Corrective Action Plans

Finding 1160882 (2024-006)

Material Weakness 2024

Martin University

IN

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring § 200.303

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid in...

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Auditors’ Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. The new systems are Jenzebar products and are fully compliant. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

View Audit 370945

Finding 1160878 (2024-005)

Material Weakness 2024

Martin University

IN

Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Students tested in the Common Origination and Disbursement (COD) reporting were not properly reported based upon University documents, including disbursement dates a...

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Students tested in the Common Origination and Disbursement (COD) reporting were not properly reported based upon University documents, including disbursement dates and applied dates. Auditors’ Recommendation: We recommend that the University strengthen its internal controls to ensure that all disbursement dates are reported to COD accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The previous SIS was subject to frequent interruptions which prevent timely data exchange with COD. Beginning with the 2024-2025 award year a new financial aid processing system was implemented. The new processing system is a more secure environment and hosted by Jenzabar for added compliance assurance. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

View Audit 370945

Finding 1160874 (2024-004)

Material Weakness 2024

Martin University

IN

Questioned Costs Student Financial Aid Significant Deficiency § 200.303

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Student checks related to student refunds of Title IV federal financial aid was outstanding more than 240 days as of June 30, 2024. Auditors’ Recommendation: We reco...

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Student checks related to student refunds of Title IV federal financial aid was outstanding more than 240 days as of June 30, 2024. Auditors’ Recommendation: We recommend that the University 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 University engaged an external consultant in June 2023, hired a new staff accountant in September 2023 and a CFO in November 2023. The University is implementing financial internal controls policies and processes to improve the financial statements preparation and preparation of the schedule of expenditures and federal awards and ensure compliance with the DOE. This includes procedures related to outstanding student refund checks over 240 days. Name(s) of the contact person(s) responsible for corrective action: Denise Johnson, Interim Controller, Bursar Dept. Supervisor Planned completion date for corrective action plan: June 30, 2025

View Audit 370945 Questioned Costs: $1

Finding 1160604 (2024-007)

Material Weakness 2024

Columbia Gorge Community College

OR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the College review its FSEOG awarding procedures and strengthen controls to ensure accurate identification and prioritization of eligible students based on EFC. Explanation of disagreement with audit fi...

Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the College review its FSEOG awarding procedures and strengthen controls to ensure accurate identification and prioritization of eligible students based on EFC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CGCC has reviewed its Federal Supplemental Educational Opportunity Grant (FSEOG) awarding policy and will continue to ensure that FSEOG funds are awarded in accordance with federal guidelines. The discrepancy between the 2023–2024 award year and the current year was due to inaccurate Student Aid Index (SAI) data generated by a previous report. For the current year, the Financial Aid Office has identified and implemented a more accurate reporting tool, which has significantly improved the reliability of the SAI data used in awarding decisions. To further strengthen our internal controls and oversight, a new Financial Aid Director will be joining our team in June 2025. This leadership addition will enhance our ability to maintain compliance and ensure accurate, consistent awarding of FSEOG funds moving forward.. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister Planned completion date for corrective action plan: 6/30/2025

View Audit 370896

Finding 1160603 (2024-006)

Material Weakness 2024

Columbia Gorge Community College

OR

Questioned Costs Procurement, Suspension & Debarment Student Financial Aid § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College strengthen its internal controls to ensure timely identification of students not meeting SAP standards. Additionally, the College should work with its system administ...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College strengthen its internal controls to ensure timely identification of students not meeting SAP standards. Additionally, the College should work with its system administrator to resolve the SAP calculation issue or implement an alternative method for tracking SAP compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CGCC has completed a thorough review of its Satisfactory Academic Progress (SAP) policy to ensure alignment with the capabilities and limitations of our current system. We remain committed to resolving ongoing system-related issues and are actively keeping the policy and system functionality in sync as improvements are made. The issue regarding SAP not calculating correctly is still in progress. We have been working closely with Anthology to identify and implement long-term solutions. Unfortunately, the necessary fixes require significant time and manual intervention. Despite these challenges, we have made progress: as of Spring 2025, we are now able to accurately identify affected students—something that was not possible during the 2023–2024 award year. Additionally, we are in the process of hiring a Financial Aid Director. This added leadership and support will help us address the remaining issues more efficiently and continue making meaningful progress toward full resolution Name(s) of the contact person(s) responsible for corrective action: Denise Reid-Strachan Planned completion date for corrective action plan: 9/1/2025

