Corrective Action Plans

Finding 1175092 (2025-001)

Material Weakness 2025

Loras College

IA

Student Financial Aid Eligibility Significant Deficiency

Loras College Corrective Action Plan For the year ended June 30, 2025 February 19, 2026 Finding 2025-001: Significant Deficiency – Incentive Compensation Assistance Listing Number: Various Federal Agency: U.S. Department of Education Condition: One out of five employees selected for testing had a pr...

Loras College Corrective Action Plan For the year ended June 30, 2025 February 19, 2026 Finding 2025-001: Significant Deficiency – Incentive Compensation Assistance Listing Number: Various Federal Agency: U.S. Department of Education Condition: One out of five employees selected for testing had a promotion letter that included a salary increase if performance metrics for enrollments were met, with goal numbers for yearover- year increases in applications, admissions, new transfer enrollment and graduate enrollment. This is not in compliance with applicable requirements regarding incentive compensation. Recommendation: The College should establish a policy where employee contracts and compensation are reviewed and approved to ensure compliance with applicable requirements regarding incentive compensation per the regulations at 34 CFR 668.14(b)(22). Corrective Action: Management has reviewed internal processes and procedures and a process has been established whereby all employee contracts and compensation are first reviewed by the Associate VP for Finance/Treasurer and President before they are sent to Human Resources for processing. The Associate VP for Finance/Treasurer has a CPA background. In addition, the President and the HR Director are now well versed in applicable requirements regarding employee compensation. Management believes this process will eliminate a reoccurrence. Renate A. Root Treasurer 1450 Alta Vista St. Dubuque, IA 52001 563-588-7775

View Audit 388712

Finding 1175074 (2025-001)

Material Weakness 2025

Burke County

NC

Eligibility Internal Control / Segregation of Duties Material Weakness

None reported Finding 2025-001 Name of contact person: Corrective Action: Proposed Completion Date: Corrective Actions for Findings 2025-001 also apply to State requirements and State Awards. Margaret Pierce - Burke County Finance Director, Korey Fisher-Wellman - Department of Social Services Direct...

None reported Finding 2025-001 Name of contact person: Corrective Action: Proposed Completion Date: Corrective Actions for Findings 2025-001 also apply to State requirements and State Awards. Margaret Pierce - Burke County Finance Director, Korey Fisher-Wellman - Department of Social Services Director, Amanda Grady - Assistant Department of Social Services Director, and Tammy Wright - Medicaid Program Manager For all findings identified, Medicaid staff are required to attend training sessions to address the issues, and sign-in sheets will be required. During training, appropriate policies will be reviewed. The root causes of the errors were determined to be staff oversight and procedural lapses, compounded by policy changes, staff turnover, and the inexperience of some workers. Medicaid Supervisors will continue conducting 2nd Party Reviews. As cases are reviewed, supervisors will provide additional training as needed, either individually or in group settings. Training materials will be kept current and shared with the lead worker to ensure proper delivery. Workers will be required to complete refresher training when errors are found and collaborate with lead workers or supervisors for more detailed instruction or training. Group training will be scheduled if multiple workers demonstrate similar issues based on 2nd Party Review results. Supervisors conducting 2nd Party Reviews will examine two random cases per worker each month for timeliness and accuracy. In addition, two extra cases per worker will be spot-checked monthly to verify accurate resource entry. The Program Manager and Supervisors will monitor reports to ensure timeliness and require staff to document any cases that have gone overdue. These processes will help determine whether improvements have been made in resource accuracy. New employees will have notices and other correspondence reviewed before they are sent out to ensure accuracy. All new employees will continue to have 100% of their cases reviewed until supervisors determine they can process cases independently and correctly. Results from 2nd Party Reviews will be shared with the Program Manager, Assistant Director, and DSS Director. Corrections have been made to cases in error, and supporting documentation has been updated in NCFAST. Section IV - State Award Findings and Question Costs Supervisors will conduct training in response to the identified errors, with completion targeted by the end of January. Success will be measured through the results of ongoing 2nd Party Reviews. The agency will continue to monitor outcomes, provide group or individual training as needed, and address persistent issues through the disciplinary process when necessary. Additional training requirements and expanded, targeted spot-checks of cases will be implemented on an ongoing basis, based on continued findings, to further strengthen accuracy and compliance. Burke County, North Carolina Section III - Federal Award Findings and Question Costs Corrective Action Plan For the Year Ended June 30, 2025 Section II - Financial Statement Findings 139

