Corrective Action Plans

Finding 524786 (2024-001)

Significant Deficiency 2024

PA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Villanova University agrees with this finding. During the year, there was turnover at the University, and we acknowledge the training of new staff must be a priority to ensure continuity of key controls. Appropriate training and new internal control processes that would have detected this error hav...

Villanova University agrees with this finding. During the year, there was turnover at the University, and we acknowledge the training of new staff must be a priority to ensure continuity of key controls. Appropriate training and new internal control processes that would have detected this error have been implemented. The department has created a submission file consisting of new graduates only to be transmitted to the National Student Clearinghouse at the end of May and another at the end of June to identify any additional students to report. In addition, the University has created a Graduation Audit Report to be used internally to verify the change in status for students who graduated, and a final validation check performed by the Senior Assistant Registrar for Student History to confirm accuracy of student status. Name of contact person: Susan Morgan, Director of Technical Student Systems, Registrars Office Anticipated Completion date: May 2025 in conjunction with the next submission of graduation files

View Audit 344168

Finding 524785 (2024-003)

Significant Deficiency 2024

Bethel University and Affiliates

MN

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no dis...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On October 26, 2024, three modifications were made to the reporting tool the financial aid office uses for Return of Title IV Funds calculations to draw attention to situations when the “student completed more than 49% of a course” exception applies. First, we added a formula to the "5 - Title IV Checklist Revised" sheet in cell D16:F17. If the answer to question 11 "Exemption 3b: Successfully complete >49%?" is Yes, the following narrative will appear in blue, bold, font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Second, we modified a formula in cell J34 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, red font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Third, we added a formula to cell E36 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, blue font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." In addition, we completed additional training with the financial aid staff who complete R2T4 calculations to ensure they (a) understand rules related to the “student completed more than 49% of a course” exception, and (b) are aware of the additional warning messages that will appear in our R2T4 calculation spreadsheet. Name of the contact person responsible for corrective action: Jeffrey D Olson, Interim Director of Financial Aid Planned completion date for corrective action plan: October 26, 2024.

View Audit 344164 Questioned Costs: $1

Finding 524761 (2024-004)

Significant Deficiency 2024

Resources for Human Development, INC

PA

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties § 200.302

Management will review the SFDS protocols and processes with the appropriate staff in order enable the consistent application of sliding fees. This will be completed by June 30, 2025.

View Audit 344160

Finding 524720 (2024-003)

Significant Deficiency 2024

Detroit Housing Commission

MI

Questioned Costs HUD Housing Programs Significant Deficiency

Condition: The Commission did not complete fiscal year 2024 recertifications. Planned Corrective Action: Annual Delinquent Recertifications are being addressed according to HUD policy. Rent Calc training has been provided and passed by all staff. We certify and maintain it will be our standard opera...

Condition: The Commission did not complete fiscal year 2024 recertifications. Planned Corrective Action: Annual Delinquent Recertifications are being addressed according to HUD policy. Rent Calc training has been provided and passed by all staff. We certify and maintain it will be our standard operating procedure to ensure compliance with HUD policies. We will continue to mitigate PIC errors and ensure continued staff training to reduce these errors. HCV Manager, will randomly review 10% of files for accuracy. A list will be maintained. As of February 17, 2025, HUD’s Recertification score was 99.7% in compliance. Contact person responsible for corrective action: Felicia Burris, HCV Program Director Anticipated Completion Date: 6/30/2025

View Audit 344146 Questioned Costs: $1

Finding 524717 (2024-002)

Significant Deficiency 2024

Detroit Housing Commission

MI

HUD Housing Programs Subrecipient Monitoring Significant Deficiency

Condition: The Commission was not able to provide support the the units that had HQS deficiencies were corrected timely and the Commission did not abate the Housing Assistance Payments (HAP) for units that failed HQS Inspections. Planned Corrective Action: Contractor has been selected, and trained i...

