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Reference Number: 2025-013 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Public Service Department Department of Libraries Federal Program: COVID-19 – Coronavirus Capital Projects Fund Assistance Listing Number: 21.029 Award Number and Year: CPFFN0202 (2/4/2022...
Reference Number: 2025-013 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Public Service Department Department of Libraries Federal Program: COVID-19 – Coronavirus Capital Projects Fund Assistance Listing Number: 21.029 Award Number and Year: CPFFN0202 (2/4/2022 – 12/31/2026) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Departments’ review their procedures and internal controls to ensure that subawards are reported timely to SAM.gov in accordance with FFATA requirements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The Departments of Public Service and Libraries, reporting obligations for Federal Funding Accountability and Transparency Act Subaward in SAM.gov will occur on a timely basis. Training for these responsibilities is provided for new employees and ad hoc as the system updates and as SAM.gov releases periodic training. A procedural job aid is in place with detailed instructions for staff who are responsible for the inputs. Compliance will be reported regularly to internal leadership. Written procedures for regular reporting to management about FFATA reporting will be established by the grants and contracts staff. A quarterly meeting will be established between the Departments to discuss and ensure that the reporting obligations have been met. Scheduled Completion Date of Correction Action Plan: Quarterly meeting established. March 31, 2026 Procedural job aid created March 31, 2026 Training provided to employees June 30, 2026 Management monitoring process established June 30, 2026 Contacts for Corrective Action Plan: Brittney Wilson, Deputy Commissioner, brittney.wilson@vermont.gov Tracy Collier, Administrative Services Director, tracy.collier@vermont.gov
Reference Number: 2025-008 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Department Name: Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: 23A60UI038010 (1/1/2022 – 9/30/2024) 23A60UR000010 (1/1/2023 – 9/30/2...
Reference Number: 2025-008 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Department Name: Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: 23A60UI038010 (1/1/2022 – 9/30/2024) 23A60UR000010 (1/1/2023 – 9/30/2025) 24A60UR000093 (1/1/2024 – 9/30/2026) Compliance Requirement: Special Tests and Provisions: UI Reemployment Programs: RESEA Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: The Department should update its internal controls to ensure that RESEA procedures are followed, that cases are properly documented and appropriate actions are taken when participants fail to meet program requirements. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: In September of 2025, the RESEA program in Vermont was transitioned from the VDOL Unemployment Insurance division to the VDOL Workforce Development division. This transition included a change of supervision for the RESEA Facilitators from a centralized supervisor to supervision by the VDOL American Job Center Regional Managers. Training was provided to these Regional Job Center Managers to help them to support their new RESEA staff. The RESEA Program Administrator will meet with the specific RESEA Facilitator, and the Regional Manager associated with these cases to provide additional technical assistance. This will include on-site visits and virtual follow-up meetings. Additionally, the RESEA Program Administrator is reviewing the current program monitoring plan and will be making some changes to include a quarterly case monitoring requirement for the regional managers in addition to the current monthly Peer Review monitoring. Scheduled Completion Date of Corrective Action Plan: March 31, 2026 Contacts for Corrective Action Plan: Jay Ramsey, Director, Workforce Development, jay.ramsey@vermont.gov
Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Nu...
Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Award Number and Year: B-20-RH-50-0001 (1/17/2022 - 2/1/2029) B-22-RH-50-0001 (3/27/2023 - 9/1/2029) B-23-RH-50-0001 (7/1/2023 - 9/1/2030) B-22-DC-50-0001 (7/1/2022 - 9/1/2029) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported in accordance with FFATA requirements. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: We have developed specific fields in the online grants management system, GEARS to manage the process of input into SAM.GOV of grant agreements and amendments by the execution date. In addition, the SAM.GOV system clearly identifies the “Subaward Date” stating “enter the date you have signed the subaward.” Staff have been trained appropriately on both GEARS and SAM.GOV to ensure the correct Subaward Date is entered. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Ann Karlene Kroll, DHCD Federal Programs Director, annkarlene.kroll@vermont.gov
Reference Number: 2025-003 Prior Year Finding: 2024-003 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1...