View Audit 388700

Finding 1175073 (2025-002)

Material Weakness 2025

Independent School District No. 16

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Significant Deficiency § 200.318

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2025-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding ...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2025-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires Independent School District No. 16, (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 special education cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its special education 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 – The District’s Executive Director of Business Services, Amy Schultz Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Business Services, Amy Schultz will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

View Audit 388697

Finding 1175026 (2025-002)

Material Weakness 2025

Lifelong Medical Care

CA

Allowable Costs / Cost Principles Significant Deficiency § 200.430

2025-002 Inadequate Documentation of Timesheet Approval for Payroll Costs Charged to the Grant - Significant deficiency in Internal Control over Compliance Name of Contact Person: Daphne Chan, Interim Head of Finance Corrective Action: Lifelong Medical Care will: - Continue to update configuration o...

2025-002 Inadequate Documentation of Timesheet Approval for Payroll Costs Charged to the Grant - Significant deficiency in Internal Control over Compliance Name of Contact Person: Daphne Chan, Interim Head of Finance Corrective Action: Lifelong Medical Care will: - Continue to update configuration of the newly implemented payroll system to adequately support processes - Revise the payroll and timekeeping policy to clearly require electronic or manual supervisory approval for all hourly timesheets before payroll processing. - Provide refresher training to supervisors on federal grant requirements related to allowable payroll costs and the necessity of timely timesheet approval. - Implement a periodic monitoring process to review samples of timesheets each pay period to confirm that approvals are documented and retained. - Maintain approved timesheets in accordance with the Lifelong's document retention policy and federal grant requirements. Estimated Completion Date: June 30, 2026 Signed by Daphne Chan Interim Head of Finance

View Audit 388651

Finding 1175015 (2025-001)

Material Weakness 2025

Lifelong Medical Care

CA

Internal Control / Segregation of Duties Special Tests & Provisions Eligibility

2025-001 Special Tests and Provisions - Significant deficiency in Internal Control over Compliance Name of Contact Person: Daphne Chan, Interim Head of Finance Corrective Action: Management implemented staff training and periodic internal reviews in response to the prior year finding related to the ...

2025-001 Special Tests and Provisions - Significant deficiency in Internal Control over Compliance Name of Contact Person: Daphne Chan, Interim Head of Finance Corrective Action: Management implemented staff training and periodic internal reviews in response to the prior year finding related to the Sliding Fee Discount Program. While these actions improved awareness of requirements, management identified the need for additional controls to ensure consistent application and documentation going forward. To address the remaining gaps, management will implement the following actions: - Strengthen intake and documentation controls by reinforcing procedures to ensure proof of income documentation is obtained and retained. - Train site staff to ensure consistency in applying sliding fee discount. - Routine spot checks with timely escalation to Site Directors and Operations leadership when issues or variances are identified. - Refine internal monitoring activities to focus on higher risk transactions, such as new patient registrations, income re-certifications, etc. for final eligibility determination. Management will continue to monitor the effectiveness of these controls and make adjustments as needed to ensure ongoing compliance with Health Center Program requirements. Estimated Completion Date: June 30, 2026 Signed by Daphne Chan Interim Head of Finance

View Audit 388651

Finding 1174997 (2025-002)

Material Weakness 2025

Stanfield Elementary School District No. 24

AZ

Internal Control / Segregation of Duties Cash Management Reporting

2025-002 Reporting Federal Assistance Listing Number: 10.553, 10.555 Program Title: Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture Passthrough Entity: Arizona Department of Education Passthrough Number: ADE ED09-0001 Compliance Requirement: L. Reporting Award Period: July 1, ...

