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Corrective Action Plans

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Finding 1165623 (2025-001)
Material Weakness 2025
Pathways Behavioral Services, Inc.
IA
Eligibility Subrecipient Monitoring Cash Management
Pathways executive management team will provide at least quarterly trainings on any changes in state of federal funding guidance and ensure implementation of this guidance is clear through regular contact with state and federal agencies.
Pathways executive management team will provide at least quarterly trainings on any changes in state of federal funding guidance and ensure implementation of this guidance is clear through regular contact with state and federal agencies.
View Audit 376282
Finding 1165469 (2025-004)
Material Weakness 2025
Clintondale Community Schools
MI
Cash Management Subrecipient Monitoring Material Weakness
see corrective action plan
see corrective action plan
View Audit 376196
Finding 1165468 (2025-003)
Material Weakness 2025
Clintondale Community Schools
MI
Allowable Costs / Cost Principles Subrecipient Monitoring
see corrective action plan
see corrective action plan
View Audit 376196
Finding 1165467 (2025-002)
Material Weakness 2025
Clintondale Community Schools
MI
Cash Management Subrecipient Monitoring Material Weakness
see corrective action plan
see corrective action plan
View Audit 376196
Finding 1165456 (2025-001)
Material Weakness 2025
Aldine Independent School District
TX
Allowable Costs / Cost Principles Reporting Subrecipient Monitoring § 200.302 § 200.303
Corrective Action Plan for Federal Award Audit Finding 2025-001 Finding Title: Allowable Costs/Cost Principles – Improper expenditure recognition Federal Program: Title II, Part A, Teacher & Principal Training and Recruiting Assistant Listing Number: 84.367A Federal Agency Name: U.S. Department of E...
Corrective Action Plan for Federal Award Audit Finding 2025-001 Finding Title: Allowable Costs/Cost Principles – Improper expenditure recognition Federal Program: Title II, Part A, Teacher & Principal Training and Recruiting Assistant Listing Number: 84.367A Federal Agency Name: U.S. Department of Education Passed-Through Agency Name: Texas Department of Education Type of Finding: Significant Deficiency in Internal Control over Compliance Description of Corrective Action The District acknowledges the internal control system did not timely detect the improper recognition of expenditures in the incorrect fiscal period. It is important to emphasize that the expenditures identified were ultimately removed from the current year activity and were excluded from the year-end reimbursement request. The District commits to strengthening its year-end closing procedures and providing comprehensive training to address the noted deficiency in monitoring and review. The following actions will be taken: Mandatory Staff Training on Expenditure Cut-off and Accruals The District will develop and implement mandatory, targeted training for all personnel responsible for processing, recording, reconciling, and reviewing federal grant expenditures, with a specific focus on year-end cut-off procedures and proper expense recognition (accruals versus prepaid expenses). Implementation of Formal Grant Expenditure Cut-off Review Procedure A formalized closing procedure will be implemented for all federal awards, ensuring a mandatory, documented review of expenditures and payables near the fiscal year-end. Persons Responsible Timothy Momanyi, Chief Financial Officer Thania Gonzalez, Assistant Superintendent of Business and Finance Anticipated Completion Date The initial staff training will occur by May 31, 2026. The full implementation of the new procedures, with documented adherence by all responsible staff, will be complete by June 30, 2026, ensuring the new controls are fully operational before the close of the 2025-2026 fiscal year.
View Audit 376161
Finding 1165448 (2025-002)
Material Weakness 2025
Westmoreland County Community College
PA
Student Financial Aid Subrecipient Monitoring Cash Management
Finding 2025-002: Student Financial Aid Cluster – Reporting View of Responsible Officials and Planned Corrective Action: Root Cause Errors occurred because the data file transmitted from Anthology to COD did not consistently include the correct student information. It is not yet clear whether the is...
