Corrective Action Plans

Finding 1175626 (2025-003)

Material Weakness 2025

CA

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency

Recommendation: We recommend that the University establish procedures to ensure that at least 7% of Federal Work Study allocation is used for community service jobs, including a reading tutor, or successfully receive a waiver. Explanation of disagreement with audit finding: There is no disagreement ...

Recommendation: We recommend that the University establish procedures to ensure that at least 7% of Federal Work Study allocation is used for community service jobs, including a reading tutor, or successfully receive a waiver. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: National University (NU) agrees with the importance of ensuring compliance with FWS community service requirements. The University implemented additional internal controls and policy changes to how it administers the FWS program and completes FISAP reporting to resolve this issue. During NU’s annual FISAP reporting process, it discovered that it had not met its FWS community service obligation. The University submitted a waiver, but it was denied. The University took immediate action to determine the cause of not meeting its FWS community service obligations. Community Partnership Management: National University previously had a partnership with Barrio Logan College Institute (BLCI) located in San Diego, CA. This partnership changed during the pandemic when all schools received a waiver for the community service requirement. In August 2024, Elyse Joiner, Director of Financial Aid Processing, again reached out to BLCI to reestablish a partnership. At that time, National was informed that the previous point of contact was no longer employed with BLCI, but the institute was still interested in partnering with National to meet the community service requirement for Federal Work Study. Ms. Joiner had several communications with BLCI to implement and finalize the setup of the reading and math tutors, with the only outstanding item related to the need for a virtual option. Unfortunately, communication between National University and BLCI ceased in April 2025 when National stopped receiving responses from BLCI to its inquiries. To establish another partnership, Ms. Joiner reached out to United Way of San Diego County to explore the possibility of establishing a reading or math tutor program with them but did not receive a response. Program Administration Change: Federal Work Study funds were budgeted to meet the University’s community service requirement; however, due to unforeseen circumstances and the efforts noted above, the University was unable to meet the 7% community service requirement. The University did have tutors available to the University community, but this did not fulfill the community service requirement. National University has since rectified this for the current aid year. The positions have been posted (R 2025 3051), and the University will have multiple FWS students at the Nest at Spectrum, offering tutoring services to both NU students and the public. The YMCA next to Spectrum will also be informed about the services to promote additional awareness within the local community. Additional opportunities are being actively explored within the Student Disability Services team and the Schools of Law & Public Service and Education. Steps taken to improve transparency and tracking: The University conducted a holistic review of the current FWS policies and procedures and has or will take the following steps: o Comprehensive training for administering the FWS program and Campus-Based Funding programs o Develop and implement an internal control plan that monitors FWS spending activity, allowing for the proactive identification of when the University should reallocate funds between campus-based programs. o Implemented quarterly calibration meetings between FWS/Operations leaders and HR to ensure its FWS program is on track to meet the FWS community service, literacy, and tutoring regulatory requirements. o Explore the expansion of community service relationships and opportunities within the Federal Work Study Program. Name(s) of the contact person(s) responsible for corrective action: - Alan Coddington, AVP Student Financial Services - Elyse Joiner, Director of Operations, Financial Aid Processing and Technical Solutions - Rob Conlon, AVP Financial Aid Compliance Planned completion date for corrective action plan: February 2026

View Audit 389454

Finding 1175625 (2025-002)

Material Weakness 2025

National University

CA

Student Financial Aid Subrecipient Monitoring Reporting

Recommendation: We recommend the University establish and implement a contingency process to ensure enrollment reporting continues during system access disruptions. This process should include monitoring NSC access status and developing alternative procedures to prevent reporting gaps, ensuring that...

