Corrective Action Plans

Finding 1165331 (2025-001)

Material Weakness 2025

OH

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s ...

Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s Tier 1 banking agreement are not inconsistent with the best financial interest of students who choose to open an account, UC Campus Services will, at a minimum, every 2 years, beginning October 2025: a. Conduct a due diligence review to ascertain whether the fees imposed under the current agreement are consistent with or below prevailing market rates. a. This will be accomplished by downloading and comparing “consumer schedule of fees” documents from UC’s current provider as well as several local competitors (e.g. US Bank, Fifth Third Bank, Chase Bank, Superior Credit Union). b. Ensure that termination provisions are maintained in the active agreement. These provisions are listed in the current agreement under Exhibit G. 4. (g). (1). In addition, the university will organize a Title IV compliance working group to meet monthly to review any communications or new requirements published by the U.S. Department of ED, State of Ohio, or other regulatory agencies. This core working group will be comprised of members of the Student Financial Aid Office, the Office of the Bursar, and the Office of the Controller, the three offices primarily responsible for awarding, disbursing, and drawing down funds related to the Title IV programs. This group will be responsible for communicating any changes to institutional responsibilities to other university partners who may need to review or revise policies and procedures based on the regulatory changes. Contact person responsible for corrective action: Neal Stark for the specific remedy for the due diligence review, Leigh Jackson for the compliance working group. Anticipated Completion Date: 10/31/2025 and every 2 years thereafter

View Audit 375925

Finding 1165325 (2025-003)

Material Weakness 2025

Rocky Mountain College

MT

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation ...

Finding 2025-003: In order to ensure proper compliance with the return of Title IV Funds, the CFO and Controller have updated the return to Title IV (R2T 4) workbook to include the correct rounding method per federal regulation and the Federal Student Aid Handbook. Documentation of each calculation will now include evidence of rounding verification as part of the R2T4 process. Additionally, the Controller will obtain annual training on current Department of Education requirements, including proper rounding and calculation methodologies.

View Audit 375900

Finding 1165320 (2025-002)

Material Weakness 2025

Rocky Mountain College

MT

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility

Finding 2025-002: In order to ensure proper compliance with the student refund and return process, the CFO, Controller, and Student Accounts Coordinator will establish clear departmental responsibilities for initiating and approving financial aid batches and create an internal processing timeline sh...

Finding 2025-002: In order to ensure proper compliance with the student refund and return process, the CFO, Controller, and Student Accounts Coordinator will establish clear departmental responsibilities for initiating and approving financial aid batches and create an internal processing timeline shorter than the 14-day federal limit. Additionally, the CFO, Controller, and Student Accounts Coordinator will obtain training on the timing and documentation requirements under 34 CFR §668.164(h).

View Audit 375900

Finding 1165315 (2025-001)

Material Weakness 2025

Rocky Mountain College

MT

Reporting Internal Control / Segregation of Duties Special Tests & Provisions

Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to moni...

Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to monitor and report student enrollment changes on a timely basis. The CFO, Controller, and Director of Student Records will explore enhanced monitoring controls such as designating a second reviewer to verify that all files were transmitted and accepted by NSC within required timeframes and implementing an internal tracking log to record the submission and confirmation dates for each roster file.

View Audit 375900

Finding 1165310 (2025-003)

Material Weakness 2025

Chatham School District

AK

Procurement, Suspension & Debarment Reporting Significant Deficiency

The District will stregthen controls to ensure all expenditures charged to federal programs are allowable, properly documented, and comply with the Uniform Guidance (2 CFR Part 200). 1. Policy and Procedure development: Written procedures will be implemented defining allowable costs, budget approval...