2025-002 Reporting Federal Assistance Listing Number: 10.553, 10.555 Program Title: Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture Passthrough Entity: Arizona Department of Education Passthrough Number: ADE ED09-0001 Compliance Requirement: L. Reporting Award Period: July 1, 2024 – June 30, 2025 Finding Type: Noncompliance, Significant Deficiency in Internal Control Questioned Costs: N/A Repeat Finding: No. Condition/Context: During our review of meals claims submitted for reimbursement, we noted variances between the District’s meal counts and what was submitted to the Arizona Department of Education. For four months tested, meals claims were under-reported by 20 lunch meals, which calculated to $90.80. Criteria: Child Nutrition Cluster claim forms should be supported by documentation showing the number of meals for which reimbursement was requested. This documentation should be maintained to support what was requested for reimbursement by ADE. Effect: Without proper controls over applications and the filing of claims, the District could over or under claim their reimbursements from the Child Nutrition Program without detecting the error. Corrective Action Plan: Management will ensure meals claims are reviewed, approved, and tie to supporting meals served before claims are submitted. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Elizabeth Ibarra, Business Manager

View Audit 388634

Finding 1174991 (2025-001)

Material Weakness 2025

County of Mendocino

CA

Eligibility Subrecipient Monitoring Significant Deficiency

Condition: During review of 40 eligibility determinations and redeterminations, we identified two exceptions: one case lacked documentation of IEVS reports required to verify income and eligibility information, and another case had a redetermination completed more than 12 months prior to the active ...

Condition: During review of 40 eligibility determinations and redeterminations, we identified two exceptions: one case lacked documentation of IEVS reports required to verify income and eligibility information, and another case had a redetermination completed more than 12 months prior to the active eligibility date, which does not comply with the annual redetermination requirement under 42 CFR 435.916. Recommendation: CLA recommends that the County strengthen monitoring procedures to ensure that Income and Eligibility Verification System (IEVS) reports are obtained and retained for all eligibility determinations, implement controls to verify that redeterminations are completed within the required 12-month timeframe prior to the active eligibility date, and provide staff training on compliance requirements and proper documentation standards to reinforce adherence to established policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: All eligibility units will review the updated CP 25- 01 “EFAS IEVS Process” by 2/27/26 and annually thereafter. Supervisors will monitor CalSAWS reports/tasks for assigned staff to ensure compliance with processing standards. Supervisors will also monitor CalSAWS Monthly Productivity reports for their units to ensure that Redeterminations are completed timely and include Medi-Cal redeterminations in the case review process for new and journey-level staff. Eligibility Specialists will review the memo MC 25-016 “Updated Medi-Cal Annual and Change in Circumstance RE Guidance” by 2/27/2026. To avoid late redeterminations, staff will be offered overtime opportunities to ensure compliance until such time as the units have enough staff to meet the workload. The Department will complete minimally two eligibility induction training classes and two journey level refresher trainings per year. Name(s) of the contact person(s) responsible for corrective action: Rachel Ebel-Elliott, Social Services Deputy Director Planned completion date for corrective action plan: 6/30/2026

View Audit 388600

Finding 1174986 (2025-002)

Material Weakness 2025

County of Mendocino

CA

Subrecipient Monitoring Reporting Significant Deficiency

Condition: During testing of 40 sampled cases, 1 case was identified where aid code 30 was charged after the 60-month lifetime limit. The noncompliant payments occurred in December 2024, January 2025, and February 2025, totaling $2,652. Recommendation: CLA recommends the County strengthen monitoring...

Condition: During testing of 40 sampled cases, 1 case was identified where aid code 30 was charged after the 60-month lifetime limit. The noncompliant payments occurred in December 2024, January 2025, and February 2025, totaling $2,652. Recommendation: CLA recommends the County strengthen monitoring controls to ensure benefits are terminated promptly upon reaching the 60-month limit unless valid exemptions are documented, implement periodic system audits to detect and prevent similar errors, provide staff training on proper coding and documentation for exemptions such as aid code 33 for hardship or extreme cruelty, and recover improper payments where feasible while reporting corrective actions to the State Department of Social Services. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective action plan: Implement Standardized Controls to ensure time limit review and transition at 60 months. Department will operationalize the use of monthly ad-hoc reporting within CalSAWS to identify individuals approaching 60 months and confirm tasks set for follow-up: Name(s) of the contact person(s) responsible for corrective action: Rachel Ebel-Elliott, Social Services Deputy Director Planned completion date for corrective action plan: 6/30/2026

View Audit 388600

Finding 1174984 (2025-002)

Material Weakness 2025

Central Michigan University

MI

Special Tests & Provisions Significant Deficiency Equipment & Real Property Management

Finding Number: 2025-002 – Special Tests and Provisions – Gramm Leach Bliley Act Missing Compliance Requirements Auditor Description of Condition and Effect: The Gramm Leach Bliley Policy, in effect at time of audit, failed to explicitly state how the university addressed the implementation of multi...

