Corrective Action Plans

Finding 524912 (2024-001)

None 2024

Wilkes University

PA

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

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed a...

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed annually by the University to ensure compliance.

View Audit 344278

Finding 524822 (2024-001)

Significant Deficiency 2024

The College of New Jersey

NJ

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.403 § 200.430

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administra...

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administration 609-771-2847 Corrective Action Plan: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions from July 1, 2023, to December 31, 2023, in the fiscal year being audited. The effort was certified after the fiscal year, as part of the year-end process which was not in line with the semi-annually time frames as historically done with guidance in our Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). The timing delays occurred due to staffing vacancies and knowledge transfer of current staff as well as misalignment of staffing. Once the staffing was realigned, trained, and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed. This task occurred during the months between August 2024 and November 2024 which was outside the policy time frames. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance by taking corrective action steps to improve monitoring and oversight, strengthen training and communications, and develop an action plan for corrective timing. The College implemented part of the corrective action on August 01, 2024, retroactive to July 1, 2023, and will complete the remaining items by the end of the next fiscal year. Anticipated Completion Date: June 30, 2025

View Audit 344210

Finding 524791 (2024-003)

Significant Deficiency 2024

University of Dubuque

IA

Subrecipient Monitoring Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive securi...

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive security policy. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 10/01/2024

View Audit 344180

Finding 524729 (2024-001)

None 2024

Nybdc Local Development Corporation

NY

Subrecipient Monitoring Matching / Level of Effort / Earmarking

We acknowledge the auditor’s comments and can confirm that the following corrective action has been implemented as of December 2024: Management has revised the process for identifying, segregating, and transferring Microloan repayments from a monthly process to a weekly process. This change will ens...

We acknowledge the auditor’s comments and can confirm that the following corrective action has been implemented as of December 2024: Management has revised the process for identifying, segregating, and transferring Microloan repayments from a monthly process to a weekly process. This change will ensure Microloan repayments received by our operating account are transferred to the appropriate MRF accounts within 10 working days. By changing the frequency of this task, we will enhance our compliance with Microloan requirements and more effectively manage Microloan program funds.

View Audit 344151

Finding 524727 (2024-001)

Significant Deficiency 2024

American Near East Refugee Aid

DC

Subrecipient Monitoring Reporting

Identifying Number: 2024-001 Finding: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA) Corrective Actions Taken: The first step is to submit the outstanding FFATA under U.S. Department of State coope...

Identifying Number: 2024-001 Finding: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA) Corrective Actions Taken: The first step is to submit the outstanding FFATA under U.S. Department of State cooperative agreement SPRMCO22CA0136, which was completed on February 17, 2025. Moving forward, Anera will implement a centralized tracking system to ensure the timely and accurate submission of all annual and government reporting requirements, as well as reports that may be triggered based on spending. A centralized tracker will be created for all agreements under the grants and compliance team, including specific deadlines and submission dates with links to those submissions. This system will provide visibility across all departments and stakeholders, ensuring that all reporting obligations are met promptly and preventing any oversight. The tracker will be maintained and regularly updated to reflect any changes in requirements or deadlines, fostering better coordination and accountability across Anera. Additionally, in order to enhance transparency and avoid potential siloing, the grants and compliance team will be expanded to include multiple team members with clear roles and responsibilities. This expansion will ensure that there is no over-reliance on any one individual, allowing for cross-functional knowledge sharing and greater collaboration. The team will work together to review and validate all reporting requirements, ensuring a more thorough and accurate submission process moving forward. This approach will also facilitate the identification and mitigation of any potential risks early in the process, strengthening overall compliance efforts. Name of Responsible Official and Title: Shanna Todd, International Grants Director Date Corrective Action Plan Executed: 2-3 Months (This time includes the onboarding new team members, building out the trackers, cross referencing all current obligations and rolling out to wider team.)

View Audit 344147

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 524695 (2024-001)

None 2024

Wilkes University

PA

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

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed a...

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed annually by the University to ensure compliance.