Condition: The Commission was not able to provide support the the units that had HQS deficiencies were corrected timely and the Commission did not abate the Housing Assistance Payments (HAP) for units that failed HQS Inspections. Planned Corrective Action: Contractor has been selected, and trained in Yardi Systems. The Landlord liaison Supervisor will work closely with the new contractor to ensure abatements are conducted timely and in compliance with Program regulatory requirements. The Landlord liaison Supervisor along with Yardi monitoring will conduct 10% Quality Control reviews to ensure contractor is following HUD compliance guidelines as it pertains to abatement activity. Contact person responsible for corrective action: Felicia Burris, HCV Program Director Anticipated Completion Date: 6/30/2025

View Audit 344146

Finding 524706 (2024-002)

Significant Deficiency 2024

Housing and Redevelopment Authority of Austin

MN

Questioned Costs Cash Management Internal Control / Segregation of Duties

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Complia...

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Recommendation: We recommend that the HRA continue to evaluate their procedures and controls in place over the draw down of funds. Management’s Response: Management agrees with the finding and will continue to monitor the draws to ensure they are spent within the required timeframe. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will ensure that all draws of funds are spent within the required timeframe. Official Responsible for Ensuring CAP: Angela Maiden, Finance Director, is the official responsible for ensuring corrective action of the deficiency. Planned Completion Date for CAP: September 30, 2025 Plan to Monitor Completion of CAP: Taggert Medgaarden, Executive Director, will ensure that the draw downs are properly managed through discussions with the Finance Director.

View Audit 344136 Questioned Costs: $1

Finding 524679 (2024-004)

Significant Deficiency 2024

La Salle University

PA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster-Assistance Listing No. 84.0007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Explanati...

Student Financial Assistance Cluster-Assistance Listing No. 84.0007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 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 will identify outstanding not cashed checks for each term. A term is normally 4 months in total as each semester generates a list of uncashed checks. Within two weeks of establishing outstanding checks, we will send letters to students informing them that they have outstanding refund checks. For approximately six months, the process of reviewing the outstanding list repeats, and if a check has not been cashed, another letter of notice is mailed. After six months, finance will send the outstanding list to Student Financial Services for a 30-day final review/outreach. At 21 O days from original refund issuance, Finance will provide the list to Financial Aid who will return balances to DOE. Name(s) of the contact person(s) responsible for corrective action: Zak Thornton, Assistant Vice President of Finance Planned completion date for corrective action plan: Corrected as of Spring 2025.

View Audit 344109 Questioned Costs: $1

Finding 524678 (2024-003)

Significant Deficiency 2024

La Salle University

PA

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

Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action tak...

Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have contracted with RPK, a leading higher educating consulting firm who has been assisting us with examining our systems, practices, policies, and procedures. We have reorganized the student accounts receivable functions into a seamless student financial service and created a student financial operations backend where all database maintenance, automation, processing, and audits are being coordinated by a team separate from those servicing students directly. We have replaced all ineffective staff members including those who oversaw the record keeping process based on the support and recommendations of RPK, and are completing audits of all files, current and past, in a manual review of all cabinets to correctly alphabetize and organize. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President, Student Financial Services Planned completion date for corrective action plan: Summer 2025

View Audit 344109

Finding 524677 (2024-002)

Significant Deficiency 2024

La Salle University

PA

Reporting Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordan...