The District will stregthen controls to ensure all expenditures charged to federal programs are allowable, properly documented, and comply with the Uniform Guidance (2 CFR Part 200). 1. Policy and Procedure development: Written procedures will be implemented defining allowable costs, budget approval processes, and documentation requirements for federal programs. 2. Pre-approval and Documentation: All expenditures charged to federal awards must receive prior approval from the Program Director and Business Manager, accompanied by invoices, purchase orders, and justification forms referencing the applicable federal cost principle. 3. Monthly Monitoring: The Business Manager will review program expenditures monthly for compliance with allowable cost principles and promptly correct any mischarges. 4. Training: Federal program staff and members of the CSG grants Committee will receive annual training on allowable costs, cost allocation, and time-and effort reporting.

View Audit 375895

Finding 1165309 (2025-001)

Material Weakness 2025

Romoland School District

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility

The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue ...

The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue to utilize the CalPads 1.17 report for reporting student counts for each school. Moving forward, we will implement a dual-verification process, requiring a second person to confirm data accuracy during the entry of numbers into CARS, thereby mitigating the risk of future data entry errors.

View Audit 375893

Finding 1165288 (2025-002)

Material Weakness 2025

Mount Saint Mary's University

CA

Student Financial Aid Reporting Significant Deficiency

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-002 Condition: For 5 of 25 students tested in the sample, the student’s status was reported late to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Corre...

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-002 Condition: For 5 of 25 students tested in the sample, the student’s status was reported late to the National Student Loan Data System (NSLDS). The sample was not a statistically valid sample. Corrective Action Plan : The Registrar’s office generates enrollment reports every three (3) weeks and they are sent to NSLDS. These reports allow for frequent degree of enrollment reporting to correct this type of error. These changes are in place and have taken effect immediately. Name(s) of Contact Person(s) Responsible for Corrective Action: Rocio De Leon, Registrar Anticipated Completion Date: Immediately Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025

View Audit 375827

Finding 1165283 (2025-001)

Material Weakness 2025

Mount Saint Mary's University

CA

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: The University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Corrective Action Plan : The University will co...

Mount Saint Mary’s University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: The University did not have evidence or documentation available to support the control/review process for return of Title IV calculations. Corrective Action Plan : The University will continue to review and adhere to our procedures for refunding awards, and the Financial Aid office will formally document the weekly review of the Return of Title IV funds. Name(s) of Contact Person(s) Responsible for Corrective Action: La Royce Housley, Director of Financial Aid Anticipated Completion Date: Immediately Joy E. Brathwaite, MBA MSA Vice President for Finance and Administration Dated: 12/4/2025

View Audit 375827

Finding 1165239 (2025-001)

Material Weakness 2025

Barton County Community College

KS

Special Tests & Provisions Student Financial Aid Period of Performance

SIGNIFICANT DEFICIENCY 2025-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition Of the 37 students tested for Return to Title IV procedures, 2 were determined to have had errors in their calculation. Recommendat...

SIGNIFICANT DEFICIENCY 2025-001 Federal Program Student Financial Assistance Cluster Compliance requirements Special Tests and Provisions – Return to Title IV Condition Of the 37 students tested for Return to Title IV procedures, 2 were determined to have had errors in their calculation. Recommendation We recommend that the College review and update its policies to ensure that accurate Return to Title IV calculations are completed. Comments on the Finding For the issue with an institutional charge incorrectly considered in the R2T4 calculation, this was due to a Federal Direct Parent PLUS Loan that was processed and a refund to the parent. Only seven of these loans were processed in the aid year of 2024-25, and there were no other R2T4 situations that involved a Federal Direct Parent PLUS Loan. The refund to the parent was shown at the top of the Banner form while student refunds show at the bottom of the Banner form. Due to the rarity of these loans being included in the calculation and the variation of where this charge is shown in Banner, this was missed. Barton personnel are now aware of where to look for this in these very rare cases. For the situation where the incorrect starting date was identified, there was human error when that was entered. Barton does have a quality assurance process to double check all dates on the Banner withdrawal form, and the R2T4 calculation spreadsheet, however, this review will now extend to checking the enrollment dates in a second Banner form. Action Taken Since the 2024-25 aid year was still open, both instances were corrected. Barton’s Director of Financial Aid has made all personnel aware of the issues and has revised the quality assurance review to watch for these issues.