View Audit 344126

Finding 524663 (2024-002)

Material Weakness 2024

University of Southern Indiana

IN

Subrecipient Monitoring § 200.303 § 200.332 § 200.521

FINDING 2024-002 Finding Subject: PPHF Geriatric Education Centers - Subrecipient Monitoring Summary of Finding: Audit Finding 2024-002 states that the University of Southern Indiana did not establish a system of internal controls to ensure that subrecipient audit reports are received and reviewed, ...

FINDING 2024-002 Finding Subject: PPHF Geriatric Education Centers - Subrecipient Monitoring Summary of Finding: Audit Finding 2024-002 states that the University of Southern Indiana did not establish a system of internal controls to ensure that subrecipient audit reports are received and reviewed, when required, to ensure that subrecipients are properly monitored in accordance with Federal regulations. Contact Person Responsible for Corrective Action: Jina Platts, Assistant Vice President for Finance and Administration and Assistant Treasurer Contact Phone Number and Email Address: 812-465-7090; jlplatts@usi.edu Views of Responsible Officials: We concur with the finding that the University should have ensured that subrecipient audit reports were received and reviewed, when required, to ensure that subrecipients are properly monitored in accordance with Federal regulations. The University had other controls in place related to subrecipient monitoring including the review of financial reports and requests for reimbursement for subrecipient expenses. One purpose of collecting and reviewing subrecipient audit reports is to determine the level of monitoring required as high, medium, or low. Although the University treats all subrecipients as high risk, we are unable to issue a formal management decision to subrecipients within six months of acceptance of the audit report by the Federal Audit Clearinghouse without assurance that audit reports are received and reviewed in a timely manner. Description of Corrective Action Plan: The University will update subrecipient monitoring procedures as follows: 1. Upon issuance of a subaward, the Business Office will verify if a subrecipient is subject to single audit according to OMB Uniform Guidance. If so, the subrecipient must provide a complete copy of their most recent independent audit used to meet their OMB Uniform Guidance requirement or a link to their record on the Federal Audit Clearinghouse. 2. The Business Office will review the report to verify that there are no findings that may impact the proposed subaward. In the event there are such findings, the Business Office will notify the Office of Sponsored Projects & Research. Together the two offices will determine an appropriate plan of action and issue a Management Decision Letter as required by Uniform Guidance. 3. The Business Office will identify subrecipients receiving payments quarterly and verify that their most recent audit reports have been received and reviewed. Any audit reports completed after issuance of a subaward will be reviewed as described in #2 above. Anticipated Completion Date: Planned corrective actions to be implemented in January 2025.

View Audit 344100

Finding 524635 (2024-001)

Significant Deficiency 2024

Great Plains Housing Advocacy, Inc. Dba Great Plains Housing 103-11100

CA

HUD Housing Programs Procurement, Suspension & Debarment Subrecipient Monitoring

Finding 2024-001: The Property received a score of 58c* on a physical inspection of the Property performed on June 7, 2023 by a representative of HUD. By reference, the REAC inspection is included as a statement of condition. Comments on the Finding and Each Recommendation: Management should ensu...

Finding 2024-001: The Property received a score of 58c* on a physical inspection of the Property performed on June 7, 2023 by a representative of HUD. By reference, the REAC inspection is included as a statement of condition. Comments on the Finding and Each Recommendation: Management should ensure all necessary repairs have been made. Management should continue to conduct routine unit and general property inspections and deficiencies should be corrected in a timely manner. Action(s) taken or planned on the finding: Agree. Management has responded to HUD in regards to this inspection report and has addressed all health and safety issues. Management will continue to correct all remaining deficiencies noted and will implement a process of self-inspection of units and common areas. Management will request a new physical inspection of the property.

View Audit 344072

Finding 524629 (2024-003)

Significant Deficiency 2024

Keystone College

PA

Questioned Costs Subrecipient Monitoring Cash Management

Management will review the FY 24 FISAP report concerning the accuracy of the SEOG drawdown and whether any portion of the drawdown should have been reported as carryover funds. Any overdraw determined as part of this reconciliation will be returned to the U.S. Department of Education. The College ...