Recommendation: We recommend the University establish and implement a contingency process to ensure enrollment reporting continues during system access disruptions. This process should include monitoring NSC access status and developing alternative procedures to prevent reporting gaps, ensuring that all student statuses are submitted accurately and within the required 60-day timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: National University agrees with the importance of ensuring accurate and timely enrollment reporting to NSLDS. The University has taken significant steps to improve its internal controls and compliance with enrollment reporting requirements. The University has identified a few items that have resulted in challenges to accurate and timely enrollment reporting during the audit year. National Student Clearing House (NSC) reporting: On October 18, 2024, the institution was notified by NSC that its access to process enrollment reporting on behalf of NU was revoked during July 2024, resulting in a reporting gap. The University took immediate action to restore access to NSC. Access issues were fully resolved on October 23, 2024. Additionally, NU revised its policies and implemented an internal control plan that monitors NSC activity allowing for proactive identification of future service interruptions. All 33 enrollment certification errors occurred during the disconnect noted above. The University believes its current enrollment certification processes are timely, accurate, and compliant. Timing of implemented enrollment reporting changes: During the audit period National University implemented several improvements to refine and enhance the timeliness of its enrollment reporting. NU established stronger alignment across both OPEIDs and adjusted its timelines to ensure consistent and timely submissions. As part of this effort, the University restructured its reporting schedule, so that finalized enrollment report is submitted by the 6th of each month, supporting a successful and expedited monthly transfer from NSC to NSLDS. Since implementing these revised timelines and deadlines, the University has observed significant improvements and consistency in its internal QA audit scores during the audit period (since January 2025). Four of the five late reporting instances occurred before the implementation date of the University’s enrollment reporting changes. The University believes its refined and enhanced process changes demonstrate its commitment to timely, accurate, and compliant enrollment certification processes. One of the five late reporting instances occurred after the implementation date, and that was related to the student’s status change from active, to pending graduate, to graduate, and then withdrawn. The University will evaluate its process for reporting student status changes from pending graduate, graduate, and withdrawal to ensure clear definitions and status flows are in place. The University will create and deliver focused training in this area to stress the importance of accurate enrollment reporting. In addition to the above, the University will continue to take the following steps: • Continued monitoring and refining of processes to maintain timely and accurate reporting. Including, but not limited to its monthly testing of enrollment reporting accuracy to NSLDS conducted by the quality assurance team. • Identification and timely delivery of training for areas of opportunity identified in the monthly reviews to the registrar and data operations teams. • Revise the internal changes and documentation processes to ensure clarity of policy and regulatory guidance in areas of identified risk/confusion during enrollment reporting processing. Name(s) of the contact person(s) responsible for corrective action: - Rob Conlon, AVP Financial Aid Compliance - Sarah Massey, AVP of Operations Student Support and Registrar Operations - Gabrielle Witruke, Associate Director Data Analytics Planned completion date for corrective action plan: November 2025

View Audit 389454

Finding 1175619 (2025-001)

Material Weakness 2025

National University

CA

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

Recommendation: We recommend the University review the R2T4 requirements and implement adequate procedures to make sure that students that withdrew have a calculation performed. We also recommend the University to evaluate the R2T4 review process to ensure Title IV funds are returned timely. Explana...

Recommendation: We recommend the University review the R2T4 requirements and implement adequate procedures to make sure that students that withdrew have a calculation performed. We also recommend the University to evaluate the R2T4 review process to ensure Title IV funds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University agrees with the importance of ensuring that the return of Title IV funds (R2T4) calculation is performed both timely and accurately. The University has taken significant steps to improve its compliance with R2T4 requirements. These efforts have yielded improved results with the late return error rate decreasing year over year from 13% to 7%. The University will continue to monitor staffing levels and workload to ensure that staffing aligns with timeline requirements. The University’s Processing team will lead focused R2T4 training on topics related to areas of noncompliance. Additional topics will be identified throughout the year as trends are identified in the Quality Assurance Audit process. The following steps will be taken immediately to address finding 2025-001. - The Processing team will continue to conduct subject matter training monthly, prioritized as follows: o Post Withdrawal Disbursements (PWD) identification o Post Withdrawal Disbursement timeline requirements - A new weekly review will be implemented by quality assurance outside of the review completed by R2T4 leadership to test if processing specialists are accurately determining if an R2T4 is required and if a refund is needed for a withdrawn student. Results will be used to coach staff members as needed. The University’s Quality Assurance team will continue to conduct weekly R2T4 reviews to test the R2T4 calculation for accuracy, timeliness of funds returned, and verifying that all internal and external system inputs are completed correctly. Findings from the internal audits will inform ongoing training and remediation steps throughout the year. Name(s) of the contact person(s) responsible for corrective action: - Rob Conlon, AVP Financial Aid Compliance - Alan Coddington, AVP Student Financial Services - John Okel, Director of Operations, Financial Aid Processing Planned completion date for corrective action plan: January 2026

View Audit 389454

Finding 1175611 (2025-002)

Material Weakness 2025

Lehigh University

PA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

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.

