Corrective Action Plans

Finding 1172058 (2025-002)

Material Weakness 2025

OR

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

Finding 2025-002 - Procurement (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating...

Finding 2025-002 - Procurement (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Department of Transportation Internal Control over Compliance: Procurement Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to develop and implement internal control policies and procedures related to procurement activities. Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements. Cause: Management and leadership lacked awareness of relevant procurement regulations. Consequently, no internal control policies or procedures related to procurement existed, or policies and procedures existed but were not implemented. Effect or Potential Effect: The lack of effective internal controls over procurement activities had allowed for widespread deficiencies and noncompliant activities, which resulted in the District’s revocation of one award. Questioned Cost: None reported Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is significant. The District failed to meet numerous procurement requirements early in the fiscal year and ultimately lost a significant award for bus acquisitions. Repeat of a Prior-Year Finding: Yes Recommendation: The District should design and implement internal controls related to procurement regulations that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations. District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses. There has been a change in the General Manager position, to improve the operations, and training of all management, staffing and leadership. The Board has had significant membership change, with new leadership actively engaged in creating a quality internal control and policy environment. Much education and training has occurred during and after fiscal year 2024-2025, up through December 2025, and is ongoing, to meet these goals. Corrective Action Plan: The District acknowledges the weaknesses and its intention of correcting weaknesses. There has been a change in the General Manager position, to improve the operations, and training of all management, staffing and leadership. The Board has had significant membership change, with new leadership actively engaged in creating a quality internal control and policy environment. Much education and training has occurred during and after fiscal year 2024-2025, up through December 2025, and is ongoing, to meet these goals. Planned Implementation Date: December 31, 2025 Responsible Persons: District Board, Umpqua Public Transit District

View Audit 385183

Finding 1172050 (2025-001)

Material Weakness 2025

Nyos Charter School, Inc.

TX

Cash Management Reporting School Nutrition Programs

Finding 2025-001, Reporting- Significant deficiency in internal controls over compliance Cause: The finding resulted from the lack of a formalized, documented review process to verify the accuracy of claim data between Skyward, PrimeroEdge, and TXUNPS. Historically, the claim reporting relied on sin...

Finding 2025-001, Reporting- Significant deficiency in internal controls over compliance Cause: The finding resulted from the lack of a formalized, documented review process to verify the accuracy of claim data between Skyward, PrimeroEdge, and TXUNPS. Historically, the claim reporting relied on single-entry verification without a defined cross-check procedure or document retention system to confirm alignment across platforms. Corrective Action: NYOS Charter School has implemented a new monthly verification process to ensure accuracy and transparency in the meal count reporting workflow. - The PEIMS Manager will generate the Average Daily Attendance (ADA) report from Skyward each month. - The Food Service Manager will use this report to enter claim data into PrimeroEdge. - The Director of Operations will then cross-reference the claim information from PrimeroEdge with the ADA report from Skyward before entering final claim data into TXUNPS. - Copies of the ADA report, the PrimeroEdge claim summary, and the TXUNPS submission confirmation will be downloaded and stored in the Food Services Google Drive for audit documentation and ongoing internal control review. - Staff involved in this process will receive annual training on verification procedures, documentation standards, and data integrity best practices. Timeline: Updated verification process implemented in October 2025; full rollout and training completed by December 2025. Responsible Party: - Chief of Operations & HR -Director of Operations - PEIMS Manager - Food Service Manager Monitoring: Quarterly internal reviews will be conducted by the Chief of Operations & HR to ensure consistent application of the cross-verification process and proper retention of supporting documentation in the Food Services Google Drive.

View Audit 385161

Finding 1172048 (2025-001)

Material Weakness 2025

Southern California Seminary

CA

Student Financial Aid Reporting Significant Deficiency

FISAP Reporting Planned Corrective Action: Deficiency: The backup documentation submitted for the Fiscal Operations Report and Application to Participate (FISAP) did not match the data reported on the FISAP. Institution Response: We acknowledge this discrepancy and agree that the FISAP backup docume...