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding : Like many US institutions, La Salle contractually relies on the National Student Clearinghouse (NSC) to conduct its enrollment reporting to NSLDS. In order to comply with established regulations, we set up an Enrollment Reporting Submission Schedule with the NSC. La Salle's schedule for 2025 is below: Term Begin Date Term End Date Transmission Type : Schedule Transmission Date Received Date Transmission Status 1/ 13/ 2025 5/ 9/ 2025 F rst of Term 1/ 31/ 2025 1/ 31 /2 25 Edtts Comp eted 1/13/ 2025 5/9/2025 Subsequent of - erm 2/ 17/ 2025 Not Yet Rece ed 1/ 13/ 2025 5/ 9/ 2025 Subsequent of Term 3/ 17/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5/ 9/ 2 25 Subsequent of-erm t./ 15/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5_/9/ 2025 Subsequent of -e,m 5/ 20/ 2025 Not Yet Rece v ed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er F,r;.: 6/ 3/ 2025 Not Yet Rece ved 5/ 19/ 2025 8/ 22/2025 Summer Subsequent 7/ 9/ 2025 Not Yet Recewed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er Subsequent 8/ 13/ 2025 Not Yet Recev ed 8/ 25/ 2025 12/ 13/2025 F rst of Terr, 9/ 23/ 2025 Not Yet Rece'ved 8/ 25/ 2025 12/13/ 2025 Subsequent of Term 10/ 28/ 2025 Not Yet ReceiVed 8/ 25 / 2025 12/ 13/ 2::>25 Subsequent of-erm 11/ 15/ 2025 Not Yet Rece·ved 8/ 25/ 2025 12/ 13/ 2025 Subsequent of-erM 12/16/ 2025 Not vet Receved Adherence to this reporting schedule would ensure timely reporting, as the NSC subsequently transmits data monthly to NSLDS, throughout the academic year, well within the requirement to report student enrollment status at least every 60 days. Our Associate Registrar for Academic Information Systems is specifically charged with maintaining, executing, and adhering to this schedule, as part of the routine duties assigned to that position in our office. Regarding accuracy, data structures are defined in our BANNER database to classify a given student's enrollment status in a given semester as full, three-quarter, half, or less-than-half time, and withdrawn. Those structures are long-established by student level (graduate, undergrad, doctoral), and do not change from semester to semester. BANNER processes extract the registration data and its timing, in light of those definitions and the data is formatted for transmission to the NSC as prescribed. Sound data entry practices have been established to make certain dates associated with those statuses, and the transition of a student within them, are accurately recorded. Consequently, we rely on the BANNER NSC extract, and the NSC's reporting relationship with NSLDS to accurately transmit that data accordingly. The NSC does work with us to rectify or resolve any seemingly inconsistent or incorrect data, based on prior transmissions and current regulations, prior to committing the given enrollment extract to the NSC database for our institution. They help us stay in compliance and consistent on both the campus-level and program-level basis upon which we're required to report. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Fall 2024

View Audit 344109

Finding 524672 (2024-001)

Significant Deficiency 2024

La Salle University

PA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University 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 return...

Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University 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 order to ensure that there is not an instance where a student does not receive their credit balance within the required 14-day window, the disbursement scheduled has been re-configured to ensure that there are no automatic disbursements running overnight the week leading up to a university and/or federal holiday. A new financial operations team has been created within the student financial services structure to ensure that processes are running smoothly and that systems between both financial aid and the finance office are effectively communicating with each other. 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 Fall 2024.

View Audit 344109

Finding 524671 (2024-001)

Significant Deficiency 2024

Selma Housing Authority

NC

Eligibility HUD Housing Programs Reporting

Finding 2024-001 Name of Contact Person: Melody Wilkins Executive Director Corrective Action: We will implement proper internal control procedures for the Public and Indian Housing program eligibility requirements. Proposed Completion Date: Immediately

View Audit 344104

Finding 524649 (2024-007)

Significant Deficiency 2024

Eureka College

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a significant deficiency in internal control over compliance relating to the Special Tests and Provisions compliance requirement. Management Response: Management agrees with the finding Corrective Action Plan: JFA deletes prior reconciliation reports. Separate file location on the cloud has been created to hold these monthly reconciliation files. Corresponding reconciliation within Sonis (see above corrective action plan for excess cash) will also occur. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088

Finding 524647 (2024-006)

Significant Deficiency 2024

Eureka College

IL

Questioned Costs Student Financial Aid Special Tests & Provisions

2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: JFA did not accurately include days of breaks for Spring Break. A manual R2T4 calculation is in place to catch errors in the days in a semester. Responsible Person: Tim Marten Implementation Date: 7/01/2024

View Audit 344088 Questioned Costs: $1

Finding 524638 (2024-002)