Finding Number: 2025-002 – Special Tests and Provisions – Gramm Leach Bliley Act Missing Compliance Requirements Auditor Description of Condition and Effect: The Gramm Leach Bliley Policy, in effect at time of audit, failed to explicitly state how the university addressed the implementation of multi-factor authentication for anyone accessing customer information on the institution's system, conducting a periodic inventory of data that notes where it is collected, stored, or transmitted, encrypting customer information on the institution's system and when it's in transit, and anticipating and evaluating changes to the information system or network. The University did not have a review process in place for ensuring all required safeguard were written in the information security program in accordance with the Gramm Leach Bliley Act. Auditor Recommendation: We recommend that the University implement procedures to ensure that all Gramm Leach Bliley policies are met and verified by a second individual. Views of Responsible Officials and Planned Corrective Action: Beginning in fiscal year 2026, Office of Information Technology (OIT) implemented an updated policy/procedure aligned with the Gramm Leach Bliley Act (GLBA) Information Security Program requirements. The updates include: implementation of multi-factor authentication (MFA) for anyone accessing customer information on the institution's system; conducting a periodic inventory to identify where customer information is collected, stored, or transmitted; encryption of customer information both on institutional systems and during transmission; procedures to anticipate and evaluate changes to the information system or network that may impact data security. Although not fully documented, the following measures were already implemented and operational at the time of audit: Multi-Factor Authentication (MFA): MFA has been in place for all systems that access customer financial information, in accordance with FTC Safeguards Rule updates effective June 2023; Encryption: Both data at rest and in transit have been encrypted using industry-standard protocols, consistent with GLBA requirements; and Data Inventory: A periodic inventory of systems and data flows has been conducted, identifying where customer information is collected, stored, and transmitted. This is part of our broader risk assessment and information security program. Internal Audit reviewed the policy and associated processes against the applicable regulation (16 CFR 314) and concluded that we were in compliance based on the regulatory guidance available. It was not until the release of the final 2025 Compliance Supplement in late November 2025 that clarification was provided indication that all eight minimum safeguards must be explicitly documented within the written information security program. Additionally, the University has established a formal review process to ensure all GLBA safeguard policies are met. Key personnel and leadership within OIT will conduct regular compliance reviews to verify adherence and promote operational efficiency. Contact person responsible for corrective action: Jerry Todd, Chief Information Security Officer, Office of Information Technology Information Security Anticipated Completion Date: 12/1/2025

View Audit 388595

Finding 1174972 (2025-001)

Material Weakness 2025

Central Michigan University

MI

Student Financial Aid Special Tests & Provisions Reporting

Finding Number: 2025-001 – Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect: In our testing of eighteen students, we noted two students who were reported with inaccurate effective dates. The University's reporting process relies on SAP system data for N...

Finding Number: 2025-001 – Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect: In our testing of eighteen students, we noted two students who were reported with inaccurate effective dates. The University's reporting process relies on SAP system data for NSLDS reporting, which did not accurately reflect the student’s actual last date of attendance. Auditor Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting to ensure that reporting is completed accurately. Views of Responsible Officials and Planned Corrective Action: Effective immediately following the Office of Technology system updates, the Registrar’s Office and Student Account Services and University Billing (SASUB) will begin utilizing SAP to store R2T4 dates. These dates will automatically populate the monthly National Student Clearinghouse (NSC) enrollment files, improve reporting accuracy, compliance, and the management of withdrawn students. This centralized platform provides authorized users with streamlined access to view pending returns, associated deadlines, and completion dates for each case. The system enhances tracking accuracy, strengthens accountability, and promotes transparency and communication among university stakeholders. Key personnel and leadership from the Registrar’s Office and SASUB will conduct regular reviews to ensure compliance and operational efficiency. Contact person responsible for corrective action: Keith J. Malkowski, Registrar of Registrar’s Office & Brian C. Bell, Director of Student Account Services and University Billing Anticipated Completion Date: 2/28/2026

View Audit 388595

Finding 1174952 (2025-001)

Material Weakness 2025

Santa Monica Community College District

CA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Views of Responsible Officials and Corrective Action Plan Responsible Officials: Associate Dean, Financial Aid & Scholarships, Director of Financial Aid & Scholarships Enhanced data on source reports The Associate Dean of Financial Aid & Scholarships, Director of Financial Aid & Scholarships, and Sy...