FISAP Reporting Planned Corrective Action: Deficiency: The backup documentation submitted for the Fiscal Operations Report and Application to Participate (FISAP) did not match the data reported on the FISAP. Institution Response: We acknowledge this discrepancy and agree that the FISAP backup documentation did not fully align with Part II, Sections 7a (Total Undergraduate Students) and 7b (Total Graduate Students) as reported on the submitted FISAP. The current FISAP reflects 43 for Section 7a, whereas the correct figure is 60, and 199 for Section 7b, whereas the correct figure is 202. Root Cause: At the time the report was prepared, the institution was relying on a contracted financial aid professional to provide the data for FISAP reporting. Although this work was performed in good faith, the contracted individual provided incorrect figures, which resulted in minor data discrepancies between the FISAP and the supporting documentation. Corrective Action Taken: Our Institution has ended its contract with the external financial aid services provider. We have transitioned all financial aid and FISAP-related responsibilities in-house and designated a qualified Data Point Administrator / Director of Financial Aid to oversee the preparation of the report. Additionally, there will be multiple financial professionals reviewing future FISAP and backup data. The current year’s FISAP has already been worked on using this updated structure, and all backup documentation has been reviewed for accuracy and confirmed to match the submitted FISAP. Preventive Measures Going Forward: To ensure accuracy and prevent recurrence, the institution has implemented the following procedures: 1. The Director of Financial Aid (Data Point Administrator) will prepare all FISAP data and maintain appropriate source documentation. 2. The Financial Aid Representative will review the completed FISAP and all backup documents to verify accuracy prior to submission. 3. The Financial Controller will receive the full FISAP packet, including backup documentation for an additional review and institutional oversight. 4. All FISAP materials and supporting documents will be stored in the institution’s secure Financial Aid OneDrive folder to ensure accessibility and consistency during audits. These steps have already been implemented for the most recent FISAP cycle and will be followed annually to maintain compliance and data integrity. Person Responsible for Corrective Action Plan: Josh James, CFO Anticipated Date of Completion: 11/24/2025

View Audit 385150

Finding 1172044 (2025-001)

Material Weakness 2025

Moraine Park Technical College District

WI

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.007, 84.033 Recommendation: Recommend that the College design and implement controls to ensure that all safeguards for identified risks required by the Gramm-Leach-Bliley Act (GLBA) are fully documented and updated as necessary. Expla...

Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.007, 84.033 Recommendation: Recommend that the College design and implement controls to ensure that all safeguards for identified risks required by the Gramm-Leach-Bliley Act (GLBA) are fully documented and updated as necessary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Moraine Park Technical College will take or has already taken the following actions to address the audit finding: 1. Updated existing policies and documentation to fully reflect the controls in place to safeguard identified risks under the Gramm-Leach-Bliley Act. 2. Revised and formalized the following documents to ensure they clearly describe current practices and continuous monitoring activities: • Incident Response document • Risk Assessment document • Written Information Security Plan • IT Vulnerability Management Practices document These updates ensure that all existing controls and processes are fully documented, current, and aligned with GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Larry Plamann, Director of Enterprise Infrastructure Planned completion date for corrective action plan: January 2026

View Audit 385130

Finding 1172004 (2025-001)

Material Weakness 2025

Housing Authority of the City of Norwalk

CT

HUD Housing Programs Special Tests & Provisions Reporting

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. Adam Bov...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. Adam Bovilsky, Executive Director, is responsible for implementing this corrective action by March 31, 2026.

View Audit 385109

Finding 1172003 (2025-001)

Material Weakness 2025

Hamline University of Minnesota

MN

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is...

Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and 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: Auditors identified two students for whom enrollment status on the campus level and program level was correctly reported to NSLDS as withdrawal in December 2024; however, both students graduated in March 2025 and that enrollment status was not updated at the campus level or the program level. We have a manual tracking procedure in place for students who complete missing coursework after their last term of enrollment that results in completion of their program. These two students were missed in that process. As a result of this finding, we have reviewed the procedure with the relevant staff and will continue to monitor the process, adding routine spot-checking of this tracking list. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar, and Lynette Wahl, Student Financial Aid Director Planned completion date for corrective action plan: October 31, 2025

View Audit 385101

Finding 1171970 (2025-004)

Material Weakness 2025

Eureka County, Nevada

NV

Subrecipient Monitoring Reporting Significant Deficiency

Finding Summary: The County did not have adequate controls to ensure Special Tests and Provisions requirements were met. The critical information reported did not have the required “Description of Work Performed” included on the reports. Corrective Action Plan: Eureka County will fill in all boxes o...