Significant Deficiency 2024

Eureka College

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2024-002 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-002 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not report actual loan disbursement dates to the COD system for 4 of 40 students in the sample (10%). We consider this condition to be a significant deficiency of internal control over compliance relating to the Special Tests and Provisions compliance and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: Implementation of a newer process based on the system and program defaults in Jenzabar Financial Aid. Will use posted dates in Sonis to ensure they match COD within the 3-day regulatory requirement. New reporting usages of SAS loan files will be checked in Sonis to ensure matching disbursement dates. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088

Finding 524605 (2024-001)

Significant Deficiency 2024

Local Area of the Workforce Development in the Northeast

PR

Matching / Level of Effort / Earmarking Subrecipient Monitoring Period of Performance

Our Agency has included activities as a joint force’s initiative with other agencies and entities in an outreach task. We have been authorized to use the distribution waiver of percentages to have a better or bigger span for our youth populations. We also signed a memorandum of understanding with at...

Our Agency has included activities as a joint force’s initiative with other agencies and entities in an outreach task. We have been authorized to use the distribution waiver of percentages to have a better or bigger span for our youth populations. We also signed a memorandum of understanding with attractive entities like the PR National Guard and have planned activities reaching youth from school programs to communities without school youths. Our alliances with DDEC, Azore and the Department of Education will contribute to an increase in youth program expenses. We have strategically created an initiative that targets in-school youths where we’ll provide workshops focused on elevating their skills and creating real-time experiences. The memorandum we have with the Department of Education has facilitated this strategy. The Individual Training account (ITA) program will also be promoted in our school district to identify candidates with barriers that can be served through our program. As part of our outreach strategy, we plan to visit foster homes alongside the Department of the Family, which we have signed a memorandum to target this group of disadvantaged youths, as well as projects we have signed with the vocational schools in our district providing real time and paid work experience. With the nine municipalities comprising our area will develop summer work experience targeting our in-and-out school youth (TSY, OSY) populations. The estimated expenses for these initiatives, based on last year's outcome, will reach the goal parameters of programs under WIOA Act. IMPLEMENTATION DATE June 2025 RESPONSIBLE PERSONS Budget Director, Executive Director, Directors of Programmatic and Operations

View Audit 344044

Finding 524579 (2024-002)

Significant Deficiency 2024

Saint Mary's University of Minnesota

MN

Student Financial Aid Reporting Significant Deficiency

Student Status Changes Condition The change in student status for 8 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. Correc...

Student Status Changes Condition The change in student status for 8 of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. However, the students were ultimately reported to the NSLDS. Corrective Action Plan: The institution launched the Jenzabar student information system in July 2023. As part of this transition, institution discontinued our branch with the National Student Clearinghouse (NSC). This closure led to recurring reporting errors each month as the NSC worked to correct the branch closure data. Currently, one person is responsible for submitting the university's monthly enrollment and degree verification reports. There has been a significant learning curve as the instruction worked to address NSC errors, Jenzabar implementation errors, Jenzabar processes, and our own SMU practices. The learning was complemented by the work to file the FVT/GE reporting in fall 2024. Starting January 1, 2025, the institution has updated processes to minimize the need for secondary reviews of reported graduations at NSC. The institution implemented a tracking system to identify situations that consistently lead to errors in the graduation reporting process. The financial aid department has been provided access to NSC to review and address errors needing to be fixed directly in NSLDS. The financial aid department will audit reports of graduates in NSLDS against those submitted through NSC. The financial aid team will partner with registrar on corrections and evaluate if access to NSLDS for members of the registrar team would also make sense.

View Audit 344025

Finding 524566 (2024-002)

Significant Deficiency 2024

City of Walnut

CA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

2024-002 Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Financial Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency i...

2024-002 Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Financial Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Award Year: 2021 Grant Award Number: N/A Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Views of Responsible Officials: A memorandum was sent to all department heads (responsible for purchasing and contracts) in January 2025 reinforcing their duty to confirm contractors and vendors suspension/debarment status with respect to federal awards. The Finance Department plans to prepare a list of contractors currently engaged in federally funded projects and verify their good standing using the online database. Going forward, contractors/vendors will be required to submit a signed Suspension & Debarment Certification prior to the award of any new agreement. Name of Responsible Person: Alexander Merkel Medina, Director of Finance Implementation Date: January 15, 2025

View Audit 344006

Finding 524548 (2024-005)

Significant Deficiency 2024

Gibraltar Area School District

WI

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Significant Deficiency § 200.214

Suspension and Debarment Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) Procedures will be updated to include documentation of verification that a vendor has not been suspended or debarred. A record of this verification will be retained. Responsible official: Mark ...