Finding 2025-002: Student Financial Aid Cluster – Reporting View of Responsible Officials and Planned Corrective Action: Root Cause Errors occurred because the data file transmitted from Anthology to COD did not consistently include the correct student information. It is not yet clear whether the issue arises from configuration problems, system design limitations, or both. Planned Corrective Action and Responsible Officials • Procedure review and update. The Financial Aid Office will review and revise procedures to ensure accurate, timely, and complete reporting to COD, including pre-submission and post-submission checks. • System-to-COD file analysis with Anthology. In partnership with Anthology's support and managed services teams, the College will: o o o Analyze how COD reporting files are created within Anthology. Identify why certain student data elements are not being transmitted correctly. Implement configuration changes or other system-level fixes to ensure accurate and complete reporting. • Enhanced manual validation until issues are resolved. If the file creation process is determined to be working "as designed" but still does not meet regulatory expectations, Financial Aid staff will perform manual review and correction of COD files prior to submission, and will monitor error and rejection reports from COD for follow-up. As with Finding 2025-001, the Vice President for Student Affairs and the Director of Financial Aid share responsibility for ensuring these corrective actions are implemented and sustained commencing on the date set forth above.
View Audit 376153
Finding 1165428 (2025-002)
Material Weakness 2025
Detroit Public Schools Community District
MI
Reporting Subrecipient Monitoring Cash Management § 200.303
Condition: The School District's controls did not prevent, or detect and correct in a timely manner, duplicative costs charged to the grant. Planned Corrective Action: The District annually processes thousands of supplemental payments for Home Visits. The audit found only 5 individual payments were ...
Condition: The School District's controls did not prevent, or detect and correct in a timely manner, duplicative costs charged to the grant. Planned Corrective Action: The District annually processes thousands of supplemental payments for Home Visits. The audit found only 5 individual payments were duplicated. The duplication was caused by human error during an internal staff transition within the Family and Community Engagement (FACE) department. This led the new manager to incorrectly report employee home visit logs twice. The FACE team will add internal controls during staff transitions to ensure documentation is not duplicated. Contact person responsible for corrective action: Jeremy Vidito, CFO Anticipated Completion Date: January 1, 2026
View Audit 376137
Finding 1165427 (2025-001)
Material Weakness 2025
Detroit Public Schools Community District
MI
Subrecipient Monitoring Cash Management HUD Housing Programs § 200.403
Condition: Costs charged to ALN 97.036 – Disaster Grants: Public Assistance were also charged to ALN 84.425 - Education Stabilization Fund (Elementary and Secondary School Emergency Relief - "ESSER") in prior fiscal years, indicating potential duplication of expenditures across federal programs. Pla...
Condition: Costs charged to ALN 97.036 – Disaster Grants: Public Assistance were also charged to ALN 84.425 - Education Stabilization Fund (Elementary and Secondary School Emergency Relief - "ESSER") in prior fiscal years, indicating potential duplication of expenditures across federal programs. Planned Corrective Action: The District applied for reimbursement of potentially eligible COVID expenditures in 2022. Per an April 5, 2022 FEMA memo “FEMA Continues Funding to Support the Safe Operations of Schools”, school districts could apply for reimbursement for ESSER funded expenditures, and then upon approval of application shift the funds to general fund. “Schools and school districts may utilize FEMA Public Assistance to receive full reimbursement for costs for the purposes above. Schools and districts may also use Elementary and Secondary School Emergency Relief (ESSER) funding from the U.S. Department of Education as a way to provide the up-front cost for the above health and safety measures, and later seek reimbursement through the FEMA Public Assistance process. For example, a local education agency (LEA) may use ESSER funds for costs that may ultimately be covered by FEMA; however, once it receives funds from FEMA for those costs, it must reimburse the ESSER grant account.” FEMA provided District award notification for COVID testing in December 2024 and January 2025, by this time the ESSER grant had closed on September 30, 2024 and the final expenditure reports for ESSER had been submitted to MDE in November 2024. Therefore the District could not complete the allowable general fund swaps. The District notified Michigan Department of Education and Michigan State Police of the timing issue. Upon request from MI State Police, the District provided documentation that available general funds were available to conduct the swaps if the FEMA approval had been received in a timely manner. Contact person responsible for corrective action: Jeremy Vidito, CFO Anticipated Completion Date: Requested documentation was submitted to Michigan State Police on November 7, 2025
View Audit 376137
Finding 1165421 (2025-002)
Material Weakness 2025
Bloomingdale School District #16
MI
Subrecipient Monitoring Significant Deficiency
The District agrees with the finding and will implement a system of internal control to properly document the time and effort that is charged to the grant. The District has contracted with the intermediate school district to provide business services and ensure the documentation is obtained for time...