View Audit 370896 Questioned Costs: $1

Finding 1160599 (2024-005)

Material Weakness 2024

Columbia Gorge Community College

OR

Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College review its current procedures for Title IV funds and implement a control that prevents and detects errors in this process. Additionally, we recommend the College impl...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College review its current procedures for Title IV funds and implement a control that prevents and detects errors in this process. Additionally, we recommend the College implement a formal review process to ensure the R2T4 calculations being prepared timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CGCC is currently undertaking a comprehensive review of its Return to Title IV (R2T4) process. In light of recent staff departures, we are reassessing the applicable regulations and developing a formalized workflow, including clear documentation of our internal controls to support consistent and compliant implementation. Name(s) of the contact person(s) responsible for corrective action: Denise Reid-Strachan Planned completion date for corrective action plan: 9/1/2025

View Audit 370896

Finding 1160595 (2024-004)

Material Weakness 2024

Columbia Gorge Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure direct loan, Pell, FSEOG, and FWS reconciliations are reviewed and such review properly documented. Explanation of disagreement with au...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure direct loan, Pell, FSEOG, and FWS reconciliations are reviewed and such review properly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed its policies and procedures and the reconciliation process conducted by Global, its third-party servicer, and has implemented a procedure whereby the Financial Aid Office retrieves the prior month’s completed reconciliation at the beginning of each month. Those records will be reconciled with the finance system records within the SIS in coordination with the Business Office. The College will review the data and make any necessary updates to student records to ensure a complete end-to-end reconciliation between G5/COD, Global, and the College. Name(s) of the contact person(s) responsible for corrective action: Sam Draper & Denise Reid-Strachan Planned completion date for corrective action plan: 6/30/2026

View Audit 370896

Finding 1160591 (2024-003)

Material Weakness 2024

Columbia Gorge Community College

OR

Internal Control / Segregation of Duties Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: We recommend the College review the requirements and implement a control to specifically monitor the outstanding Title IV funded checks and the refunds of disbursements to students throughout the yea...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007 Recommendation: We recommend the College review the requirements and implement a control to specifically monitor the outstanding Title IV funded checks and the refunds of disbursements to students throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has reviewed its policies and procedures in relation to the audit finding and has implemented adjustments to its posting process to ensure more accurate recording of transaction dates that initiate the Title IV credit balance process. In addition, targeted training and coaching have been provided to responsible personnel to reinforce compliance and improve the timeliness of student refunds in accordance with statutory timeframes. Emphasis has been placed on the communication and coordination between the Financial Aid and Business office to ensure that batches are posted in a timely fashion in accordance with the disbursement dates on COD. Additionally, for instances of uncashed refund checks resulting from Title IV credit balances, the Business Office will collaborate with Financial Aid to ensure the return of funds to the appropriate federal programs within 240 days of the date of issuance. Name(s) of the contact person(s) responsible for corrective action: Sam Draper & Denise Reid-Strachan Planned completion date for corrective action plan: 6/30/2026

View Audit 370896

Finding 1160588 (2024-002)

Material Weakness 2024

Columbia Gorge Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College review current processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate as well as...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Recommendation: We recommend the College review current processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate as well as retaining evidence of this control being performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Enrollment reporting is the responsibility of the Columbia Gorge Community College (CGCC) Registrar. The reporting of enrollment information in a timely manner for the year ended June 30, 2024, was impacted by the implementation of a new Student Information System (SIS) in May 2021. The SIS included significant changes to student recording procedures and a new enrollment reporting process. In response to the Enrollment Reporting Finding for the year ended June 30, 2024, the Registrar continues to work on mitigating any issues that negatively impact enrollment reporting. Our reporting have significantly improved during the 2024-2025 academic year. Name(s) of the contact person(s) responsible for corrective action: Catherine Graham Planned completion date for corrective action plan: 9/30/2025

View Audit 370896

Finding 1160259 (2024-003)

Material Weakness 2024

Franklin Home for the Aged D/b/a Peabody Place

NH

Student Financial Aid Subrecipient Monitoring Eligibility § 200.512

Condition Found: Per 2 CFR § 200.512(a), the auditee must submit the data collection form (DCF) and reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the auditee’s fiscal year. The aud...