View Audit 375642

Finding 1165228 (2025-001)

Material Weakness 2025

West Palm Beach Housing Authority

FL

HUD Housing Programs Eligibility Reporting

Moving to Work Demonstration Program -Assistance Listing No. 14.881 Recommendation: We recommend that management assign a designated individual to ensure rent reasonableness, income verification, and recertifications are completed accurately and on time, in accordance with HUD guidelines and the Aut...

Moving to Work Demonstration Program -Assistance Listing No. 14.881 Recommendation: We recommend that management assign a designated individual to ensure rent reasonableness, income verification, and recertifications are completed accurately and on time, in accordance with HUD guidelines and the Authority's administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Director of HCV Program Administration and Ass istant Director of HCV Program Administration will be in charge of reviewing all Rent Reasonableness. Name(s) of the contact person(s) responsible for corrective action: Teresa J. Gonzalez, and Darrell Mciver. Planned completion date for corrective action plan: Effective immediately.

View Audit 375578

Finding 1165227 (2025-001)

Material Weakness 2025

Mitchell Hamline School of Law

MN

Student Financial Aid Reporting Significant Deficiency

Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in respo...

Recommendation: We recommend Mitchell Hamline School of Law review its reporting procedures to ensure the students' statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Starting in January 2026, the Registrar’s Office will be performing the monthly reporting. In preparation for this change in responsibilities, Student Financial Aid has provided training to multiple individuals in the Registrar’s Office along with detailed documented procedures. Student Financial Aid and the Registrar’s Office will coordinate responses/requests from NSLDS. Name(s) of the contact person(s) responsible for corrective action: Sheila Tolley, Executive Registrar and Nick Anderson, Director of Financial Aid Planned completion date for corrective action plan: Spring Semester 2026

View Audit 375564

Finding 1165209 (2025-001)

Material Weakness 2025

Augustana College

IL

Student Financial Aid Reporting Significant Deficiency

Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action tak...

Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Augustana intends to modify the NSC/NSLDS monthly data file to ensure that campus and program enrollment dates are pulled from the appropriate data fields in the student information system. Additionally, Augustana intends to implement a step in the withdrawal process to ensure the change in status is reported accurately and timely. Name of the contact person responsible for corrective action: John Cage at johncage@augustana.edu Planned completion date for corrective action plan: January 30, 2026

View Audit 375481

Finding 1165199 (2025-005)

Material Weakness 2025

Yupiit School District

AK

Allowable Costs / Cost Principles Procurement, Suspension & Debarment School Nutrition Programs § 200.303

Finding 2025-005 Lack of Internal Controls over Activities Allowed or Unallowed, Allowable Costs/Cost Principles Name of Contact Person: Jennifer Phillip, Kary Delsignore Corrective Action Plan: Invoices will be approved for payment by the person who receives the product and then approved also by th...

Finding 2025-005 Lack of Internal Controls over Activities Allowed or Unallowed, Allowable Costs/Cost Principles Name of Contact Person: Jennifer Phillip, Kary Delsignore Corrective Action Plan: Invoices will be approved for payment by the person who receives the product and then approved also by the food service coordinator. No unallowable costs will be paid for with food service revenue. Proposed Completion Date: Fiscal Year 2026.

View Audit 375473

Finding 1165198 (2025-004)

Material Weakness 2025

Yupiit School District

AK

Cash Management Reporting School Nutrition Programs

Finding 2025-004 Lack of Internal Controls over Reporting Name of Contact Person: Jennifer Phillip, Kary Delsignore Corrective Action Plan: Records will be reviewed monthly by two individuals to ensure they are complete. Back up documentation shall be kept in a secure location where at least two oth...