The District agrees with the finding and will implement a system of internal control to properly document the time and effort that is charged to the grant. The District has contracted with the intermediate school district to provide business services and ensure the documentation is obtained for time and effort.
View Audit 376118
Finding 1165420 (2025-003)
Material Weakness 2025
Oblong Cusd #4
IL
Subrecipient Monitoring Cash Management Reporting
The Superintendent will thoroughly review and approve quarterly 'historical expenditure reports" and supporting documentation on a regular basis prior to electronic submissions. Reviews will encompass a search for adjustments and duplicate classifications, and a determination of reasonable vendors, ...
The Superintendent will thoroughly review and approve quarterly 'historical expenditure reports" and supporting documentation on a regular basis prior to electronic submissions. Reviews will encompass a search for adjustments and duplicate classifications, and a determination of reasonable vendors, expense descriptions, budget to actual comparisons, and dates. Corresponding documents will be manually signed and dated to indicate approval.
View Audit 376114
Finding 1165378 (2025-002)
Material Weakness 2025
Ecorse Public Schools
MI
Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness
Corrective Action Plan: Implement improved payrol l a llocation procedures. redesign and maintain cha11 of accounts we have a lready started. and enhance budget monitoring by monthly meeting with d irectors to go over grants. Hold monthly coordination meetings between finance and program departments...
Corrective Action Plan: Implement improved payrol l a llocation procedures. redesign and maintain cha11 of accounts we have a lready started. and enhance budget monitoring by monthly meeting with d irectors to go over grants. Hold monthly coordination meetings between finance and program departments to discuss budget performance and funding compliance.
View Audit 375991
Finding 1165331 (2025-001)
Material Weakness 2025
University of Cincinnati
OH
Student Financial Aid Subrecipient Monitoring Significant Deficiency
Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s ...
Condition: The University did not have controls in place to ensure that the required due diligence review was completed in the last two-year period related to the current established contract. Planned Corrective Action: In order to ensure that the terms of the consumer accounts offered through UC’s Tier 1 banking agreement are not inconsistent with the best financial interest of students who choose to open an account, UC Campus Services will, at a minimum, every 2 years, beginning October 2025: a. Conduct a due diligence review to ascertain whether the fees imposed under the current agreement are consistent with or below prevailing market rates. a. This will be accomplished by downloading and comparing “consumer schedule of fees” documents from UC’s current provider as well as several local competitors (e.g. US Bank, Fifth Third Bank, Chase Bank, Superior Credit Union). b. Ensure that termination provisions are maintained in the active agreement. These provisions are listed in the current agreement under Exhibit G. 4. (g). (1). In addition, the university will organize a Title IV compliance working group to meet monthly to review any communications or new requirements published by the U.S. Department of ED, State of Ohio, or other regulatory agencies. This core working group will be comprised of members of the Student Financial Aid Office, the Office of the Bursar, and the Office of the Controller, the three offices primarily responsible for awarding, disbursing, and drawing down funds related to the Title IV programs. This group will be responsible for communicating any changes to institutional responsibilities to other university partners who may need to review or revise policies and procedures based on the regulatory changes. Contact person responsible for corrective action: Neal Stark for the specific remedy for the due diligence review, Leigh Jackson for the compliance working group. Anticipated Completion Date: 10/31/2025 and every 2 years thereafter
View Audit 375925
Finding 1165320 (2025-002)
Material Weakness 2025
Rocky Mountain College
MT
Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility
Finding 2025-002: In order to ensure proper compliance with the student refund and return process, the CFO, Controller, and Student Accounts Coordinator will establish clear departmental responsibilities for initiating and approving financial aid batches and create an internal processing timeline sh...