Finding Summary: The County did not have adequate controls to ensure Special Tests and Provisions requirements were met. The critical information reported did not have the required “Description of Work Performed” included on the reports. Corrective Action Plan: Eureka County will fill in all boxes on the grant report when being submitted to the Nevada Division of Emergency Management. Responsible Individual: Jayme Halpin, Assistant Public Works Director Anticipated Completion Date: Eureka County will amend the past quarterly reports and any future quarterly reports to reflect actual work performed on the report. This will be completed by January 29, 2026.

View Audit 385051

Finding 1171943 (2025-001)

Material Weakness 2025

Grange Acres Nonprofit Housing Corporation (phase Ii)

MI

Special Tests & Provisions HUD Housing Programs Significant Deficiency

U.S. Department of Housing and Urban Development Grange Acres Nonprofit (Phase II) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Suite 1 Lansing, MI 4...

U.S. Department of Housing and Urban Development Grange Acres Nonprofit (Phase II) respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Suite 1 Lansing, MI 48912 Audit period: July 1, 2024 – June 30, 2025 The finding from the June 30, 2025 schedule of findings and questions costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. Finding Number 2025-001 – Significant Deficiency in Internal Control over Major Federal Program Compliance: Special Tests and Provisions: - Replacement Reserve Requirements Recommendation: The Project should deposit $429 into the replacement reserve account. Additionally, procedures should be followed to ensure management identifies the need for required deposits. Action Taken: The Project has deposited the underfunded amount and will review future HUD communications to identify replacement reserve funding requirements.

View Audit 385022

Finding 1171934 (2025-003)

Material Weakness 2025

City of Wells, Nv

NV

Reporting Cash Management Significant Deficiency § 200.303

Finding Summary: 2 CFR Part 200 (Uniform Guidance) requires that the non-Federal entity must establish and maintain effective internal control over the Federal award. Eide Bailly noted two out of five reimbursement requests had no evidence of approval. Responsible Individuals: Samantha Nance, City C...

Finding Summary: 2 CFR Part 200 (Uniform Guidance) requires that the non-Federal entity must establish and maintain effective internal control over the Federal award. Eide Bailly noted two out of five reimbursement requests had no evidence of approval. Responsible Individuals: Samantha Nance, City Clerk Corrective Action Plan: Create a checklist for all reimbursement request procedures to include prepared by and approved by signatures with every request. Anticipated Completion Date: Immediately

View Audit 384971

Finding 1171866 (2025-001)

Material Weakness 2025

Cleveland State University

OH

Student Financial Aid Subrecipient Monitoring Significant Deficiency § 200.303

Name of the contact person responsible for corrective action planned: Brenda Wendt Controller Cleveland State University 2121 Euclid Avenue Cleveland, OH 44115 Phone: 216.687.3676 Email: b.wendt@csuohio.edu Corrective actions planned: Finding Number: 2025-001 The University did not have adequate con...

Name of the contact person responsible for corrective action planned: Brenda Wendt Controller Cleveland State University 2121 Euclid Avenue Cleveland, OH 44115 Phone: 216.687.3676 Email: b.wendt@csuohio.edu Corrective actions planned: Finding Number: 2025-001 The University did not have adequate controls in place to ensure that credit balances were refunded in a timely manner within the 14-calendar-day requirement. Management has implemented a process to ensure that credit balances are processed within the 14-calendar-day requirement. A workflow hierarchy is in place to ensure adequate staffing and training, preventing processing delays. Any deviations from the normal processing of credit balances will be sent to the relevant department immediately for further action. Anticipated completion date: December 2025

View Audit 384835

Finding 1171711 (2025-001)

Material Weakness 2025

Northwest Compass

IL

Subrecipient Monitoring Reporting Significant Deficiency

SECTION 5 – CORRECTIVE ACTION PLAN Finding 2025 – 001: Grant Administration Condition: During our current audit fieldwork, we noted that the Organization does not have adequate procedures in place for tracking and monitoring grant activities. Each grant has unique reporting and compliance requiremen...