View Audit 389449

Finding 1175608 (2025-004)

Material Weakness 2025

La Salle University

PA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.032, 84.033, 84.063 Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding ...

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.032, 84.033, 84.063 Recommendation: We recommend the University review its policies and procedures related to outstanding Title IV checks to ensure they are being returned to the Department of Education after being outstanding more than 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: La Salle University AVP/Controller and AVP/Student Financial Service have reviewed the finding related to the escheatment of Title IV student refunds and have implemented a formal step-by-step process and policy to ensure compliance going forward. The updated procedure outlines clear responsibilities, required timelines, and documentation standards for processing unclaimed refunds and escheating funds in accordance with federal and state regulations. Staff have been informed of the new process and will follow the documented policy moving forward. Name(s) of the contact person(s) responsible for corrective action: AVP/Controller, Viviana Yang and AVP/Student Financial Service, Michele McDevitt. Planned completion date for corrective action plan: March 31,2026

View Audit 389443

Finding 1175607 (2025-003)

Material Weakness 2025

La Salle University

PA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies to ensure correct dates are being used in the calculation and that it is reviewed for accuracy. Explanation of disagreement with audit...

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies to ensure correct dates are being used in the calculation and that it is reviewed for accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Selected semester-related values in our Student Information System (BANNER) will be reviewed for compliance with the official, stated values in the school’s academic calendar. Adjusting for Housing-related dates or potential extensions due to possible delays caused by uncontrollable events will not be included. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Summer 2026 (Fall 2025 and Spring 2026 are already in process as of this writing)

View Audit 389443

Finding 1175602 (2025-001)

Material Weakness 2025

La Salle University

PA

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing COD reporting to ensure timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit...

Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing COD reporting to ensure timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: La Salle University has developed a report that enables weekly auditing of the Pell-eligible student population to ensure accurate identification and timely submission for evaluation. This report will be monitored on an ongoing weekly basis to promptly detect and address any errors related to Pell eligibility. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President for Student Financial Services Planned completion date for corrective action plan: Corrected as of Spring 2026 (Fall 2025 is already complete as of this writing)

View Audit 389443

Finding 1175598 (2025-001)

Material Weakness 2025

Gila Bend Unified School District No. 24

AZ

Internal Control / Segregation of Duties Cash Management Reporting

2025-001 Reporting Federal Assistance Listing Number: 10.553, 10.555, 10.559 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: ...

2025-001 Reporting Federal Assistance Listing Number: 10.553, 10.555, 10.559 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 net under-reported by 48 lunch and breakfast meals, which calculated to $432.84. 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: Sherry Wallace, Director of Finance.

View Audit 389426

Finding 1175586 (2025-001)

Material Weakness 2025

Mid-Kansas Community Action Program, Inc.

KS

Significant Deficiency

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL PROGRAMS FEDERAL AGENCY: DEPARTMENT OF HEALTH AND HUMAN SERVICES PASS THROUGH ENTITY: KANSAS HOUSING RESOURCE CORPORATION PROGRAM NAME: COMMUNITY SERVICES BLOCK GRANT ASSISTANCE LISTING NUMBER: 93.569 AWARD PERIOD: YEAR ENDED JUNE 30, 2025 2025-001 Compl...

FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL PROGRAMS FEDERAL AGENCY: DEPARTMENT OF HEALTH AND HUMAN SERVICES PASS THROUGH ENTITY: KANSAS HOUSING RESOURCE CORPORATION PROGRAM NAME: COMMUNITY SERVICES BLOCK GRANT ASSISTANCE LISTING NUMBER: 93.569 AWARD PERIOD: YEAR ENDED JUNE 30, 2025 2025-001 Compliance and Controls over Tri-Partite Board Requirement for the Community Services Block Grant (Significant Deficiency) Recommendation: We recommend the Board of Directors and management work to fill the vacancies in the public and low-income sectors. Action Taken (Unaudited): Mid-Cap turns in a report to KHRC monthly, has board discussion and has restructured board recruitment. Planned completion for filling all vacancies is 2/6/2026.