Finding 2025-002: In order to ensure proper compliance with the student refund and return process, the CFO, Controller, and Student Accounts Coordinator will establish clear departmental responsibilities for initiating and approving financial aid batches and create an internal processing timeline shorter than the 14-day federal limit. Additionally, the CFO, Controller, and Student Accounts Coordinator will obtain training on the timing and documentation requirements under 34 CFR §668.164(h).
View Audit 375900
Finding 1165315 (2025-001)
Material Weakness 2025
Rocky Mountain College
MT
Reporting Internal Control / Segregation of Duties Special Tests & Provisions
Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to moni...
Finding 2025-001: In order to ensure proper compliance with reporting student enrollment statuses to the National Student Loan Data System, the CFO, Controller, and Director of Student Records will familiarize themselves with federal reporting deadlines and create an improved internal system to monitor and report student enrollment changes on a timely basis. The CFO, Controller, and Director of Student Records will explore enhanced monitoring controls such as designating a second reviewer to verify that all files were transmitted and accepted by NSC within required timeframes and implementing an internal tracking log to record the submission and confirmation dates for each roster file.
View Audit 375900
Finding 1165309 (2025-001)
Material Weakness 2025
Romoland School District
CA
Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility
The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue ...
The initial issue was resolved. We determined that a transposition error occurred during the entry of the student count numbers into the CARS system. Importantly, this data entry error did not affect the funding allocation received. In accordance with the auditor's recommendations, we will continue to utilize the CalPads 1.17 report for reporting student counts for each school. Moving forward, we will implement a dual-verification process, requiring a second person to confirm data accuracy during the entry of numbers into CARS, thereby mitigating the risk of future data entry errors.
View Audit 375893
Finding 1165268 (2025-001)
Material Weakness 2025
Affordable Housing Network, Inc. & Consolidated Entities
IA
Subrecipient Monitoring Material Weakness
Management agrees with the finding, and will evaluate available personnel to coordinate monitoring procedures to ensure accurate tenant calculations.
Management agrees with the finding, and will evaluate available personnel to coordinate monitoring procedures to ensure accurate tenant calculations.
View Audit 375764
Finding 1165259 (2025-001)
Material Weakness 2025
District School Board of Pasco County
FL
Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking
Planned Corrective Action: The District remains committed to maintaining the highest standards of accurate reporting and will implement the following action steps: 1. Withdrawal Documentation Requirement: All student withdrawals in grades nine through twelve that will be removed from the cohort must...
Planned Corrective Action: The District remains committed to maintaining the highest standards of accurate reporting and will implement the following action steps: 1. Withdrawal Documentation Requirement: All student withdrawals in grades nine through twelve that will be removed from the cohort must be accompanied by a completed withdrawal form sent to parents via email or provided in person. This form will be uploaded directly into the student's record to ensure required documentation is readily available and securely archived. 2. Enhance Fields in Student Records: When a withdrawal code is applied that removes a student from a graduation cohort, additional fields will be added to the student's record: a. "Move To" Field: This field will now be required and will capture the anticipated new school or location of enrollment. b. Withdrawal Form Upload Field: This field will require the upload of the completed withdrawal form and supporting documentation. 3. Development of a Monitoring Tool: The District will design and deploy an enhanced monitoring tool for use by schools and designated district staff. This tool will provide a comprehensive report, tracking withdrawal codes removing students from graduation cohorts within the student information system. 4. Staff Training and Ongoing Monitoring: The District will provide additional training for relevant staff on enhanced procedures. Monitoring measures to ensure compliance will be completed by designated District staff and include direct follow-up with schools that have incomplete documentation. Anticipated Completion Date: March 17, 2026 Responsible Contact Person: Holly Rockhill, Technology & Information Services, Sr. Manager
View Audit 375735
Finding 1165257 (2025-005)
Material Weakness 2025
School District of Waupaca
WI
Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management
2025-005 – Medicaid – Allowable Activities and Costs - The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Official – Austin Moore, Business Manager Anticipated Completion Date – The District will correct this in the subseq...