Finding 2025-004 Lack of Internal Controls over Reporting Name of Contact Person: Jennifer Phillip, Kary Delsignore Corrective Action Plan: Records will be reviewed monthly by two individuals to ensure they are complete. Back up documentation shall be kept in a secure location where at least two other budget supervisors are aware and have access to same. Proposed Completion Date: Fiscal Year 2026

View Audit 375473

Finding 1165195 (2025-001)

Material Weakness 2025

Southern Wesleyan University

SC

Reporting Student Financial Aid Eligibility

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Will need to meet with academic records and determine if Doctorate program Dissertation 1-hour course can be coded and reported as full time to NSLDS Person Responsible for Corrective Action Plan: ...

Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Will need to meet with academic records and determine if Doctorate program Dissertation 1-hour course can be coded and reported as full time to NSLDS Person Responsible for Corrective Action Plan: Academic Records / Regina Bolding Harned - Registrar / Allison Sullivan – Director of Financial Aid Anticipated Date of Completion: 12/5/25

View Audit 375472

Finding 1165121 (2025-002)

Material Weakness 2025

Hoonah City School District

AK

Procurement, Suspension & Debarment Reporting Significant Deficiency § 200.329

Finding 2025-002 Lack of Internal Control Over Reporting Name of Contact: Rayna Bowdre Corrective Action: The District will ensure all federal reports are properly prepared and values reflect actual values in the accounting software. Proposed Completion Date: December 31, 2025.

View Audit 375416

Finding 1165119 (2025-001)

Material Weakness 2025

Marine Technology Society, Inc.

DC

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency

Management concurs with the finding and will implement procedures to retain evidence of suspension and debarment reviews for all vendors and subrecipients under federally funded programs.

View Audit 375405

Finding 1165114 (2025-001)

Material Weakness 2025

Maricopa County Community College District Foundation

AZ

Reporting Significant Deficiency Internal Control / Segregation of Duties

Item: 2025-001 Assistance Listing Number: 21.027 Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 157096-0 Award Year: October 1, 2022 – September 30, ...

Item: 2025-001 Assistance Listing Number: 21.027 Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: City of Phoenix Pass-Through Grantor Identifying Number: 157096-0 Award Year: October 1, 2022 – September 30, 2025 Compliance Requirement: Reporting Criteria: Per the grant agreements, Maricopa County Community College District Foundation (the “Foundation”) must submit several programmatic reports throughout the grant period with various due dates. Condition: A required programmatic report was submitted 6 days after the due date. Name of Contact Person: Judy Sanchez, Interim CEO Phone Number: 602-402-5062 Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action Plan: The Foundation will design and implement controls regarding the tracking of reporting due dates and retention of concurrent documentation when obtaining extensions or approval for late submissions.

View Audit 375404

Finding 1165101 (2025-001)

Material Weakness 2025

City of Caseville

MI

Reporting Significant Deficiency Internal Control / Segregation of Duties

Recommendation: It is recommended that the City implement written policies and procedures over significant internal control areas. Action to be taken: We agree with the finding and are in the process of implementing written policies and procedures over significant internal control areas including fe...

Recommendation: It is recommended that the City implement written policies and procedures over significant internal control areas. Action to be taken: We agree with the finding and are in the process of implementing written policies and procedures over significant internal control areas including federal award programs.

View Audit 375358

Finding 1165048 (2025-001)

Material Weakness 2025

Housing Authority of Washington County

MD

HUD Housing Programs Significant Deficiency

U.S. Department of Housing and Urban Development Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the housing authority designate an individual to ensure HQS inspections are completed timely. Explanation of disagreement with audit finding: There ...

U.S. Department of Housing and Urban Development Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the housing authority designate an individual to ensure HQS inspections are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our internal audits take place monthly. The HCV department leadership pulls the list of recertifications, interims, and new admissions and samples 10% of each to ensure they have been done correctly, with all information documented. This internal audit includes checking the rent calculation, utilities, verification documents, and tenant/landlord notification. The agency has been completing this internal practice consistently since February 2024. We have designated this responsibility to an HCV staff member. Name(s) of the contact person(s) responsible for corrective action: Morgan Gower Planned completion date for corrective action plan: In progress as of February 2024 and ongoing.