View Audit 389415

Finding 1175584 (2025-001)

Material Weakness 2025

McDaniel College and Subsidiary

MD

Subrecipient Monitoring Cash Management Reporting

Finding 2025-001 Condition Significant Deficiency – Disbursement/Refund of Credit Balances - Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the credit balance occ...

Finding 2025-001 Condition Significant Deficiency – Disbursement/Refund of Credit Balances - Title IV regulations (34 CFR 668.164(h)(1) require that Title IV credit balances on student accounts be paid directly to the student as soon as possible but no later than 14 days after the credit balance occurred. A student or parent may authorize the Institution to hold the credit balance to be applied to specified other nontuition fees, room and board charges as noted in the regulations at (34 CFR 668.165(b)). The credit balance generated in the accounts of 2 out of 25 students tested was not timely refunded to them based on the outlined criteria, leading to late refunds to those students (neither of which completed a voluntary hold authorization). The sample was not a statistically valid sample. The College's payment process cycle is not set up to process refunds as soon as possible, which caused delays in refunds being made to students, resulting in a violation of the 14-day maximum policy. Corrective Action Plan Corrective Action Planned: The College acknowledges the untimely disbursement of Title IV credit balance refunds. We concur that, for 2 of the 25 student accounts reviewed, Title IV credit balances were not refunded within the 14-day period required under 34 CFR 668.164(h)(1). We further acknowledge that no valid student or parent authorization to hold these credit balances was on file, and therefore the refunds should have been issued promptly. The College completed an internal review and determined that the delays resulted from the structure of the existing payment processing cycle. Although the College’s processes emphasize careful reconciliation and verification of student account activity, the timing of our refund cycle was not aligned with the regulatory requirement. To remediate this deficiency and ensure full compliance going forward, the College is implementing the following corrective action: Revision of Federal Funds Disbursement Policies: The College is revising its policy governing the drawdown and disbursement of federal funds to align the timing of Title IV activity with the academic add/drop period. This change will ensure greater predictability of credit balance creation and enhance monitoring capabilities. The College is committed to strengthening its internal controls to ensure sustained compliance with all Title IV cash management regulations. Name(s) of Contact Person(s) Responsible for Corrective Action: Pat Tyler, Bursar and Destiny Guerrero, Director of Financial Aid. Anticipated Completion Date: May 2026 – next semester starting date

View Audit 389412

Finding 1175444 (2025-001)

Material Weakness 2025

Round Rock Housing Authority

TX

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

At the time of the most recent independent audit by Smith Marion conducted in December 2025, it was found that RRHA was not completing voucher re-inspections within the required timeframe when an inspection failed. Health and safety inspections are required to be reinspected within 48 hours, and oth...

At the time of the most recent independent audit by Smith Marion conducted in December 2025, it was found that RRHA was not completing voucher re-inspections within the required timeframe when an inspection failed. Health and safety inspections are required to be reinspected within 48 hours, and other inspections must be completed within 30 days. In the past RRHA only had one inspector on staff who tracked all inspections. Due to an increase in portability vouchers a second caseworker was hired in 2025. However, a new system was not created to track both caseworker’s inspections. This resulted in RRHA overlooking timelines and not completing inspections in a timely manner as required. Part of this was also related to miscommunication between the two case workers. To ensure inspections are completed as required by HUD regulation, in the future, each caseworker/inspector is now required to schedule a follow-up inspection appointment at the same time as the failed inspection report is created. Additionally, a separate shared spreadsheet has been created to track failed inspection and verify that each one is being completed within the required time. With these new steps in place we can indicate if a failed inspection needs a 24-hour and/or a 30- day re-inspection and if a follow-up inspection has been already scheduled. RRHA also increased the scheduled time/ days from once a week to two days a week for inspection since we now have two HCV employees/ inspectors available. Effective immediately the process for inspection has been updated and both HCV employees are completing inspections.