Condition Found: Per 2 CFR § 200.512(a), the auditee must submit the data collection form (DCF) and reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the auditee’s fiscal year. The audit for the year ended December 31, 2023, was not submitted to the Federal Audit Clearinghouse until DATE, which is after the required submission deadline of September 30, 2024. Individual(s) Responsible for Corrective Action: Lynda P. Goldthwaite, Executive Director and Stacey Matott, Director of Finance Planned Corrective Action: With the debt work out in place, management should continue to follow procedures in place to ensure the timely completion of future audits and submission of the reporting package to the Federal Audit Clearinghouse. Anticipated Completion Date: September 30, 2025

View Audit 370637

Finding 1160258 (2024-002)

Material Weakness 2024

Franklin Home for the Aged D/b/a Peabody Place

NH

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

Condition Found: The Organization did not make the required annual deposits into the debt payment reserve, capital asset replacement reserve, resident asset depletion reserve, and the facility fill reserve. We confirmed the balances of the four reserve accounts and identified that all four reserve a...

Condition Found: The Organization did not make the required annual deposits into the debt payment reserve, capital asset replacement reserve, resident asset depletion reserve, and the facility fill reserve. We confirmed the balances of the four reserve accounts and identified that all four reserve accounts were not funded in accordance with the USDA loan agreement. Individual(s) Responsible for Corrective Action: Lynda P. Goldthwaite, Executive Director and Stacey Matott, Director of Finance Planned Corrective Action: Peabody Place sought a debt work out in 2025 that would allow for deferral of required deposits for six months until January 1, 2026. Anticipated Completion Date: Completed

View Audit 370637 Questioned Costs: $1

Finding 1159875 (2024-002)

Material Weakness 2024

County of York, Pennsylvania

PA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking

We concur with this finding. The County of York has hired a Human Services Director of Finance to assist with improving systems and financial processes within the Human Services (HS) divisions. The HS Executive Director and Director of Finance are recommending engaging an expert Consultant to assist...

We concur with this finding. The County of York has hired a Human Services Director of Finance to assist with improving systems and financial processes within the Human Services (HS) divisions. The HS Executive Director and Director of Finance are recommending engaging an expert Consultant to assist the County’s Children & Youth Fiscal team in getting caught up on internal system timelines, as well as delayed reporting. The Consulting company will also be working to adequately train the Children & Youth Fiscal team for development purposes.

View Audit 370417

Finding 1159874 (2024-001)

Material Weakness 2024

County of York, Pennsylvania

PA

Student Financial Aid Reporting Internal Control / Segregation of Duties

We concur with this finding. Children, Youth and Families will explore ways to better track the State Fiscal Year and County’s Calendar Year side-by-side. The Children & Youth Fiscal team will work with the Director of Finance to implement reconciliation processes and will prioritize timeliness of r...

We concur with this finding. Children, Youth and Families will explore ways to better track the State Fiscal Year and County’s Calendar Year side-by-side. The Children & Youth Fiscal team will work with the Director of Finance to implement reconciliation processes and will prioritize timeliness of reporting.

View Audit 370417

Finding 1158306 (2024-006)

Material Weakness 2024

Mount Sinai Health System, Inc.

NY

Student Financial Aid Allowable Costs / Cost Principles Reporting

Finding 2024-006 L. Reporting Information on the federal program: Grantor: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective actions: Management agrees with the finding that FISAP was not c...