Views of Responsible Officials and Corrective Action Plan Responsible Officials: Associate Dean, Financial Aid & Scholarships, Director of Financial Aid & Scholarships Enhanced data on source reports The Associate Dean of Financial Aid & Scholarships, Director of Financial Aid & Scholarships, and System Specialist worked with the MIS (IT) Department to enhance information provided on the reports used by Financial Aid staff to facilitate identifying student withdrawals and initiating the calculation process. Enhanced report will cut down on the need to manually check student information as the Specialist is processing students. New data elements on the report include course and class section information, start and end week, number of units by course, drop date field and the instructor e-mail. Increase frequency of generating the student withdrawal report. The System Specialist has scheduled on their calendar to run the student withdrawal report every week to ensure that the withdrawals are identified in a timely manner and the calculations and returns are completed within the 45-day window. Redistributed department workload; Specialist focused on withdrawal determination/calculation. The Associate Dean has tasked additional office support to assist the System Specialist in the communication follow up with the impacted students, freeing up the System Specialist’s workload to concentrate fully on the withdrawal determination and calculation completion. Monthly review by Associate Dean to confirm adjustments completed for student withdrawals. The Associate Dean will request a monthly report to review and ensure that the calculations and aid adjustments are completed for each student who has withdrawn. This process update will put in place internal checks and balances over the review of the calculations to ensure financial aid funding is returned in a timely manner. The Associate Dean, or their designee, will sign-off that they have reviewed the report each month and file a copy.

View Audit 388546

Finding 1174918 (2025-001)

Material Weakness 2025

Ser-Jobs for Progress of the Texas Gulf Coast, Inc. and Subsidiary

TX

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Corrective Action: An unnecessary step in the process was removed . Previously, program staff waited for funder confirmation approving the billing report before attaching a screenshot and submitting the executive summary. The process has been updated, so screenshots are submitted without waiting for...

Corrective Action: An unnecessary step in the process was removed . Previously, program staff waited for funder confirmation approving the billing report before attaching a screenshot and submitting the executive summary. The process has been updated, so screenshots are submitted without waiting for funder approval. In addition, the accounting department will shift its closing date 1 day prior to the funder's executive summary reporting deadline. Responsible Parties: Chief Program Officer & Chief Financial Officer Date to be Corrected: 03/31/2026 If the U.S. Department of Labor has any questions regarding this plan, please contact Liliana Rambo, CEO, 713.773.6000 x 117.

View Audit 388511

Finding 1174915 (2025-001)

Material Weakness 2025

Northwestern Health Sciences University

MN

Student Financial Aid Reporting Significant Deficiency

National Student Loan Data System (NSLDS) Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for the "Campus Level" as well as making sure records are being timely reported. Explanation of disagreement with a...

National Student Loan Data System (NSLDS) Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for the "Campus Level" as well as making sure records are being timely reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although the Colleague data is correct, the logic in Colleague used to send the files to the NSC is excluding records when the student is not registered for classes in the month an action such as graduation or withdrawal occurs. In that situation the NSC is inserting default dates onto the record based on the last date of their classes in the prior term. We will continue to manually review and correct issues when needed. Name of the contact person responsible for corrective action: Sean Murphy, Registrar Planned completion date for corrective action plan: Already in place.

View Audit 388485

Finding 1174842 (2025-001)

Material Weakness 2025

San Diego Community College District

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Views of Responsible Officials and Corrective Action Plan We concur. Management has revised its procedures for R2T4, as well as added additional monthly review to ensure compliance.

View Audit 388422

Finding 1174798 (2025-001)

Material Weakness 2025

Lutheran Social Service of Minnesota and Affiliates

MN

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Americorps Seniors Senior Companion Program – Assistance Listing No. 94.016 Recommendation: We recommend that additional review procedures are put in place to ensure the volunteer type is accurate based on their income review. Explanation of disagreement with audit finding: There is no disagreement ...