View Audit 389242

Finding 1175442 (2025-002)

Material Weakness 2025

City of Sand Springs

OK

Reporting Significant Deficiency

RE: Finding 2025-002 Capital Assets Additions/Cutoff Errors In conjunction with our FY25 annual audit, please see the City's corrective action plan below: The City of Sand Springs will implement enhanced internal controls and review procedures concerning capital asset additions to ensure invoices an...

RE: Finding 2025-002 Capital Assets Additions/Cutoff Errors In conjunction with our FY25 annual audit, please see the City's corrective action plan below: The City of Sand Springs will implement enhanced internal controls and review procedures concerning capital asset additions to ensure invoices and applications for payment are accurately processed and recorded in the proper fiscal year. Specific corrective actions will include: Formalized Cutoff Review Process o Establish a documented year-end cutoff checklist for capital projects. o Require verification of invoice dates, application-for-payment periods, and substantial completion dates prior to posting. o Ensure all invoices and applications for payment are reviewed for proper fiscal year classification before approval. Improved Review of Applications for Payment o Require secondary review and approval of all applications for payment related to capital projects. o Implement a control to ensure cancelled or corrected applications for payment are clearly documented and removed from processing prior to payment. o Maintain supporting documentation evidencing review and approval. Encumbrance and Fiscal Year Posting Controls o Strengthen procedures for tracking encumbrances at year-end, including reconciliation between open encumbrances, invoices received, and capital asset postings. o Require supervisory review of all capital asset additions posted during the year-end close process to confirm proper fiscal year posting. Training and Accountability o Provide targeted training to finance and project management staff on fiscal year cutoff requirements and capital asset accounting. o Clearly define roles and responsibilities for invoice review, posting, and approval to reduce reliance on informal manual adjustments. Expected completion date: Procedures will be implemented for the fiscal year ending June 30, 2026, and applied during interim processing and year-end close. Party Responsible: Finance Director and Finance Staff, in coordination with applicable Department Heads and Project Managers. Contact Information: Arlena Barnes 918-246-2646 arlena.barnes@sandspringsok.gov

View Audit 389227

Finding 1175440 (2025-001)

Material Weakness 2025

Milwaukee Institute of Art and Design, Inc.

WI

Reporting Special Tests & Provisions Student Financial Aid

Finding 2025-001 Condition Management implemented controls that specifically addressed some of the circumstances surrounding prior year finding 2024-001. Management's review of the enrollment reporting did not timely report certain student Campus-Level and Program-Level data elements. Student record...

Finding 2025-001 Condition Management implemented controls that specifically addressed some of the circumstances surrounding prior year finding 2024-001. Management's review of the enrollment reporting did not timely report certain student Campus-Level and Program-Level data elements. Student records within the NSLDS was identified with non-timely Campus-Level and Program-Level data elements. Corrective Action Plan Corrective Action Planned: Management agrees with the finding. To resolve this issue, when a student formally withdraws or is academically dismissed in summer, the student information will be manually added to the next National Student Clearinghouse (NSC) upload file, submitted once a month, and marked as “Withdrawn” with an effective status date of the withdrawn date of determination. This complies with NSC processes detailed here: https://help.studentclearinghouse.org/compliancecentral/knowledge-base/enrollment-reporting-for-summer-and-other-non-required-terms/. Name of Contact Person Responsible for Corrective Action: Mark Fetherston, Vice President for Enrollment Management Anticipated Completion Date: Process and procedures will be updated in February 2026, with first implementation in May 2026 (as part of the Summer 2026 submission process).

View Audit 389221

Finding 1175419 (2025-001)

Material Weakness 2025

City of Reno

NV

Subrecipient Monitoring Reporting Significant Deficiency

Federal program: Community Development Block Grants/Entitlement Special Purpose Grants Cluster (CFDA #14.218). Condition/context: During testing, auditors were provided with documentation that indicated the City did not file a PR29-CDBG Cash on Hand Quarterly report by the specified due date. Of the...