2025-005 – Medicaid – Allowable Activities and Costs - The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Official – Austin Moore, Business Manager Anticipated Completion Date – The District will correct this in the subsequent fiscal year.
View Audit 375728
Finding 1165252 (2025-002)
Material Weakness 2025
School District of the City of Hazel Park
MI
Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking
We are compiling award letters in our shared drive as they come in so we have all of the pieces needed to complete the schedule of expenditures. We are also enhancing our grant monitoring throughout the year to have a better handle on the grants and accurately report the activity.
We are compiling award letters in our shared drive as they come in so we have all of the pieces needed to complete the schedule of expenditures. We are also enhancing our grant monitoring throughout the year to have a better handle on the grants and accurately report the activity.
View Audit 375717
Finding 1165248 (2025-001)
Material Weakness 2025
Wgbh Educational Foundation
MA
Subrecipient Monitoring § 200.301
Management's Views and Corrective Action Plan 2025-001- Compliance with Federal Funding Accountability and Transparency Act (FFATA) Reporting Sponsoring Agency: National Endowment for the Humanities Award Name: American Experience, A Man Called White Award Number: TR-297125-24 Assistance Listing Tit...
Management's Views and Corrective Action Plan 2025-001- Compliance with Federal Funding Accountability and Transparency Act (FFATA) Reporting Sponsoring Agency: National Endowment for the Humanities Award Name: American Experience, A Man Called White Award Number: TR-297125-24 Assistance Listing Title: Promotion of the Humanities Public Programs Assistance Listing Number: 45.164 Award Year: 2024-2025 Management's Views and Corrective Action Plan WGBH Educational Foundation (“the Foundation”) concurs with this finding. During fiscal year 2025, the Foundation identified a control failure with their established FFATA reporting control. After thorough review of active subaward agreements, the Foundation identified one contract that was not reported timely. Due to the grant's termination date of April 2, 2025, the Foundation was not able to file the report through SAM.gov. However, the Foundation promptly reached out to the National Endowment for Humanities (NEH) for assistance with filing. At this time, the Foundation has not received a response from NEH on next steps. The Foundation has since enhanced its control to include a three-way reconciliation using system generated reports to validate completeness of the Foundation’s monthly list of executed subaward agreements prior to reporting deadline. In addition to the reconciliation, the Foundation has implemented a FFATA process checklist which captures the process steps, applicable contract execution date(s), report submission date(s) and sign off/approval of the monthly process. A secondary review and approval of the process have been included in the updated control. The enhanced control was implemented for the September 2025 FFATA reporting. Contact person: Katie Dillon Managing Director, Production Finance and Grants Compliance 617-300-3829
View Audit 375703
Finding 1165224 (2025-003)
Material Weakness 2025
Doane University
NE
Student Financial Aid Subrecipient Monitoring
Finding 2025-003 Condition Of the sample of 25 disbursements, seven students tested did not receive proper notification of the student's right, or the parent's right to cancel any portion of the loans to be distributed. The sample was not a statistically valid sample. Corrective Action Plan To addre...