Reference Number: 2025-003 Prior Year Finding: 2024-003 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1015 (9/30/2022 – 9/29/2025), AM21DBIVT1011 (9/30/2022 – 9/29/2026), Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency complete implementation of its corrective action plan from the prior year. It should review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported timely to SAM.gov in accordance with FFATA requirements and that all previously issued subawards are reported. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The business office will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “FFATA reportable” upon grant execution in the Agency’s grants and contracts workbook. The Financial Directors will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the appropriate Federal system by the last business day of each month. Scheduled Completion Date of Corrective Action Plan: 4/30/26 Contacts for Corrective Action Plan: Amy Mercier, Financial Director, amy.mercier@vermont.gov Karen Mae Smith, Financial Director, karenmae.smith@vermont.gov
Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the...
Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the student was enrolled in the summer term and their summer Pell Grant was not processed until October. As a result, the Title IV credit balance was created well after the end of the summer payment period, outside of our typical refund monitoring cycle for that term. In the second instance, the credit balance was identified within the 14-day requirement. However, the student had not enrolled in direct deposit through the eBill system. Lehigh contacted the student to obtain payment instructions. When no banking information was provided to Lehigh, a paper check had to be issued, which extended the disbursement timeline beyond the 14-day period. While these situations were atypical, we recognize the importance of ensuring timely disbursement regardless of individual circumstances. To strengthen controls, we continue to prioritize Title IV credit balance refunds over refunds resulting from institutional aid or other funding sources to ensure compliance with federal timelines. Although we continue our institutional practice of holding refunds until after the 10th day of class to account for schedule adjustments and enrollment changes, we will begin generating and reviewing credit balance reports earlier in the cycle to allow sufficient processing time. We will implement automated reporting to identify credit balances that occur after the end of an academic period. These reports will be sent to a shared bursar office email account rather than an individual staff member. This will ensure visibility and actionability even during staff absences, turnover, or non-workdays. Responsibility for monitoring and processing Title IV credit balances will be formally documented. Multiple staff members will be trained in the procedures to ensure appropriate backup coverage during employee absences, leave, or staffing transitions. Management will periodically review refund timelines to confirm adherence to procedures and verify that credit balances are disbursed within regulatory timeframes. We believe these corrective actions address the audit recommendation and will ensure timely and consistent processing of Title IV credit balance disbursements regardless of staffing availability.Name of contact person: Jennifer Mertz is the Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: All of the control strengthening mechanisms and documentation will be complete by June 30, 2026.
Finding Number: 2025-005 Title: Policies and Procedures Related to Packaging Student Financial Aid To enhance compliance and address these deficiencies, the College will implement a new procedure for documenting and retaining borrower notifications. A timestamped email notification system will be cr...
Finding Number: 2025-005 Title: Policies and Procedures Related to Packaging Student Financial Aid To enhance compliance and address these deficiencies, the College will implement a new procedure for documenting and retaining borrower notifications. A timestamped email notification system will be created to ensure that all required communications to students regarding federal direct loans are not only sent but also retained for auditing purposes. Additionally, a formal review process will be established to verify transfer students' grade levels and academic progressions. This will involve cross-referencing transfer credits and ensuring proper classification of students to prevent future errors. After all transcripts are evaluated, Financial Aid will repackage the aid offer, if required. Regular audits will be introduced to review the documentation of borrower notifications and the packaging process to ensure compliance with federal regulations. Furthermore, training sessions will be conducted for staff involved in the Financial Aid and Registrar Departments to reinforce the importance of accuracy in documenting communications and package decisions. By implementing these corrective actions, the College aims to enhance compliance with federal guidelines and improve the accuracy of Financial Aid packaging for all students. Management is committed to these changes and will ensure the timely execution of this plan. Anticipated Completion Date: March 31, 2026
Finding Number: 2025-004 Associated Criterion: 34 CFR 668.22 - Treatment of Title IV Funds When a Student Withdraws To effectively address the issues related to student withdrawals, a comprehensive action plan will be implemented. First, a thorough review of existing withdrawal policies and procedur...
Finding Number: 2025-004 Associated Criterion: 34 CFR 668.22 - Treatment of Title IV Funds When a Student Withdraws To effectively address the issues related to student withdrawals, a comprehensive action plan will be implemented. First, a thorough review of existing withdrawal policies and procedures will be conducted to identify any gaps in the notification process concerning withdrawn students. Building on this assessment, a timely notification procedure will be developed, which will standardize how all relevant departments, including the Registrar, Financial Aid, and Student Affairs, are notified whenever a student withdraws. This procedure will outline specific timelines and designate responsible parties for alerting each department. To maintain compliance, regular audits of withdrawal cases will be conducted, ensuring adherence to the newly established procedures. Quarterly reviews will also be set up to assess the effectiveness of the notification process. By implementing this Corrective Action Plan, Missouri Valley College aims to improve the timely notification of withdrawn students, ensuring compliance with federal regulations and minimizing the risks associated with late reporting of Title IV funds. Anticipated Completion Date: March 31, 2026
Finding Reference: 2025-004 - SFA - Special Tests - Disbursements to or on Behalf of Students (JSU) Responsible Official: Adrienne Walls, Bursar 601.979.0320 Adrienne.Walls@jsums.edu Corrective Action Planned: Jackson State University will update internal controls to ensure compliance with 34 CFR 66...