Federal program: Community Development Block Grants/Entitlement Special Purpose Grants Cluster (CFDA #14.218). Condition/context: During testing, auditors were provided with documentation that indicated the City did not file a PR29-CDBG Cash on Hand Quarterly report by the specified due date. Of the four (4) reports available for testing, two (2) were randomly selected and it was noted that one (1) was not filed by the due date. Corrective action: The City will establish and maintain deadlines and monitor the timely submission of all required reports under the CDBG program, including the PR29 quarterly report. The tracking system will include key due dates, responsible staff and confirmation of submission to ensure accountability and consistency. Procedures will also be established and implemented to ensure continuity of reporting in the event of staff turnover. Implementation date: Implemented and in effect immediately. Contact person: Elaine Wiseman, (775)334-2578, wisemane@reno.gov

View Audit 389174

Finding 1175411 (2025-002)

Material Weakness 2025

Guilford College

NC

Special Tests & Provisions Student Financial Aid Significant Deficiency

Audit Period: June 30, 2025 The findings from the June 30, 2025 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONS COSTS – MAJOR FEDERAL AWARD PROGRAM AUDIT 2025-002 –...

Audit Period: June 30, 2025 The findings from the June 30, 2025 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONS COSTS – MAJOR FEDERAL AWARD PROGRAM AUDIT 2025-002 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Return of Title IV Refunds (Significant Deficiency) Condition: From a population of 74 students that officially or unofficially withdrew during the term, we tested nine students and noted that four students required refund calculations. From the fall 2024 semester calculations we noted that the College did not deduct Thanksgiving break of nine days, November 23, 2024 through December 1, 2024, from the total days in the semester. Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period (34 CFR Section 668.22(f)(2)(i)). Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the condition above. Effect: Calculations were incorrect for the three students tested that officially or unofficially withdrew during the fall 2024 term resulting in an incorrect amount of funds returned to the student and the Department of Education. Repeat Finding from a Prior Year: No Recommendation: We recommend the College implement procedures for accurate preparation and calculation of Title IV refunds. Management Response: The college is in agreement with the recommendation to implement procedures for accurate preparation and calculation of Title IV funds. If the Federal Audit Clearinghouse has questions regarding this plan, please call Danielle Pfaff, Controller, at 1-336-316-2140 or dpfaff@guilford.edu

View Audit 389123

Finding 1175409 (2025-001)

Material Weakness 2025

Pasadena Area Community College District

CA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

The Office of Financial Aid is currently strengthening the Return to Title IV (R2T4) process by formalizing written procedures and integrating industry best practices. As part of this effort, we are implementing a quality control system whereby a second team member reviews each file to ensure the ac...

The Office of Financial Aid is currently strengthening the Return to Title IV (R2T4) process by formalizing written procedures and integrating industry best practices. As part of this effort, we are implementing a quality control system whereby a second team member reviews each file to ensure the accuracy of calculations, the completion of necessary pullbacks or billings, and timely communication with students. Additionally, we are enhancing our Title IV reconciliation process to serve as an added layer of oversight, verifying that award data in our student information system (Banner) aligns with records in the Common Origination and Disbursement (COD) system.

View Audit 389117

Finding 1175381 (2025-002)

Material Weakness 2025

Independent School District No. 728

MN

Procurement, Suspension & Debarment Eligibility Significant Deficiency

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 requires Independent School District No. 728 (the District) to establish and maintain effective internal control over compliance with requirements applicable to its federal program expenditures, including suspension and debarment requirements. Our testing indicated the District did not have sufficient controls in place within its special education cluster federal programs to assure it 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, prior to purchasing over $25,000 of goods or services from the vendor. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to suspension and debarment for special education cluster federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding prior to expending federal funds with such vendors. Official Responsible – The District’s Director of Finance, Joseph Primus. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Director of Finance will monitor the implementation of these corrective actions to ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website prior to expending federal funds with such vendors.

View Audit 389098

Finding 1175357 (2025-001)

Material Weakness 2025

West Hills Community College District

CA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

The District concurs with the audit finding. The error occurred in the context of courses offered in modules, which are subject to unique federal calculation requirements. To address this finding and strengthen internal controls over R2T4 calculations for modular coursework, Lemoore College will imp...