SECTION 5 – CORRECTIVE ACTION PLAN Finding 2025 – 001: Grant Administration Condition: During our current audit fieldwork, we noted that the Organization does not have adequate procedures in place for tracking and monitoring grant activities. Each grant has unique reporting and compliance requirements, which is handled inconsistently among the Organization’s departments. Plan: The Executive Director, along with staff, will create better policies and procedures around the tracking and monitoring of grant funding throughout the year. Anticipated Date of Completion: Fiscal Year 2026 Name of Contact Person: Sonia Ivanov, Executive Director Management Response: Northwest Compass Inc is currently in the process of formally putting inn writing the policies and procedures we are currently following in this regard. We anticipate having this completed in the current fiscal year.

View Audit 384740

Finding 1171710 (2025-002)

Material Weakness 2025

Vista Prairie at Garnette Gardens

MN

Special Tests & Provisions Procurement, Suspension & Debarment Cash Management

A transfer back of $23,000 for the excess surplus cash was made on 8/27/25. It was our first time taking out surplus cash and now have a better process in place to correct this going forward.

View Audit 384739

Finding 1171709 (2025-001)

Material Weakness 2025

Vista Prairie at Garnette Gardens

MN

Reporting Significant Deficiency Internal Control / Segregation of Duties

It is not cost effective to have an internal control system designed to provide for the preparation of the financial statements and accompanying notes. We requested that our auditors, Eide Bailly LLP, prepare the financial statements and the accompanying notes to the financial statements as a part o...

It is not cost effective to have an internal control system designed to provide for the preparation of the financial statements and accompanying notes. We requested that our auditors, Eide Bailly LLP, prepare the financial statements and the accompanying notes to the financial statements as a part of their annual audit. We have designated a member of management to review the drafted financial statements and accompanying notes.

View Audit 384739

Finding 1171578 (2025-019)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking Reporting Significant Deficiency § 200.303

Finding 2025-019 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: To address reporting finding...

Finding 2025-019 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: To address reporting findings, in FY 2025 BCHD developed a Grants Management Standard Operating Procedure manual that continues to be updated as processes are adjusted to ensure compliance with all grant awards. Additionally, BCHD fiscal has completed the following steps to address this finding: • Restructured the fiscal grants management team to strengthen internal controls around grants management, standardize processes and improve efficiency. • Conducted small group training within the newly formed teams around the specifics of job responsibilities and requirements. • Created an internal grants tracker in Smartsheet to include all grant award periods, reporting requirements and due dates. • Compliance team entered required data in SAM.gov for FFATA reporting. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Conduct separate workshops with division leaders, programs directors and the compliance team to review all grant awards and compliance requirements for each award in addition to reviewing process for close out of grant awards and annual reporting requirements. • Update the grants tracker to include both fiscal and program reporting requirements. BCHD will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. Per the GMO’s guidance, BCHD will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

View Audit 384683

Finding 1171560 (2025-017)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking Reporting Significant Deficiency § 200.303

Finding 2025-017 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-027 Auditee’s Corrective Action Plan: To address reporting fin...

Finding 2025-017 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-027 Auditee’s Corrective Action Plan: To address reporting findings, in FY 2025 BCHD developed a Grants Management Standard Operating Procedure manual that continues to be updated as processes are adjusted to ensure compliance with all grant awards. Additionally, BCHD fiscal has completed the following steps to address this finding: • Restructured the fiscal grants management team to strengthen internal controls around grants management, standardize processes and improve efficiency. • Conducted small group training within the newly formed teams around the specifics of job responsibilities and requirements. • Created an internal grants tracker in Smartsheet to include all grant award periods, reporting requirements and due dates. • Compliance team entered required data in SAM.gov for FFATA reporting. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Conduct separate workshops with division leaders, programs directors and the compliance team to review all grant awards and compliance requirements for each award in addition to reviewing process for close out of grant awards and annual reporting requirements. • Update the grants tracker to include both fiscal and program reporting requirements. BCHD will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. Per the GMO’s guidance, BCHD will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

View Audit 384683

Finding 1171505 (2025-012)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking Reporting Significant Deficiency § 200.303

Finding 2025-012 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOED will strengthen its fiscal reporting ...