Management will review the FY 24 FISAP report concerning the accuracy of the SEOG drawdown and whether any portion of the drawdown should have been reported as carryover funds. Any overdraw determined as part of this reconciliation will be returned to the U.S. Department of Education. The College has also strengthened controls and trained staff to ensure compliance with cash management practices for future federal awards.

View Audit 344059 Questioned Costs: $1

Finding 524616 (2024-004)

Significant Deficiency 2024

Marymount University

VA

Subrecipient Monitoring Cash Management § 200.305

Research and Development Cluster – Assistance Listing Numbers 47.070, 47.076, 47.084, and 93.846 Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and per...

Research and Development Cluster – Assistance Listing Numbers 47.070, 47.076, 47.084, and 93.846 Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Midway through the fiscal year, we introduced a new process involving multiple layers of approval before a drawdown is executed. The drawdown calculation is done either by the Senior Accountant or Grant Manager and sent to either the Grant Manager (if prepared by the Senior Accountant), or Controller (if prepared by the Grant Manager) for review and approval. If additional information is needed, the approver sends the request back for updating and recalculation. Name(s) of the contact person(s) responsible for corrective action: Mutale Sokoni, Associate Vice President for Finance, 703-284-1496 Planned completion date for corrective action plan: Action taken during April 2024

View Audit 344056

Finding 524608 (2024-002)

Significant Deficiency 2024

Marymount University

VA

Student Financial Aid Subrecipient Monitoring

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safegu...

Student Financial Aid Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, and 84.268 Recommendation: We recommend that the University engage a third party or perform the risk assessment for the areas required by the Gramm-Leach-Bliley Act 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 prepared a separate Corrective Action Plan document in response to this finding due to the sensitivity. Each requirement noted as a deficiency within the finding is address separately and appropriate response is being taken. Name(s) of the contact person(s) responsible for corrective action: Carl Whitman, Associate Vice President and Chief Information Officer (703-526-6901) Planned completion date for corrective action plan: Action plan completed on February 18, 2025.

View Audit 344056

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 524589 (2024-001)

None 2024

City of Clarksville

TN

Subrecipient Monitoring Reporting

Management's Corrective Action Plan: Due to changes in departmental management and responsibilities submission was not timely. We have now implemented policies and procedures to ensure grant activity is reported in accordance with the grant requirements. This matter was resolved subsequent to June 3...

Management's Corrective Action Plan: Due to changes in departmental management and responsibilities submission was not timely. We have now implemented policies and procedures to ensure grant activity is reported in accordance with the grant requirements. This matter was resolved subsequent to June 30, 2024.

View Audit 344029

Finding 524552 (2024-002)

Significant Deficiency 2024

Des Moines Rhf Housing, Inc. Dba Virginia Park Apartments #074-Eh184

CA

HUD Housing Programs Subrecipient Monitoring

Statement of Condition 2024-002 (Assistance Listing 14.181): The Property received a Management Occupancy Review (MOR) rating of Below Average and is unable to locate a response to HUD correcting the findings in the MOR. Recommendation: Management should clear all findings from the MOR and follow u...

Statement of Condition 2024-002 (Assistance Listing 14.181): The Property received a Management Occupancy Review (MOR) rating of Below Average and is unable to locate a response to HUD correcting the findings in the MOR. Recommendation: Management should clear all findings from the MOR and follow up with HUD to request a close-out letter. Management Response: Agree. On January 24, 2025, management responded to the MOR findings and believes they have adequately addressed all deficiencies. No further action is required.

View Audit 343963

Finding 524550 (2024-001)

Significant Deficiency 2024

Des Moines Rhf Housing, Inc. Dba Virginia Park Apartments #074-Eh184

CA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Statement of Condition 2024-001 (Assistance Listing 14.181): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended October 31, 2024. Recommendation: Management should transfer $19,200 from the operating cash account to the reserve for replacements ...

Statement of Condition 2024-001 (Assistance Listing 14.181): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended October 31, 2024. Recommendation: Management should transfer $19,200 from the operating cash account to the reserve for replacements fund or request a suspension of monthly deposits from HUD. Management Response: Agree. On January 9, 2025, management transferred $19,200 from the operating account to the reserve for replacements fund.