The District concurs with the audit finding. The error occurred in the context of courses offered in modules, which are subject to unique federal calculation requirements. To address this finding and strengthen internal controls over R2T4 calculations for modular coursework, Lemoore College will implement the following corrective actions: 1. System-Based Calculation Tool Development Lemoore College will work with the District’s IT department to develop a tool that accurately calculates the percentage of the term completed for students enrolled in courses offered in modules. This tool will be designed to align with applicable federal R2T4 requirements and reduce reliance on manual calculations. 2. Interim Manual Calculation Controls Until the system-based solution is implemented, Lemoore College will implement enhanced review procedures for all R2T4 calculations involving modular coursework, including documented secondary review of the withdrawal date, module dates, and percentage of term completed. 3. Procedure Documentation and Staff Guidance Lemoore College will update internal procedures and provide targeted guidance to Financial Aid staff regarding R2T4 calculations for modular courses, including documentation standards and review expectations. 4. Ongoing Monitoring Supervisory monitoring and periodic spot checks will be conducted to ensure the continued accuracy of R2T4 calculations involving modular coursework.

View Audit 389062

Finding 1175305 (2025-007)

Material Weakness 2025

Hilbert College

NY

Student Financial Aid Eligibility Significant Deficiency

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063 Recommendation: We recommend that the College review its procedures to ensure their internal system pulls the correct SAI amounts directly from the student's ISIR when calculating a student’s Pell award. Explanation of disa...

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063 Recommendation: We recommend that the College review its procedures to ensure their internal system pulls the correct SAI amounts directly from the student's ISIR when calculating a student’s Pell award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure compliance, the College will implement the following corrective actions: 1. System Configuration Review: The Financial Aid Office, in coordination with Powerfaids (College Board), will conduct a comprehensive review of system configuration settings to confirm that SAI values are pulled directly and accurately from the student’s valid ISIR transaction when calculating Pell eligibility when PARM ROLL is run each year. 2. Validation and Testing: The College will perform test file reviews comparing ISIR SAI values to system-calculated Pell awards to confirm accuracy. Any discrepancies identified will be corrected through system reconfiguration or vendor-supported adjustments (as per College Board.) 3. Quality Control Review: A secondary-level review, (i.e., the counselors designated to their individual alphabet cohort) will be implemented during each awarding cycle to confirm that Pell awards align with the student’s valid SAI and enrollment intensity. These corrective actions strengthen internal controls over Pell awarding, ensure SAI data integrity, and mitigate the risk of future calculation discrepancies. Name(s) of the contact person(s) responsible for corrective action: Stephanie Schroeder, Director of Financial Aid Planned completion date for corrective action plan: Immediate action will take place, with the goal of implementing these changes effectively before the start of the new academic year

View Audit 389014

Finding 1175304 (2025-006)

Material Weakness 2025

Hilbert College

NY

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: We recommend the College evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are r...

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: We recommend the College evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In the absence of the Bursar due to short-term disability, the Associate Bursar was not fully trained in processing credit balances within the required timeframe. Since then, under direction of the Bursar, the Associate Bursar has been trained and occasionally processes credit balances to ensure comfortability and accuracy. The College has evaluated and updated its policies and procedures regarding student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Name(s) of the contact person(s) responsible for corrective action: Julie Lanski, Director Student Financial Services/Bursar Planned completion date for corrective action plan: May 31, 2026

View Audit 389014

Finding 1175299 (2025-005)

Material Weakness 2025

Hilbert College

NY

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: We recommend that the College review its reporting procedures to COD to ensure disbursements are reported timely and accurately to be in compliance with regulations. Explanati...