Finding 2025-012 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOED will strengthen its fiscal reporting controls to ensure all required fiscal reports are submitted timely and in accordance with the grantor’s established timetable. This corrective action includes formal distribution of the grantor’s fiscal reporting schedule to responsible staff, implementation of internal calendar tracking for all fiscal reporting deadlines, and enhanced monitoring procedures to ensure deadlines are met and escalated when necessary. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: June 30, 2026

View Audit 384683

Finding 1171413 (2025-008)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking HUD Housing Programs Reporting § 200.303

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, t...

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, the Consolidated Planning Division has been conducting a widespread effort to ensure programmatic compliance with all City and Federal requirements. To date, it has prioritized: • Reducing the grant’s at-risk financial exposure from approximately $28M in FY23 to $1.03M in FY25. • Implemented moving all NPO operating contracts to the same Period of Performance (July 1 – June 30 of the grant year) to ensure timely expenditure of funds and reduce compliance burden on staff. • Implemented the use of a form agreement approval process for the Board of Estimates (BOE) which reduced the lag time for contract execution and subsequent reimbursement from over 12 months, to approximately 2 months once the executed grant agreement has been received from HUD and approved by the BOE. • Standardized required subrecipient activity reporting and requests for reimbursement in Neighborly (the City’s reporting system of record for the CDBG grant program) to a quarterly basis. • Required all supporting documentation be submitted and reviewed quarterly to eliminate the possibility of overpayment or reimbursement for ineligible activities. • Hired a Director of CDBG finance to improve fiduciary and compliance oversight of federal funds. • Ensured the HUD-required Cash-on-Hand report is entered into a new screen in HUD’s system of record - Integrated Disbursement and Information System (IDIS) - (reporting that was previously collected through Federal Financial Report (FFR)/Standard Form 425 (SF-425) on a timely basis. Corrective Action Plan: • A new Director of CDBG Finance will be hired before the end of FY26. • The new Director of CDBG Finance will be provided training to complete the Cash on Hand Report and will cross-train additional staff on the completion of this report to ensure redundancy. • Supporting documents will be kept on the divisional shared drive in a clearly named subfolder. Contact Person: Mary Correia, Deputy Commissioner David Fielder, Assistant Commissioner Completion Date: June 30, 2026

View Audit 384683

Finding 1171385 (2025-002)

Material Weakness 2025

Contra Costa Community College District

CA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Views of Responsible Officials and Corrective Action Plan The District has reviewed the current R2T4 procedures and taken corrective measures to strengthen internal controls over the Return of Title IV calculations to ensure that funds are returned in a timely manner. 1. Process Review: All Financia...

Views of Responsible Officials and Corrective Action Plan The District has reviewed the current R2T4 procedures and taken corrective measures to strengthen internal controls over the Return of Title IV calculations to ensure that funds are returned in a timely manner. 1. Process Review: All Financial Aid staff involved in the R2T4 process have reviewed the Overpayments-R2T4 Policy and Procedure to ensure a full understanding of each step and to continue to comply with federal timelines and documentation requirements. 2. Monitoring and Accountability: The Financial Aid Office will conduct a review of the return of Title IV calculations and ensure that the funds are returned to the ED within 45 days after the institution determines that the student withdrew. 3. Ongoing Evaluation: The Overpayments-R2T4 Policy and Procedure will be reviewed periodically by the Districtwide Financial Aid Directors Workgroup to ensure continued compliance and effectiveness of internal controls.

View Audit 384667

Finding 1171369 (2025-003)

Material Weakness 2025

Sheltercare

OR

Allowable Costs / Cost Principles Period of Performance Significant Deficiency

--Corrective Action Plan: Management has prepared a written procedure for the process used to bill payroll and related costs to the federal award programs. This process will be followed in the future to ensure this same mistake is not made. Once it was brought to management’s attention, they adjuste...

--Corrective Action Plan: Management has prepared a written procedure for the process used to bill payroll and related costs to the federal award programs. This process will be followed in the future to ensure this same mistake is not made. Once it was brought to management’s attention, they adjusted their process to get back “on track”, such that the correct two-week period is being billed each time and none are being repeated. Further, management will implement a more robust review of this process in case similar errors still exist. --Person Responsible: Phoebe Benjamin, Associate Finance Director --Date Implemented: 1/1/2026

View Audit 384658

Finding 1171367 (2025-002)

Material Weakness 2025

Sheltercare

OR

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

--Corrective Action Plan: As part of the significant turnover within the accounting department in FY24-25, the individual preparing the current year SEFA this year had no previous experience with doing so. Management will take better care to prepare it next year so that it does not require adjustmen...