View Audit 343963 Questioned Costs: $1

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 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

Finding 524497 (2024-001)

Material Weakness 2024

Franklin Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection repor...

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors were performed during the audit period. 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 Reporting compliance requirement which includes documentation of the operation of the controls. Contact Person Responsible for Corrective Action: Camilla Hoffman, Assistant Deputy Treasurer Contact Phone Number and Email Address: hoffmanca@franklinschools.org, 317-346-8748 Views of Responsible Officials: We concur with the finding, but we would like to emphasize that the review had been implemented. It just was not documented by the reviewer. Description of Corrective Action Plan: The Assistant Deputy Treasurer will begin documenting her review of the required ESSER reporting via email, so that this review can be verified by auditors or other inquirers. Anticipated Completion Date: This corrective action will be added to the district’s procedures immediately, but ESSER reporting is not anticipated until later in the Spring 2025.

View Audit 343871

Finding 524461 (2024-005)

Material Weakness 2024

City of Lincoln City, Oregon

OR

Subrecipient Monitoring Material Weakness Reporting

Beginning March 2025, the City's Finance department will review and sign off on any annual financial reports submitted to the U.S. Department of Treasury. The City will provide training to appropriate staff that Finance Departmental review is required.

View Audit 343795

Finding 524447 (2024-001)

Significant Deficiency 2024

National 4-H Council

DC

Questioned Costs Subrecipient Monitoring § 200.1 § 200.211 § 200.303 § 200.332

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial managemen...

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial management of Council’s grants, including subrecipient monitoring and allowable cost review, were under the purview of the program teams. In May 2024, these responsibilities were deemed to be more appropriately aligned with the Finance and Business Operations Team’s skill sets and brought under that team’s management. Additionally, in December 2023, the accounts payable process was automated, enabling a more thorough review of each reimbursement package. Anticipated Completion Date: May 6, 2024 Responsible Contact Person: Stan Harrell, Chief Financial Officer

View Audit 343772 Questioned Costs: $1

Finding 524441 (2024-001)

Significant Deficiency 2024

McDaniel College and Subsidiary

MD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Y...

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Year – May 31, 2024 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan Corrective Action Planned: {The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring. Identify the specific actions to be taken to eliminate or mitigate the recurrence of the finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Kemia Himon, Financial Aid Director Anticipated Completion Date: 3.3.25

View Audit 343760 Questioned Costs: $1

Finding 524430 (2024-002)

Significant Deficiency 2024

Municipality of Quebradillas

PR

Subrecipient Monitoring Reporting § 200.328

The Municipality established internal control to maintain schedule of the due date reports in order to avoid this situation.

View Audit 343714

Finding 524393 (2024-002)

Material Weakness 2024

Loma Linda University

CA

Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs § 200.329

Finding 2024-002 – Internal control deficiency and noncompliance over Reporting related to performance reports Connecting Minority Communities Pilot Program – Timeliness and Accuracy During testing over the Reporting compliance requirement, management did not have effective internal controls in pl...

Finding 2024-002 – Internal control deficiency and noncompliance over Reporting related to performance reports Connecting Minority Communities Pilot Program – Timeliness and Accuracy During testing over the Reporting compliance requirement, management did not have effective internal controls in place to ensure performance reports were submitted by the deadline and completed correctly. Management did not submit the required performance reports by the deadline and certain key line items were not completed correctly. Management Response and Action Plan: Management will meet with the Principal Investigator and provide additional training emphasizing the importance of timely submission and accuracy of grant documentation and reports. In addition, management will monitor submission deadlines and follow-up with the Principal Investigator to ensure timely filing. Responsible Person: Executive Director of Sponsored Project Administration Target Date: February 2025

View Audit 343628

Finding 524366 (2024-003)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were ...

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for and will keep documentation of the review being done and signed off on. Anticipated Completion Date: This will be corrected with the next round of ESSER reporting due January 2025.

View Audit 343584

Corrective Action Plans

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