View Audit 375153

Finding 1164934 (2025-002)

Material Weakness 2025

Ypsilanti Community Schools

MI

Cash Management Significant Deficiency Internal Control / Segregation of Duties § 200.305

Corrective Action: The Finance Director will establish clear timelines for submitting and processing payment requests to prevent any discrepancies in cash requests or disbursements. Well-defined internal procedures, including submission deadlines and approval workflows, will ensure that funds are re...

Corrective Action: The Finance Director will establish clear timelines for submitting and processing payment requests to prevent any discrepancies in cash requests or disbursements. Well-defined internal procedures, including submission deadlines and approval workflows, will ensure that funds are requested, approved, and drawn down efficiently. Ongoing monitoring of pending requests, coupled with proactive communication among team members, will further support timely financial management and minimize any risks. Responsible Person: Director of Finance

View Audit 374865

Finding 1164894 (2025-001)

Material Weakness 2025

South San Francisco Unified School District

CA

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

District staff is aware of the student records requirement and will ensure this is accurate moving forward. In addition, a training has been provided to the staff at the schools to ensure they are also informed of this requirement.

View Audit 374836

Finding 1164888 (2025-004)

Material Weakness 2025

Thames Valley Council for Community Action, Inc.

CT

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.308 § 200.309 § 200.403

Finding 2025.004 – Period of Performance Federal Program Name: Continuum of Care Federal Assisted Listing Number:: 14.267 Recommendation We recommend that management implement additional controls and policies over period of performance. Staff who purchase items with grant funds should have additiona...

Finding 2025.004 – Period of Performance Federal Program Name: Continuum of Care Federal Assisted Listing Number:: 14.267 Recommendation We recommend that management implement additional controls and policies over period of performance. Staff who purchase items with grant funds should have additional training on period of performance requirements. Planned Corrective Action: TVCCA is strengthening its period of performance controls through the following actions: 1. Training – All employees with purchasing power will be trained on the deadlines of the grants they are responsible for. This training includes what the definition of obligation truly is, as well as allowable spend down period of their grants. Finance staff will also be trained on the timing and definitions of obligations. 2. Revised internal controls and workflow – Cutoff testing will be performed and added to the month close checklist on a quarterly basis to align with grant closing schedules. 3. Monitoring – Cutoff testing will be monitored on a quarterly basis in association with quarter ending checklist. Name of Contact Person: Max Logan, CFO, 860-425-6506, mlogan@tvcca.org Anticipated Completion Date: March 31, 2026

View Audit 374772

Finding 1164847 (2025-001)

Material Weakness 2025

Iliff School of Theology

CO

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

Condition: The School did not have a documented Direct Loan quality assurance program in place during a significant portion of the year under audit. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student as...

Condition: The School did not have a documented Direct Loan quality assurance program in place during a significant portion of the year under audit. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student assistance programs. The School coordinated with this third-party processor to ensure that a documented quality assurance program was put into place in March 2025 and regularly exercised for compliance purposes. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: March 2025

View Audit 374691

Finding 1164835 (2025-002)

Material Weakness 2025

Chippewa Hills School District

MI

School Nutrition Programs Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.439

Federal Award - Finding Number: 2025-002 Responsible Person: Director of Finance Condition: The district charged to the food service fund the cost of an asset that was not included on the approved equipment list from Michigan Department of Education and did not obtain approval from Michigan Departme...

Federal Award - Finding Number: 2025-002 Responsible Person: Director of Finance Condition: The district charged to the food service fund the cost of an asset that was not included on the approved equipment list from Michigan Department of Education and did not obtain approval from Michigan Department of Education prior to purchase. Corrective Action Plan: All food service fund asset purchases made going forward will be compared to the approved equipment list or approved by the Michigan Department of Education prior to purchase. Anticipated Correction Date: Immediate and Ongoing

View Audit 374660

Corrective Action Plans

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