Suspension and Debarment Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) Procedures will be updated to include documentation of verification that a vendor has not been suspended or debarred. A record of this verification will be retained. Responsible official: Mark Lindem, Business Manager, mark.lindem@gibraltar.k12.wi.us Anticipated Completion Date: June 30, 2025

View Audit 343957

Finding 524537 (2024-002)

Significant Deficiency 2024

Landmark College, INC

VT

Subrecipient Monitoring Significant Deficiency

The College continues to document the policies and procedures and implement any outstanding requirements to become fully compliant with GLBA. Where necessary the College will reach out to third parties for assistance. Anticipated completion during late FY 2025 to mid FY 2026.

View Audit 343940

Finding 524536 (2024-001)

Significant Deficiency 2024

Phoenix Union High School District No. 210

AZ

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Significant Deficiency § 200.303

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Adrian De Alba, Execu􀆟ve Director of Finance Anticipated Completion Date: February 20, 2025 Planned Corrective Action: Finding: A purchase order (PO) was iss...

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Adrian De Alba, Execu􀆟ve Director of Finance Anticipated Completion Date: February 20, 2025 Planned Corrective Action: Finding: A purchase order (PO) was issued without proper authorization. Action planned in response to finding: The District concurs with the finding, recognizing that the expenditure was allowable, and that the approval process was not in place for this expenditure. The District has removed access to the quick approval option for the end‐user to ensure bypassing does not occur. The District will continue to provide training ensuring end users follow proper procedures. Internal controls will be evaluated to ensure proper approval systems are in place to prevent this from recurring.

View Audit 343938

Finding 524524 (2024-004)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Student Financial Aid Reporting Significant Deficiency

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the 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: • Fully implement and utilize existing reporting functionality in Jenzabar for National Student Clearinghouse • Review existing reporting procedures and process configurations for NSC reporting in Jenzabar to ensure that things are working correctly and being reported in a timely manner • Document the full process internally in the Registration and Records department Name(s) of the contact person(s) responsible for corrective action: Chris Cook, Registrar Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524519 (2024-003)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is reviewing the updated GLBA requirements and updating the WISP to ensure it includes all of the required elements. Name(s) of the contact person(s) responsible for corrective action: Justin Sin, IT Director Planned completion date for corrective action plan: May 31, 2025

View Audit 343891

Finding 524514 (2024-002)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support the loan such as repayment history, documentation showing the original payment was accepted by the student, etc. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Subsequent to the audit testing, all Perkins loan MPNs were located and the College is finalizing its assignment of the loans to the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO and Grant Drinnen, Cash and Accounts Receivable Specialist Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524509 (2024-001)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with a...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed and updated its procedures related to the process of reviewing and remitting unclaimed student refund checks. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO Planned completion date for corrective action plan: January 31, 2025

View Audit 343891 Questioned Costs: $1

Finding 524499 (2024-002)

Significant Deficiency 2024

Franklin Community School Corporation

IN

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency § 200.303

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant...

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The School Corporation had designed a system of internal controls to ensure payroll expenditures charged to the grant fund were allowable. However, 2 of the 44 expenditures tested did not show have documentation that the control had been applied and operated effectively. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements and apply the controls consistently to all transactions. Contact Person Responsible for Corrective Action: Kerri Powers-Hoffman, Payroll Specialist Contact Phone Number and Email Address: hoffmank@franklinschools.org, 317-346-8738 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Specialist will ensure the files posted to the shared drive for the monthly board meetings contain all payroll claims necessary for approval each month. The Payroll Specialist also will review the prior months file to ensure no payroll claims were skipped, which is what resulted in this finding. Anticipated Completion Date: This corrective action has already been implemented.

View Audit 343871

Corrective Action Plans

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