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: We recommend that the College review its reporting procedures to COD to ensure disbursements are reported timely and accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure compliance, the College will implement the following corrective actions: 1. Established Reporting Timeline: All disbursements will be reported to COD within fifteen calendar days of the date of disbursement, in accordance with federal regulations. 2. Secondary-Level Review: We will make it a goal to have another person within the student finance office trained to perform bi-weekly or monthly reviews of COD transmission reports to confirm accuracy and completeness. Evidence of review will be documented and retained. These corrective actions strengthen internal controls, enhance monitoring processes, and ensure disbursements are reported to COD timely and accurately moving forward. Name(s) of the contact person(s) responsible for corrective action: Stephanie Schroeder, Director of Financial Aid Planned completion date for corrective action plan: Immediate action will take place, with the goal of implementing these changes effectively before the start of the new academic year

View Audit 389014

Finding 1175294 (2025-004)

Material Weakness 2025

Hilbert College

NY

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: We recommend the College review its reporting procedures to ensure that key line Items within the Fiscal Operations Report and Application to Participate (FISAP) are reviewed ...

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: We recommend the College review its reporting procedures to ensure that key line Items within the Fiscal Operations Report and Application to Participate (FISAP) are reviewed and accurately reported to Department of Education as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Controller will ensure that when reporting revenue on the FISAP that it properly breaks out Graduate tuition separately from all other Tuition. Name(s) of the contact person(s) responsible for corrective action: Lisa Ressman, Controller Planned completion date for corrective action plan: February 17, 2026

View Audit 389014

Finding 1175289 (2025-003)

Material Weakness 2025

Hilbert College

NY

Reporting Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on reporting student's verification statuses to COD timely and accurately to be in compliance with regulations. Explanati...

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on reporting student's verification statuses to COD timely and accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To ensure compliance, the College will implement the following corrective actions: 1. Policy Update: The Financial Aid Policies and Procedures will be revised to formally document procedures for reporting verification status updates to COD, including defined timelines and assigned responsibilities within the office. 2. Established Reporting Timeline: Verification status updates will be submitted to COD within ten business days of verification completion or any change impacting Pell eligibility. 3. Tracking and Oversight: A verification tracking log will be implemented to document completion dates and COD reporting dates within the Powerfaids system to ensure verification tasks are completed. 4. Staff Training: Financial aid staff will receive training in updated procedures and COD reporting requirements. These measures strengthen internal controls, enhance oversight, and ensure timely and accurate reporting of verification statuses to COD moving forward. Name(s) of the contact person(s) responsible for corrective action: Stephanie Schroeder, Director of Financial Aid Planned completion date for corrective action plan: Immediate action will take place, with the goal of implementing these changes effectively before the start of the new academic year.

View Audit 389014

Finding 1175284 (2025-002)

Material Weakness 2025

Hilbert College

NY

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on determining student's withdrawals, specifically the proper calculation elements and proper rounding were necessary to ...

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on determining student's withdrawals, specifically the proper calculation elements and proper rounding were necessary to ensure timely and accurate returns of Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) Break days of 5 consecutive days or more were incorrectly added to PowerFaids during setup. The College has reviewed and updated its policies and procedures to show that both the Director of Financial Aid and the Bursar will review the number of days to be entered into PowerFaids to ensure that prior and post-weekend days are included in the scheduled break when applicable. 2) In manually calculating the Return of Title IV Funds, the adding machine was inadvertently not set to round to three decimal places as required. The Bursar is responsible for calculating Return of Title IV funds and will ensure that any manual calculations are rounded to three decimal places as required. Policies and procedures have been updated to reflect the requirements of this critical step. Name(s) of the contact person(s) responsible for corrective action: Julie Lanski, Director Student Financial Services/Bursar Planned completion date for corrective action plan: May 31, 2026

View Audit 389014

Finding 1175279 (2025-001)

Material Weakness 2025

Hilbert College

NY

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on reviewing enrollment status changes to NSLDS to ensure that all status changes are being reported timely and accuratel...

Student Financial Assistance Cluster – Federal Assistance Listing No. 84.063, 84.268, 84.007, 84.038, 84.033 Recommendation: The College should review its policies and procedures on reviewing enrollment status changes to NSLDS to ensure that all status changes are being reported timely and accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the NSLDS. The Registration and Records Office will continue to work with NSCL and NSLDS on specific enrollment scenarios that require different submission update requirements. Name(s) of the contact person(s) responsible for corrective action: Katelyn Letizia, Interim Vice President Institutional Effectiveness and Academic Strategy. Planned completion date for corrective action plan: May 31, 2026

View Audit 389014

Corrective Action Plans

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