Americorps Seniors Senior Companion Program – Assistance Listing No. 94.016 Recommendation: We recommend that additional review procedures are put in place to ensure the volunteer type is accurate based on their income review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Program leadership will review and update existing policies and procedure manuals to ensure provide clear and accurate steps to adhere to funding guidance. The supporting technology will be updated in a manner that will require program coordinators/managers to actively complete a required field to verify current income eligibility. In addition, the program will develop and implement an active review process to monitor and support compliance and accurate record keeping. Name(s) of the contact person(s) responsible for corrective action: Drew Erickson Planned completion date for corrective action plan: 02/28/2026

View Audit 388351

Finding 1174791 (2025-008)

Material Weakness 2025

Clarkson College

NE

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

2025-008 Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College provide all necessary employees with training, support, and sufficient time to follow College policies and federal requirements related to monthly reconciliations. Explanation of disagreem...

2025-008 Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College provide all necessary employees with training, support, and sufficient time to follow College policies and federal requirements related to monthly reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College utilizes a third party service provider to service both the Nurse Student and Nurse Faculty Loan programs. Due to staff turnover and the student information system implementation of Anthology, there was inconcistency in what was has been provided for both loan programs. As of FY 2025 year-end and looking forward, the College finance team has taken the additional steps to review and reconcile the balances. In the review, it was noted that there was an issue with the uploading of date to the third party provider and the College has added additional controls in a review of data that is received by the provider as well as regular communication between the College Finance department and Financial Aid departments on any discrepencies. Name(s) of the contact person(s) responsible for corrective action: Nathan Wiegand, VP of College Finance/CFO Planned completion date for corrective action plan: Implemented in FY 2026.

View Audit 388309

Finding 1174783 (2025-007)

Material Weakness 2025

Clarkson College

NE

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College review and strengthen its policies and procedures to ensure that all student credit balances resulting from federal funds are refunded within the required 14-day period. Explanation of disagreement...

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College review and strengthen its policies and procedures to ensure that all student credit balances resulting from federal funds are refunded within the required 14-day period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This finding was from Fall of 2024. During the Fall semester of FY 25, Clarkson College experienced turnover with its financial aid department staff. From Spring 2025 on, the financial aid department now processes financial aid weekly on Monday through Wednesday each week. The student accounts team in turn runs a report for any credit balances on Thursday morning each week. Upon running the report, the student accounts team will then process and issue either a check or ACH payment refund that same day so that at most, there is a eight-day period. In addition, the College enhanced the check payment process so that the checks can be generated, printed, and mailed same-day. Name(s) of the contact person(s) responsible for corrective action: Nathan Wiegand, VP of College Finance/CFO Planned completion date for corrective action plan: Implemented in January, 2025.

View Audit 388309

Finding 1174775 (2025-006)

Material Weakness 2025

Clarkson College

NE

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College establish a process to ensure that all disbursement information is accurately reported to the COD system. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College establish a process to ensure that all disbursement information is accurately reported to the COD system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: It was noted in COD that a disbursement date did not match the date recorded in our Anthology system; the discrepancy was by one day. Once identified, the Financial Aid team corrected the error. Unfortunately, the correction was made outside the required 15-day window. All disbursement dates have now been updated, and we have implemented a new process to ensure that all dates in Anthology and COD align. The Financial Aid team is actively monitoring this to ensure that current and future disbursement dates consistently match providing an additional reconciliation of dates. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Implemented

View Audit 388309

Finding 1174767 (2025-005)

Material Weakness 2025

Clarkson College

NE

Student Financial Aid Eligibility Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no d...

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: There was one student in Fall 2024 who was under-awarded Pell Grant funds due to an error related to the student’s withdrawal status and the number of credits attempted. The Pell award was manually processed incorrectly based on this enrollment change. Beginning in Spring 2025, the Financial Aid team implemented a new process requiring a formal review of enrollment intensity for all students prior to determining and disbursing Pell Grant funds. This ensures that Pell awards are calculated and adjusted accurately. Additionally, the team now utilizes enrollment and Pell related reports to help identify potential changes in student enrollment and support timely, accurate award reviews. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented January, 2025.

View Audit 388309

Finding 1174759 (2025-004)

Material Weakness 2025

Clarkson College

NE

Student Financial Aid Eligibility Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure that calculations use the correct number of break days and are completed accurately and within the required timeframes. Explanation ...