Finding 2024-006 L. Reporting Information on the federal program: Grantor: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective actions: Management agrees with the finding that FISAP was not correctly populated. Management has since corrected the data and submitted a revised FISAP. Management notes there was turnover in the PSON’s Office of Student Financial Aid during the year and an employee was not properly trained on the FISAP preparation. Training has since been implemented and new employees in the department will be trained accordingly. Names of responsible official: Denis Donegan Vice President of Finance, Mount Sinai Health System Denis.donegan@mountsinai.org Projected completion date: The project is expected to complete by December 31, 2025.

View Audit 370128

Finding 1158301 (2024-005)

Material Weakness 2024

Mount Sinai Health System, Inc.

NY

Matching / Level of Effort / Earmarking Special Tests & Provisions Student Financial Aid

Finding 2024-005 N. Special Tests and Provisions - Disbursement to or on Behalf of Students Information on the federal program: Grantor: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective ac...

Finding 2024-005 N. Special Tests and Provisions - Disbursement to or on Behalf of Students Information on the federal program: Grantor: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective actions: Management agrees with the finding that certain credit refunds were not issued timely. PSON and ISMMS’ Offices of Student Financial will implement a control that ensures communication related to refunds is enhanced when a student withdraws. ISMMS has ensured compliance with the Department of Education’s 14-day credit balance requirement by contracting with Nelnet, an external financial management vendor, to administer the credit refund process, supported by ongoing monitoring and periodic internal reviews. The control will ensure that all credit refunds are issued timely. Names of responsible official: Denis Donegan Vice President of Finance, Mount Sinai Health System Denis.donegan@mountsinai.org LaVerne Walker Director of Student Financial Services, Icahn School of Medicine at Mount Sinai Laverne.walker@mssm.edu Projected completion date: The project is expected to complete by December 31, 2025.

View Audit 370128

Finding 1158296 (2024-004)

Material Weakness 2024

Mount Sinai Health System, Inc.

NY

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

Finding 2024-004 N. Special Tests and Provisions - Enrollment Reporting Information on the federal program: Grantor: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective actions: Management ag...

Finding 2024-004 N. Special Tests and Provisions - Enrollment Reporting Information on the federal program: Grantor: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective actions: Management agrees with the finding described above. PSON and ISSMS’ Offices of Student Financial will ensure that all NSLDS submissions are made timely and with the correct status of each student. The respective Offices are implementing enhanced monitoring, staff training, and periodic internal reviews to confirm compliance. Names of responsible official: Denis Donegan Vice President of Finance, Mount Sinai Health System Denis.donegan@mountsinai.org LaVerne Walker Director of Student Financial Services, Icahn School of Medicine at Mount Sinai Laverne.walker@mssm.edu Projected completion date: The project is expected to complete by December 31, 2025.

View Audit 370128

Finding 1158291 (2024-003)

Material Weakness 2024

Mount Sinai Health System, Inc.

NY

Matching / Level of Effort / Earmarking Special Tests & Provisions Student Financial Aid

Finding 2024-003 N. Special Tests and Provisions - Verification Information on the federal program: Grantor: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective actions: Management agrees wit...

Finding 2024-003 N. Special Tests and Provisions - Verification Information on the federal program: Grantor: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective actions: Management agrees with the finding described above. PSON’s Office of Student Financial Aid will implement a process that ensures all required documentation is retained. Employees of the Student Financial Aid Office will be trained and PSON will be in compliance with the requirements in the Federal Student Aid Handbook. Name of responsible official: Denis Donegan Vice President of Finance, Mount Sinai Health System Denis.donegan@mountsinai.org Projected completion date: The project is expected to complete by December 31, 2025.

View Audit 370128

Finding 1158248 (2024-002)

Material Weakness 2024

Providence St. Joseph Health

WA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Management acknowledges the findings related to Common Origination and Disbursement (COD) reporting as identified. These discrepancies were primarily due to limitations in our current review procedures. We are revising our internal policies and procedures to include detailed guidance on verifying an...

