 2025 that includes the Due Date, Date sent to the Controller for Approval, the Approval date and the submission date. ● How compliance and performance will be measured and documented for future audit, management and performance review. Emails documenting the review of the RFRs are kept as proof of review and saved in our files as well as Workday. The tracking document will also be made available for future review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Grant Accountants will be responsible for ensuring that we are in compliance with the corrective actions UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV OSP does have separation of duties from the originator of the subaward to the review of the subaward agreement in entering all of the data points into Sam.gov for FFATA reporting; however, UNLV OSP will create a process document that explicitly notes this for future documentation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Cross checking of the issued subaward (originator) is reviewed and entered into the federal portal by the submitter. As the federal portal requires one party to enter and submit, OSP management perceives this to be very low risk but will ensure reviews occur. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. WNC – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Western Nevada College implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

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Finding 1180477 (2025-003)

Material Weakness 2025

Nevada System of Higher Education

NV

Cash Management Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

Cash Management Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Controls were implemented beginning on April 14, 2025, to require secondary approvals on al...

Cash Management Responses DRI – Agrees with the finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; Controls were implemented beginning on April 14, 2025, to require secondary approvals on all sponsored invoice transactions. NSHE’s accounting system was reconfigured to require a review step for all invoice business processes. An individual other than the preparer must now review and approve all transactions. ● How compliance and performance will be measured and documented for future audit, management and performance review. Documentation for all sponsor invoice transactions occurs through the business process history in the accounting system. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. UNLV agrees with this finding. ● Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place; UNLV Office of Sponsored Programs (OSP) has an internal control that requires a reconciliation form to be completed with each invoice submission. With any manual control, human error may occur, as in this case; however, the reconciliation form is used every time and is reviewed by the originator and approving authority. ● How compliance and performance will be measured and documented for future audit, management, and performance review. Reinforcement of cross-checking of the reconciliation form is enforced and will be used as documentation for review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

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Finding 1179938 (2025-010)

Material Weakness 2025

Lake Superior State University

MI

Special Tests & Provisions Student Financial Aid Period of Performance

Incorrect Term Dates Used in R2T4 Calculations Auditor Description of Condition and Effect. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the...

Incorrect Term Dates Used in R2T4 Calculations Auditor Description of Condition and Effect. During testing of Return to Title IV ("R2T4") calculations for students who withdrew during the academic year, we noted 1 of 2 student calculations tested had an incorrect term start date when determining the percentage of the payment period completed. We further noted that the University used an incorrect term start date for all R2T4 calculations performed for the Fall 2024 semester. Specifically, the start date used in the calculation did not agree to the official academic calendar approved for the applicable term. As a result of this condition, the University performed R2T4 calculations that included inaccurate percentages of the payment periods completed, which lead to the improper calculation of Title IV funds earned and unearned. Auditor Recommendation. We recommend that the University implement a control requiring reconciliation of term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Additionally, management should review R2T4 calculations completed during the affected period to determine whether recalculations and any necessary adjustments or returns are required. Corrective Action. The University will establish formal procedures to review the term dates used in R2T4 calculations to the officially approved academic calendar prior to processing withdrawals. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026

View Audit 392277

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