Finding 2025-003 Condition Of the sample of 25 disbursements, seven students tested did not receive proper notification of the student's right, or the parent's right to cancel any portion of the loans to be distributed. The sample was not a statistically valid sample. Corrective Action Plan To address this issue, the ERP notification process has been updated to ensure students receive clear and compliant communications regarding Direct Loan disbursements. Name(s) of Contact Person(s) Responsible for Corrective Action: Susan Collins, Director of Financial Aid Completion Date: October 17, 2025 Linda Scholting CFO 10/29/2025 Doc Management Response: Management has updated notification processes to ensure appropriate and timely notifications are sent to students.
View Audit 375536
Finding 1165223 (2025-002)
Material Weakness 2025
Doane University
NE
Student Financial Aid Subrecipient Monitoring Reporting
Finding 2025-002 Condition Of 25 students tested, the status date for one selected student was not reported in a timely manner on the campus level in the National Student Loan Data System (NSLDS). The sample was not statistically valid. Corrective Action Plan To address this issue, the Registrar’s O...
Finding 2025-002 Condition Of 25 students tested, the status date for one selected student was not reported in a timely manner on the campus level in the National Student Loan Data System (NSLDS). The sample was not statistically valid. Corrective Action Plan To address this issue, the Registrar’s Office will adjust the final spring submission date or add a fifth submission to ensure all spring updates are captured. This action resolves timing gaps caused by the non-term summer and the 60+ day interval between spring and fall semesters. Name(s) of Contact Person(s) Responsible for Corrective Action: Denise Ellis, Registrar Anticipated Completion Date: Spring submission dates will be modified or added by November 1, 2025 Linda Scholting CFO 10/29/2025 Management Response: Management has adjusted processes to ensure all student updates are correctly captured.
View Audit 375536
Finding 1165222 (2025-001)
Material Weakness 2025
Doane University
NE
Student Financial Aid Subrecipient Monitoring
Finding 2025-001 Condition During the year, there were no documented internal controls in place over the Title IV refund calculations. In the sample of 5 students who withdrew from the University, there was one student for whom the return was miscalculated. The result was too much aid being refunded...
Finding 2025-001 Condition During the year, there were no documented internal controls in place over the Title IV refund calculations. In the sample of 5 students who withdrew from the University, there was one student for whom the return was miscalculated. The result was too much aid being refunded. The sample was not statistically valid. Corrective Action Plan To address this issue, the Title IV Return of Funds Policy has been updated to strengthen accountability and compliance. All R2T4 calculations will be completed by the Financial Aid Counselor and reviewed by the Director, with signatures documenting internal controls. A checklist and quarterly reviews will ensure accuracy, and ERP integration within Ellucian Colleague, set for full implementation by October 31, 2025, will automate calculations and improve compliance monitoring. Name(s) of Contact Person(s) Responsible for Corrective Action: Susan Collins, Director of Financial Aid Anticipated Completion Date: October 31, 2025 Linda Scholting CFO 10/29/2025
View Audit 375536
Finding 1165201 (2025-002)
Material Weakness 2025
Franklin Public School District
WI
School Nutrition Programs Subrecipient Monitoring Eligibility
2025-002 – Child Nutrition Cluster – Eligibility – The District is aware of the missing eligibility documents for the Child Nutrition program and will implement new procedures and a plan to reduce the missing documentation. Responsible Officials – Heidi Engel, Enrollment & Transportation Coordinator...
2025-002 – Child Nutrition Cluster – Eligibility – The District is aware of the missing eligibility documents for the Child Nutrition program and will implement new procedures and a plan to reduce the missing documentation. Responsible Officials – Heidi Engel, Enrollment & Transportation Coordinator, and Jessica Christensen, District Food Service Manager Anticipated Completion Date – The District will correct this in the subsequent fiscal year.
View Audit 375479
Finding 1165119 (2025-001)
Material Weakness 2025
Marine Technology Society, Inc.
DC
Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency
Management concurs with the finding and will implement procedures to retain evidence of suspension and debarment reviews for all vendors and subrecipients under federally funded programs.
Management concurs with the finding and will implement procedures to retain evidence of suspension and debarment reviews for all vendors and subrecipients under federally funded programs.
View Audit 375405
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