--Corrective Action Plan: As part of the significant turnover within the accounting department in FY24-25, the individual preparing the current year SEFA this year had no previous experience with doing so. Management will take better care to prepare it next year so that it does not require adjustment, and has prepared a written procedure to follow for preparation of the SEFA. --Person Responsible: Phoebe Benjamin, Associate Finance Director --Date Implemented: 1/1/2026

View Audit 384658

Finding 1171345 (2025-002)

Material Weakness 2025

East Valley Institute of Technology School District No. 401

AZ

Student Financial Aid Special Tests & Provisions Significant Deficiency

2025-002: SPECIAL TESTS AND PROVISIONS – GRAMM-LEACH-BLILEY ACT Program: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Cluster Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, and 84.268 Fe...

2025-002: SPECIAL TESTS AND PROVISIONS – GRAMM-LEACH-BLILEY ACT Program: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Cluster Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Questioned Costs: N/A Repeat Finding: No Condition/Context: During our review of the District’s information security policies and procedures, it was noted that the District did not have formally written information security policies and procedures. The District did not have a process to evaluate and maintain a data inventory, ensuring sensitive data is at a higher risk profile and prioritized for security protocols. The District did not limit administrative privileges to dedicated administrator accounts; instead system administrators utilized their administrative accounts for all their job function, rather than just the functions requiring higher levels of access. Criteria: Title IV-eligible institutions are subject to the Gramm-Leach-Bliley Act (the ‘‘Act’’). The Act requires financial institutions to explain their information sharing practices to their customers and to safeguard sensitive data. The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ‘‘financial institutions’’ and subject to the Act because they appear to be significantly engaged in wiring funds to consumers. Institutions agree to comply with the Act in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs. Institutions are required to develop, implement and maintain a written comprehensive information security program. Corrective Action: The District will implement policies and procedures over information technology to properly comply with the provision of the Gramm-Leach-Bliley Act. The District will prepare a security policy that addresses data classifications that ensure sensitive data is protected. In addition, administrator accounts will be restricted. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Edith Perez, Chief Financial Officer

View Audit 384637

Finding 1171342 (2025-001)

Material Weakness 2025

East Valley Institute of Technology School District No. 401

AZ

Student Financial Aid Reporting Significant Deficiency

2025-001: REPORTING Program: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Cluster Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education T...

2025-001: REPORTING Program: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Cluster Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: L. Reporting Questioned Costs: N/A Repeat Finding: No Condition/Context: Total tuition and fees as reported in the FISAP report was $3,228,909 while the District’s underlying accounting records showed $2,883,823, for a difference of $345,086. Total Federal Pell grant expenditures were reported as $362,929 on the FISAP report while the underlying accounting records and schedule of expenditures of federal awards showed $408,614, for a difference of $45,685. Criteria: The Student Financial Assistance cluster requires that the District submit the Fiscal Operations Report and Application to Participate (FISAP) annually. The amount should agree to the underlying accounting records. Corrective Action: The District will implement procedures to ensure the FISAP revenues and expenditures as posted within the general ledger match with the corresponding application. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Edith Perez, Chief Financial Officer

View Audit 384637

Finding 1171321 (2025-001)

Material Weakness 2025

Craven County

NC

Eligibility Internal Control / Segregation of Duties Cash Management

Board of Commissioners Administration Building Jason R. Jones, Chairman 406 Craven Street Dennis Bucher, Vice Chairman New Bern, NC 28560 Thomas F. Mark George S. Liner Fax 252-637-0526 Theron L. McCabe jveit@cravencountync.gov Ettienne “E.T.” Mitchell Beatrice R. Smith Administrative Staff Jack B. ...