Management acknowledges the findings related to Common Origination and Disbursement (COD) reporting as identified. These discrepancies were primarily due to limitations in our current review procedures. We are revising our internal policies and procedures to include detailed guidance on verifying and documenting disbursement and enrollment dates, academic year parameters, and cost of attendance calculations prior to COD submission. This will include additional layers of review to ensure timely and accurate reporting. These policies and procedures will be implemented by December 31, 2025.

View Audit 370126

Finding 1158246 (2024-001)

Material Weakness 2024

Providence St. Joseph Health

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303

Management concurs with KPMG’s assessment that the risk assessment and monitoring control activities were not sufficiently designed to ensure adequate segregation of duties or to provide evidence of control operation. These gaps were primarily due to limited staffing and processes that have not evol...

Management concurs with KPMG’s assessment that the risk assessment and monitoring control activities were not sufficiently designed to ensure adequate segregation of duties or to provide evidence of control operation. These gaps were primarily due to limited staffing and processes that have not evolved to meet all compliance requirements. Management will implement new control policies and procedures that ensure proper segregation of duties and introduce review mechanisms at a sufficient level of precision to detect and prevent noncompliance. These policies and procedures will be implemented by December 31, 2025.

View Audit 370126

Finding 1158232 (2024-003)

Material Weakness 2024

New York College of Traditional Chinese Medicine

NY

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2025-003: Campus Crime Awareness Requirements Not Met Comments on Finding and Recommendation(s): Statement of Concurrence: We concur with the finding of 1. a burglary crime was reported in the Annual Security Report when it should have been reported as a motor vehicle theft. The issue was du...

Finding 2025-003: Campus Crime Awareness Requirements Not Met Comments on Finding and Recommendation(s): Statement of Concurrence: We concur with the finding of 1. a burglary crime was reported in the Annual Security Report when it should have been reported as a motor vehicle theft. The issue was due to error entry, neighboring lines. 2. motor vehicle theft and a weapons violation was not reported to the Department of Education. The issue was due to carelessness. These were correctly reported in the Annual Security Report. Usually, the Annual Security Report and report to the Department of Education is prepared and completed by the Student Services Coordinator and the Administrative Dean based on the statistic report from the school and the Police Department in August/September. Because the college was engaged in the self-study for accreditation, everyone was extremely busy at that time. Errors might occur when doing things in a hassle way. Actions Taken or Planned: 1. Corrections were made in the Annual Security Report and in the report to the Department of Education. Two corrections were made in the DOE website: Criminal Offenses - Public Property: For 2023, line J (motor vehicle theft) was changed from 0 to 1. Arrests - Public Property: For 2023, line a (weapon) was changed from 0 to 2 2. New Hire: The college is in the process of hiring a new Student Services Coordinator. This individual will work with the Administrative Dean for ensuring the accuracy and timelines of reporting moving forward. 3. A strengthen double-check system will be established to ensure the accuracy of all reporting. Completion Date: Ongoing 9/26/2025 Dong-Hua Yang MD, PhD Date Title: Administrative Dean Telephone: 516-739-1545 Email: administrative_dean@nyctcm.edu

View Audit 370123

Finding 1158231 (2024-002)

Material Weakness 2024

New York College of Traditional Chinese Medicine

NY

Questioned Costs Student Financial Aid Special Tests & Provisions

Finding 2025-002: Untimely Paid Credit Balance Comments on Finding and Recommendation: Statement of Concurrence: We concur with the finding of Untimely Paid Credit Balance The delay in issuing the credit balance was due to a timing oversight related to the award year dates. Although the Credit Balan...

Finding 2025-002: Untimely Paid Credit Balance Comments on Finding and Recommendation: Statement of Concurrence: We concur with the finding of Untimely Paid Credit Balance The delay in issuing the credit balance was due to a timing oversight related to the award year dates. Although the Credit Balance Authorization Form was on file, the refund was processed after the award year had ended, rather than within the required timeframe. In the past, students were always allowed to keep funds in their Populi accounts for future use regardless of the loan award year, and it had not previously been indicated that this practice was not allowed. Actions Taken or Planned: We have reviewed our internal procedures and will strengthen oversight of award year deadlines to ensure that all credit balances are refunded within the required timeframe. Moving forward, the financial aid and accounting teams will implement a compliance checklist and establish calendar reminders to prevent similar delays. Additionally, we will revise the wording on our Credit Balance Authorization Form to read: “Leave the funds in my account and any remaining funds from the current award year in my account up to the end of the loan period.” Completion Date: Ongoing 9/26/2025 Dong-Hua Yang MD, PhD Date Title: Administrative Dean Telephone: 516-739-1545 Email: administrative_dean@nyctcm.edu