Finding Reference: 2025-004 - SFA - Special Tests - Disbursements to or on Behalf of Students (JSU) Responsible Official: Adrienne Walls, Bursar 601.979.0320 Adrienne.Walls@jsums.edu Corrective Action Planned: Jackson State University will update internal controls to ensure compliance with 34 CFR 668.165 related to required notifications for Direct Loan disbursements. The Bursar’s Office will be responsible for issuing required loan disbursement notifications to students and parents. The Bursar’s Office will work in coordination with the University’s Banner consultant to develop and implement an automated process to identify loan disbursements and trigger required notifications. At this time, system-generated notifications are not active. Until automation is implemented, the University will utilize a manual notification process to ensure compliance. Notifications will include (1) the date and amount of the disbursement, (2) the right to cancel all or a portion of the loan, and (3) the process and timeframe to request cancellation. Policies and procedures will be updated to document the notification process. A pre-disbursement control will be implemented prior to each disbursement cycle to verify that the notification process—manual or automated—is in place and functioning as intended. Monitoring procedures will be established to include weekly reviews of disbursement records and notification logs to ensure notifications are issued timely and accurately. Exceptions identified will be resolved promptly. The Assistant Bursar will serve as the control owner responsible for performing and documenting this review. Staff will receive training on regulatory requirements and updated procedures. A standard notification template has been developed and will be used to support the manual process and future automated communications. These actions address the cause of the finding, which resulted from notifications being inadvertently disabled in the financial aid system, and will strengthen controls to prevent recurrence. Estimated Completion Date: April 30, 2026
Finding Reference: 2025-003 - SFA - Special Tests - Using a Servicer to Deliver Title IV Credit Balances (ASU) Responsible Official: Charles Crump, Special Assistant to the VP for Finance (ccrump@alcorn.edu) Corrective Action Planned: The institution will update the E-App to accurately reflect the t...
Finding Reference: 2025-003 - SFA - Special Tests - Using a Servicer to Deliver Title IV Credit Balances (ASU) Responsible Official: Charles Crump, Special Assistant to the VP for Finance (ccrump@alcorn.edu) Corrective Action Planned: The institution will update the E-App to accurately reflect the third-party servicer relationship. Additionally, the institution will implement periodic reviews of all third-party relationships involved in the delivery of Title IV credit balances to ensure they are properly reported on the E-App and remain in compliance. Estimated Completion Date: June 30, 2026
Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (ASU) Responsible Official: Dr. Capetra Polk, Default Management Coordinator capetra@alcorn.edu Corrective Action Planned: Our prior corrective plan was to ensure that any post-withdrawal aid eligible for disbursement would...
Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (ASU) Responsible Official: Dr. Capetra Polk, Default Management Coordinator capetra@alcorn.edu Corrective Action Planned: Our prior corrective plan was to ensure that any post-withdrawal aid eligible for disbursement would be processed in a timely manner. Although corrective actions were implemented in response to the previous finding, the university unfortunately returned funds outside the required timeframe, resulting in the current finding. To address this issue, responsibility for the R2T4 process has been reassigned, and new staff have been trained and will assume these duties to prevent future oversights. Estimated Completion Date: June 30, 2026 Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (DSU) Responsible Official:Megan Smith, Director of Financial Aid (mlsmith@deltastate.edu) and Tammy Prather, Registrar (tprather@deltastate.edu) Corrective Action Planned: Delta State University understands that the spring break start date did not match the days of the break and have resolved the accuracy of those entries to policy. The Registrar and Director of Financial Aid will verify the input of the dates prior to processing withdrawals each year. Delta State University is implementing a weekly process to ensure all R2T4 reviews are conducted and funds returned within the required timeframe. Estimated Completion Date: June 30, 2026 Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (MVSU) Responsible Official: Angela Fant, Director of Financial Aid (Angela.Fant@mvsu.edu) and Jeffery Loggins, University Registrar (JLoggins@mvsu.edu) Corrective Action Planned: As part of ongoing corrective actions, the Office of Financial Aid will continue to verify the accuracy of data provided by the Registrar’s Office prior to processing and awarding aid. In addition, better coordination will be implemented to manage and ensure the submission of accurate data. Estimated Completion Date: June 30, 2026 Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (UMMC) Responsible Official: Davita Weary, Director Financial Aid (FinancialAid@umc.edu) Corrective Action Planned: To ensure accuracy, uniformity, and compliance across all UMMC schools, the following corrective actions will be implemented. All academic calendars must clearly state standardized semester start and end dates using the required language. In addition, standardized break and holiday language must be applied consistently for all holidays, recesses, and institutional closures. Oversight of the academic calendar will be provided by the UMMC Academic Affairs Council, and all academic calendars and associated verbiage must be submitted for review and approval by the Council. The Academic Affairs Council will conduct a full review prior to publication, provide feedback and required revisions during the review period, and return any non‑compliant submissions for correction. In addition to calendar requirements, Financial Aid Advisors will be required to participate in Return to Title IV (R2T4) training offered through the National Association of Student Financial Aid Administrators (NASFAA), and the Financial Aid Director will conduct periodic spot checks of R2T4 submissions throughout the year to ensure continued compliance. Estimated Completion Date: Immediately Finding Reference: 2025-001 - SFA - Special Tests - Return of Title IV Funds (USM) Responsible Official: David Williamson, Director of Financial Aid (david.williamson@usm.edu) Corrective Action Planned: The University of Southern Mississippi (USM) acknowledges the audit finding and agrees that controls surrounding Return of Title IV (R2T4) calculations must be strengthened to ensure full compliance with federal requirements. During the Spring 2025 semester, the institution experienced a two‑day weather‑related delay in the start of classes. As a result, the Registrar updated the academic calendar start date to align with the actual commencement of instruction. No in‑person or online classes were held, and no federal aid disbursements occurred prior to the revised start date. The Spring 2025 semester remained a standard academic term with at least 15 weeks of instructional time. While the institution believed the revised calendar reasonably reflected student attendance and instructional activity, the audit identified that the payment period start date used in Return of Title IV calculations did not align precisely with the approved term structure for purposes of federal aid calculations. This misalignment resulted in incorrect day counts for certain withdrawals. To address this issue and mitigate future risk, the University will implement the following corrective actions: •The Office of Financial Aid will formally coordinate with the Registrar prior to the start of each semester to confirm that academic calendar dates used for Title IV purposes align with approved payment periods and federal regulations. •Any future adjustments to the academic calendar regardless of instructional time impact will be reviewed for Title IV implications, and written guidance will be obtained from the U.S. Department of Education by contacting caseteams@ed.gov as appropriate. •Internal procedures for Return of Title IV calculations will be updated to require verification of calendar day inputs against the institution’s final, approved academic calendar prior to processing. These actions are intended to reinforce internal controls over compliance and ensure consistent application of federal requirements across all withdrawals. Estimated Completion Date: March 18, 2026
Head Start - AL #93.6000 Recommendation: The Organization should ensure all new board members receive training within 180 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will ensure that all new and existi...
Head Start - AL #93.6000 Recommendation: The Organization should ensure all new board members receive training within 180 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will ensure that all new and existing board members receive necessary training within 180 days of being seated and on an annual basis. Name(s) of the contact person(s) responsible for corrective action: Rita Zilka, Fiscal Director Planned completion date for corrective action plan: September 30, 2026
Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with aud...
Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: NEO will perform an internal audit of enrollment reports sent to the National Student Clearinghouse (NSC) monthly to ensure NSC is submitting records on behalf of NEO in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Amy Ishmael Planned completion date for corrective action plan: April 1, 2026 If the U.S. Department of Education has questions regarding this plan, please call Amy Ishmael at 918- 540-6212.
Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the College implement for...
Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed correctly and timely. We also recommend the College implement formal review procedures to document the Return of Title IV calculations are being performed to minimize the likelihood that errors may go undetected and not be corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: NEO will check the scheduled break days before the beginning of each semester to make sure the correct number of days is entered into SOATBRK. Documentation will be retained to confirm that a check was performed. NEO performed the recalculations and is working with FSA to make corrections. Name(s) of the contact person(s) responsible for corrective action: David Fisher and Ashley Mayfield Planned completion date for corrective action plan: March 14, 2026.