Board of Commissioners Administration Building Jason R. Jones, Chairman 406 Craven Street Dennis Bucher, Vice Chairman New Bern, NC 28560 Thomas F. Mark George S. Liner Fax 252-637-0526 Theron L. McCabe jveit@cravencountync.gov Ettienne “E.T.” Mitchell Beatrice R. Smith Administrative Staff Jack B. Veit III, County Manager Commissioners 252-636-6601 Gene Hodges, Assistant County Manager Manager 252-636-6600 Nan Holton, Clerk to the Board Finance 252-636-6603 Amber M. Parker, Human Resources Director Human Resources 252-636-6602 Craig Warren, Finance Director None Reported. Finding 2025-001 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed completion date: April Rollins, Medicaid Program Manager Policy refresher training will be held by December 31, 2025. Refresher training for staff that files should be reviewed internally to ensure proper documentation is in place for eligibility determination. Workers will receive refresher training what files should contain and the importance of complete and accurate record keeping. Staff will have refresher training that all files include online verifications; documented resources of income and those amounts agree to information in NC FAST. The results found or documentation made in case notes should clearly indicate what actions were performed and the results of those actions. Second party reviews of at least or in excess of the state’s mandated 98 cases will be conducted quarterly. The second party review threshold for staff is 90%. Any errors will be discussed one on one by the supervisor with the employee to ensure the employee has a full understanding of policies and procedures. Supervisors will review error trends every quarter to determine if further group training is needed. The Learning Gateway trainings have also been completed in the past 180 days for all Medicaid staff will further assist with retaining staff. 12/31/2025 Corrective Action Plan For the Year Ended June 30, 2025 Section II - Financial Statement Findings Section III - Federal Award Findings and Questioned Costs 188

View Audit 384595

Finding 1171162 (2025-003)

Material Weakness 2025

Arizona Christian University

AZ

Student Financial Aid Eligibility Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure the Stafford loans are awarded within the annual and aggregate limits. Explanation of disagreement with audit finding: T...

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their awarding procedures and implement procedures to ensure the Stafford loans are awarded within the annual and aggregate limits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the time the Subsidized Direct Loan was initially awarded, the student was classified as grade level one and was correctly awarded $3,500. Subsequently, the student’s grade level increased; however, the Direct Loan award was not adjusted accordingly. The Office of Financial Aid relies on email notifications to identify students with grade-level changes, and the notification for this student was inadvertently missed. In response to this error, the Office of Financial Aid implemented additional monitoring controls. A report was developed to identify all students with changes in grade level and is now generated and provided weekly by the Office of the Registrar to the Office of Financial Aid. A designated Financial Aid Advisor has been assigned responsibility for reviewing this report and adjusting Direct Loan awards as necessary to ensure accuracy. As an additional preventative measure, the Director of Financial Aid will verify student grade level and corresponding Direct Loan eligibility prior to disbursement. The Office of Financial Aid will also conduct periodic reviews to confirm that Direct Loan awards consistently and accurately align with students’ grade levels.

View Audit 384567

Finding 1171157 (2025-002)

Material Weakness 2025

Arizona Christian University

AZ

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding:...

Student Financial Aid Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The withdrawal dates applied in the Return to Title IV (R2T4) calculations were based on the dates students were administratively withdrawn by the Office of the Registrar. Upon identification of the audit finding, the Office of Financial Aid conducted a comprehensive review of the affected R2T4 calculations and made the necessary corrections. Any balances resulting from these errors were subsequently written off. Additionally, the Director of Financial Aid completed a full file review for the applicable award year to assess the accurate inclusion of scheduled break days. During this review, two additional students were identified whose R2T4 calculations did not include the appropriate number of break days. The calculations for these students were corrected, and the resulting balances were written off. No further errors were identified. As part of the corrective action, the Office of Financial Aid has hired an additional Financial Aid Advisor dedicated to the review and completion of R2T4 calculations. Furthermore, the Director of Financial Aid has implemented a secondary review process for all completed R2T4 calculations to ensure accuracy and compliance. The Office of Financial Aid has also reviewed the Financial Aid Handbook and applicable Code of Federal Regulations (CFR) related to R2T4 calculations to reinforce adherence to regulatory requirements. Name(s) of the contact person(s) responsible for corrective action: Angel Faast and Laura Silva Planned completion date for corrective action plan: 12/17/2025

View Audit 384567

Corrective Action Plans

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