View Audit 370123 Questioned Costs: $1

Finding 1158230 (2024-001)

Material Weakness 2024

New York College of Traditional Chinese Medicine

NY

Student Financial Aid Reporting Special Tests & Provisions

Finding 2025-001: Inaccurate and Untimely Enrollment Status Reporting Comments on Finding and Recommendations: Statement of Concurrence: We concur with the finding of Inaccurate and Untimely Enrollment Status Reporting The inaccuracies and delays were mainly the result of our scheduling process. Cur...

Finding 2025-001: Inaccurate and Untimely Enrollment Status Reporting Comments on Finding and Recommendations: Statement of Concurrence: We concur with the finding of Inaccurate and Untimely Enrollment Status Reporting The inaccuracies and delays were mainly the result of our scheduling process. Currently, we update enrollment maintenance every two months, typically on the day prior to the scheduled dates. We now understand that enrollment status updates must be completed within 15 days after the scheduled date. Actions Taken or Planned: We have reviewed the enrollment maintenance schedule and adjusted our process to ensure compliance with the requirement. Moving forward, enrollment status will be updated within 15 days after the scheduled date. This adjustment will be fully implemented starting from the next scheduled update on 09/30/2025. 9/26/2025 Dong-Hua Yang MD, PhD Date Title: Administrative Dean Telephone: 516-739-1545 Email: administrative_dean@nyctcm.edu

View Audit 370123

Finding 1158192 (2024-006)

Material Weakness 2024

Atrium Health, Inc.

NC

Student Financial Aid Cash Management Period of Performance

Corrective Action Plan: Atrium Health CMHA management in the future will ensure that all correspondence, including notes from review meetings and approvals of key decisions, will be documented and retained as part of the support records for FEMA related awards. Proposed Completion Date: No further a...

Corrective Action Plan: Atrium Health CMHA management in the future will ensure that all correspondence, including notes from review meetings and approvals of key decisions, will be documented and retained as part of the support records for FEMA related awards. Proposed Completion Date: No further action is required until future needs arise for Atrium Health CMHA to obtain FEMA funding awards at which time management will ensure all documentation supporting the process and key decisions are retained.

View Audit 370096

Finding 1158191 (2024-005)

Material Weakness 2024

Atrium Health, Inc.

NC

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: Atrium Health CMHA management, as part of the 2025 process and procedure consulting engagement, will ensure that appropriate training and process design for Jenzabar Financial Aid (JFA) system are implemented to accurately capture and retain all data required for FISAP report...

Corrective Action Plan: Atrium Health CMHA management, as part of the 2025 process and procedure consulting engagement, will ensure that appropriate training and process design for Jenzabar Financial Aid (JFA) system are implemented to accurately capture and retain all data required for FISAP reporting. Proposed Completion Date: By December of 2025, Atrium Health CMHA management will complete the corrective action.

View Audit 370096

Finding 1158190 (2024-004)

Material Weakness 2024

Atrium Health, Inc.

NC

Student Financial Aid Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303

Corrective Action Plan: Atrium Health CMHA management, as part of the 2025 process and procedure consulting engagement, will ensure that all GLBA requirements over the Information Security Program are both documented completely and inclusive in scope of both general CMHA IT systems as well as IT sys...

Corrective Action Plan: Atrium Health CMHA management, as part of the 2025 process and procedure consulting engagement, will ensure that all GLBA requirements over the Information Security Program are both documented completely and inclusive in scope of both general CMHA IT systems as well as IT systems specific to the SFA program. Proposed Completion Date: By December of 2025, Atrium Health CMHA management will complete the corrective action.

View Audit 370096

Corrective Action Plans

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