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend the College review the R2T4 requirements and implement procedures to ensure that calculations use the correct number of break days and are completed accurately and within the required timeframes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the review period, two students did not receive their Return to Title IV (R2T4) calculations within the required 45-day timeframe. The delay occurred because the Financial Aid Office did not receive the corresponding change of registration forms from the Registrar’s Office, which is necessary to initiate the R2T4 process. To prevent recurrence, the Financial Aid Office has implemented the following corrective actions: 1. Monitoring Reports: The team now runs a student status change report to independently identify potential R2T4 cases, even if documentation has not yet been forwarded. 2. Improved Communication Workflow: Financial Aid has been added to the Registrar’s change of registration email distribution list to ensure timely notification of withdrawals, drops, and status changes. These measures strengthen internal controls, improve cross departmental communication, and ensure that all future R2T4 calculations are completed within federal timelines. Name(s) of the contact person(s) responsible for corrective action: Dr. Carla Dirkshneider, VP of Enrollment and Retention Planned completion date for corrective action plan: Corrective action was implemented in June 2025.

View Audit 388309

Finding 1174706 (2025-003)

Material Weakness 2025

Lutheran Child and Family Services of Illinois

IL

Significant Deficiency Internal Control / Segregation of Duties

Recommendation: CLA recommends the Agency follow its prescribed policy of supervisors performing and documenting their approval of the documentation of employees' time and effort. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to ...

Recommendation: CLA recommends the Agency follow its prescribed policy of supervisors performing and documenting their approval of the documentation of employees' time and effort. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: We have revised our policy and procedures to make sure that all employees and supervisors are required to approve their timesheet and a follow-up from our HR department will ensure that we have established compliance with this finding. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Immediately

View Audit 388267

Finding 1174705 (2025-002)

Material Weakness 2025

Lutheran Child and Family Services of Illinois

IL

Procurement, Suspension & Debarment Significant Deficiency § 200.212 § 200.318

Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Explanation of disagreement with audit finding: There is no disagreement wi...

Recommendation: CLA recommends the Agency update its procurement policy to include procedures that a vendor be verified as not being debarred, suspended, or excluded and documentation maintained to support the determination. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Agency is committed to following the procurement process and requirements outlined within the policies and procedures. The Agency plans to revise current procurement policy to have a process for debarred, suspended, or excluded and documentation maintained to support the determination. All procurement will be monitored through the Sage Intacct and Ramp system, which has already been implemented. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Immediately

View Audit 388267

Finding 1174704 (2025-001)

Material Weakness 2025

Lutheran Child and Family Services of Illinois

IL

Procurement, Suspension & Debarment Significant Deficiency

Recommendation: CLA recommends the Agency maintain an audit trail for all procurements. This can be done electronically for efficiency. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Agency is committed to followin...

Recommendation: CLA recommends the Agency maintain an audit trail for all procurements. This can be done electronically for efficiency. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: The Agency is committed to following the procurement process and requirements outlined within the policies and procedures. The Agency plans to revise current procurement policy to have a process for the maintenance of documentation related to procurement determinations. All procurement will be monitored through the Sage Intacct and Ramp system, which has already been implemented. Name of the contact person responsible for corrective action: Dhiren Shah, CFO Planned completion date for corrective action plan: Immediately

View Audit 388267

Finding 1174660 (2025-002)

Material Weakness 2025

Shenandoah Area Agency on Aging, INC

VA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Management agrees with the finding. Management plans to implement a process to ensure that the AMR report will be submitted accurately. If the Federal Audit Clearinghouse has questions regarding this plan, please call Cindy Donaldson, Director of Finance, at 540-635-7141.

View Audit 388226

Finding 1174654 (2025-002)

Material Weakness 2025

North Sweetwater Water and Sewer District

WY

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

The NSWSD Board will include motions and votes pertaining to the approval of federal funding requests in their Meeting Minutes to ensure all Uniform Guidance regulations, relating to allowability, accuracy, and proper authorization of federal expenditure requests, are performed in accordance with fe...

The NSWSD Board will include motions and votes pertaining to the approval of federal funding requests in their Meeting Minutes to ensure all Uniform Guidance regulations, relating to allowability, accuracy, and proper authorization of federal expenditure requests, are performed in accordance with federal regulations.

View Audit 388204

Corrective Action Plans

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