SIGNIFICANT DEFICIENCY 2025-001 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreeme...
SIGNIFICANT DEFICIENCY 2025-001 Student Financial Assistance Cluster– Assistance Listing No. 84.063, 84.007, 84.033, 84.268 Recommendation: We recommend the College review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: NEO will develop a separate report in addition to the RRREXIT report to identify students that need to be notified of their responsibility to complete exit counseling. Name(s) of the contact person(s) responsible for corrective action: David Fisher Planned completion date for corrective action plan: March 15, 2026.
Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Business Manager, Food Service Director, and Business Office Staff Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The foll...
Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Business Manager, Food Service Director, and Business Office Staff Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The following corrections will be implemented. 1. Review and update procedures for calculating indirect costs in accordance with USDA Memo SP 60‐2016 and 2 CFR Part 200. 2. Ensure use of the ADE‐approved unrestricted indirect cost rate annually. 3. Implement a standardized calculation worksheet to document allowable indirect cost limits. 4. Require review and approval of indirect cost calculations by the Business Manager prior to posting. 5. Provide training to business office staff on federal cost principles and Child Nutrition requirements. 6. Perform periodic internal reviews to ensure compliance.
Special Education Cluster – Assistance Listing No. 84.027 Recommendation: We recommend the Board revise its procurement policies to fully align with Uniform Guidance requirements and strengthen internal controls to ensure procurement transactions charged to federal awards are reviewed for compliance...
Special Education Cluster – Assistance Listing No. 84.027 Recommendation: We recommend the Board revise its procurement policies to fully align with Uniform Guidance requirements and strengthen internal controls to ensure procurement transactions charged to federal awards are reviewed for compliance prior to payment. This should include updated policy guidance, staff training, and documented supervisory review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Action Plan: CCPS Purchasing Department will make the following changes to our current purchasing policy manual to comply with the Audit recommendation above: Noncompetitive bidding (written justification and purchase desc. Docs require) $ 0 - 5K threshold. Informal bidding (3) price quotes required for $5k - $25,000 purchase threshold with no exceptions for MOI. Formal Bidding required at 25K or greater (ITB, RFP, RFQ’s etc) Require purchase justification for all purchases regardless of dollar threshold Require authorized signature approval based on our current dollar threshold for all purchases Name(s) of the contact person(s) responsible for corrective action: Nelson E. Sample, CPPO, Procurement Manager Planned completion date for corrective action plan: No later than June 30,2026
Finding Number: 2025-001 Considering Subsidized Loans First Planned Corrective Action: The financial aid office concurs with this finding. We have received guidance from our annual audit partners and will install updated processes to ensure that consideration of subsidized loans is prioritized durin...
Finding Number: 2025-001 Considering Subsidized Loans First Planned Corrective Action: The financial aid office concurs with this finding. We have received guidance from our annual audit partners and will install updated processes to ensure that consideration of subsidized loans is prioritized during the awarding process. Person Responsible for Corrective Action Plan: Brice Baumgardner, Vice President of Enrollment Management Anticipated Date of Completion: 4/1/2026
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Findi...
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Ra Chhoth, Finance and Operations Executive Director. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plans to Monitor – The District’s Finance and Operations Executive Director, Ra Chhoth will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.
Recommendation: We recommend the University implement procedures to ensure evidence of the key control review over payments to program participants is documented and retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to...
Recommendation: We recommend the University implement procedures to ensure evidence of the key control review over payments to program participants is documented and retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Eastern Oregon University implemented a standardized internal review and documentation process for new scholarship and other program participant payment requests. The process now requires documentation showing that award criteria were reviewed and met, a secondary review was completed, the payment or disbursement amount was verified for accuracy before release, and post-disbursement reconciliation was performed. To support this process, the University created a form to document each step of the review and retain evidence of completion. The responsible department has also been instructed on the documentation expectations and records retention requirements so that evidence of these control activities is maintained and available for future audit review. This corrective action has been implemented for all new requests going forward. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert, Financial Aid Director Planned completion date for corrective action plan: Completed.
Recommendation: We recommend the University review the GLBA Safeguards Rule and implement appropriate processes and controls to ensure compliance with all applicable provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response ...
Recommendation: We recommend the University review the GLBA Safeguards Rule and implement appropriate processes and controls to ensure compliance with all applicable provisions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The IT Department, in conjunction with Human Resources and individual directors and department heads, will institute an annual system inventory of data classification and owner, ensuring job roles and position descriptions are mapped to access profiles. The CIO will review the current classification process for assigning role-based access and the related IT ticketing process for access to ensure existence of documented approvals for provisioning and role changes through a defined access request and approval workflow. IT will also work with HR to establish onboarding/position change/separation controls and timelines triggered by HR provisioning with same-day termination (within 24-hours) upon termination and role change reviews with transfers. IT will also enforce multi-factor authentication (MFA) administrative access where feasible. The relevant Policy and Procedure Manuals will be updated to define access privileges and approval processes, and staff will be trained annually and with onboarding. Name(s) of the contact person(s) responsible for corrective action: Russ Fagan, Chief Information Officer Planned completion date for corrective action plan: March 31, 2026
Recommendation: We recommend the University enhance its procedures for reviewing professional judgement decisions to ensure that evidence of review is documented and retained Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to ...
Recommendation: We recommend the University enhance its procedures for reviewing professional judgement decisions to ensure that evidence of review is documented and retained Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will review its procedures and document retention practices to ensure that key controls related to professional judgment determinations are documented and evidenced for audit purposes. The University will evaluate existing processes and supporting records and will implement any needed improvements to strengthen documentation and audit support. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert, Director of Financial Aid Planned completion date for corrective action plan: Completed
Recommendation: We recommend the University retain evidence that key controls over COD reporting were performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office completes COD reporting on a...
Recommendation: We recommend the University retain evidence that key controls over COD reporting were performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office completes COD reporting on a weekly basis and will maintain a documentation set for each reporting cycle in a central location using consistent naming conventions. The documentation set will include COD submission batch acceptance files and receipt acknowledgements, edit and error reports with resolution notes and dates, internal system disbursement rosters showing dates and amounts, and adjustment logs. These records will be used to support monthly federal aid reconciliations with the Business Affairs Office. Designated staff responsible for COD submission tracking will also maintain the related reconciliation support documentation. The Financial Aid Policy and Procedure Manual will be updated accordingly, and staff will be trained annually and during onboarding. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert, Director of Financial Aid Planned completion date for corrective action plan: March 31, 2026
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status, and effective dates within NSLDS match the records of the institution and a...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status, and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University reports enrollment more frequently than the required 60 days to capture status changes in a timely manner. Reporting occurs each term at the end of the second week, the Tuesday after Census, Monday of week 7, and the end of the term. The Registrar and Financial Aid Office created a process to communicate accurate last dates of academic engagement (LDAs) for unofficial withdrawals so that withdrawal dates match LDAs used in Return of Title IV (R2T4) calculations and unofficial withdrawals are reported to NSLDS through the regular NSC process. The Offices have also instituted a shared tracking and review process to regularly spot-check enrollment reports to ensure that data reported in Banner matches NSC reports and is correctly uploaded to NSLDS. Documentation of unofficial withdrawals, LDAs, error reports, and tracking of sampling outcomes with any needed corrections are maintained in the school’s files and shared between offices. The Registrar’s Office will review Banner and NSC submissions to ensure accurate and matching LDAs and status dates; the Financial Aid Office is responsible for confirming NSC submittals have successfully uploaded to NSLDS and reflect correct data that matches R2T4 and unofficial withdrawal info. Manual reporting to NSLDS will only be used for emergency updates to meet timeliness requirements, with multiple follow-up verification for NSC or roster file overwrites. Policy and Procedures Manuals will be updated accordingly, and staff in both offices will be trained annually and with onboarding. Name(s) of the contact person(s) responsible for corrective action: Emily Sharratt, Registrar; Jason Hibbert, Director of Financial Aid Planned completion date for corrective action plan: March 31, 2026
The District will work to establish and review policies and procedures to ensure adequate funding is reserved for debt service during the year and at fiscal year end.
The District will work to establish and review policies and procedures to ensure adequate funding is reserved for debt service during the year and at fiscal year end.
Budget Based Rent increase has been submitted to HUD and is in queue for approval. The request includes funding for the reimbursement of the Replacement Reserve. We anticipate that this will be approved.
Budget Based Rent increase has been submitted to HUD and is in queue for approval. The request includes funding for the reimbursement of the Replacement Reserve. We anticipate that this will be approved.
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