Corrective Action Plans

Finding 1177061 (2025-034)

Material Weakness 2025

State of Colorado

CO

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility

The Department agrees with the recommendation and will strengthen internal controls over Medicaid eligibility determinations to ensure compliance with federal and state regulations. The Department will issue formal Management Decision Letters to the identified counties requiring the development and ...

The Department agrees with the recommendation and will strengthen internal controls over Medicaid eligibility determinations to ensure compliance with federal and state regulations. The Department will issue formal Management Decision Letters to the identified counties requiring the development and implementation of Department-approved Corrective Action Plans. These plans will be required to address root causes related to income and resource calculation, documentation of eligibility determinations, and household composition, including any necessary training or guidance for county and Medical Assistance site caseworkers. The Department will review, approve, and monitor corrective actions to ensure deficiencies are appropriately addressed.

View Audit 390975

Finding 1177007 (2025-001)

Material Weakness 2025

Metropolitan Family Service

OR

Subrecipient Monitoring

Metropolitan Family Service respectfully submits the following corrective action plan for the year ending June 30, 2025. Audit: July 1, 2024 – June 30, 2025 The finding from the schedule of findings and questioned cost are discussed below. The finding is numbered with the number assigned in the sche...

Metropolitan Family Service respectfully submits the following corrective action plan for the year ending June 30, 2025. Audit: July 1, 2024 – June 30, 2025 The finding from the schedule of findings and questioned cost are discussed below. The finding is numbered with the number assigned in the schedule. 2025-001 FINDING – SUBRECIPIENT MONITORING Recommendation: We recommend that the Organization implement the necessary internal controls to ensure that subrecipient monitoring is performed and documented. Additionally, we recommend that the Organization revise their Subrecipient Monitoring Policy to address 2 CFR 332 and to give clear directives of how subrecipient monitoring will be performed and documented. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action Plan: Steps were taken to update MFS’s Subrecipient Monitoring Policy and procedures to better address 2 CFR 332 giving clear directives of how subrecipient monitoring will be performed and documented going forward. Name(s) of the contact people responsible for correction action: Richard Seals, CFO; Nick Clark, Senior Financial Analyst; and the relevant Program Manager/Director Plan completion date for corrective action plan: December 31, 2025

View Audit 390864

Finding 1176982 (2025-001)

Material Weakness 2025

University of St. Thomas

TX

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Reference Number: 2025-001 Finding: Other Instance of Noncompliance and Deficiency Status: In-Progress Corrective Action: An instance was found where the R2T4 calculation for one student had a typo of the incorrect date. This was subsequently corrected. We reviewed this student record and concluded ...

Reference Number: 2025-001 Finding: Other Instance of Noncompliance and Deficiency Status: In-Progress Corrective Action: An instance was found where the R2T4 calculation for one student had a typo of the incorrect date. This was subsequently corrected. We reviewed this student record and concluded that it was a human error made. There is no pattern of incorrect information being used. To avoid future errors, the Assistant Director will meet with the Dean monthly and we will review completed R2T4's during that period. We believe having another pair of eyes to review the work completed will be sufficient to correct any inconsistencies. Person(s) Responsible for Implementing: Lynda McKendree, Dean of Scholarships and Financial Aid and Thuylieu Aligo, Assistant Director of Scholarships and Financial Aid. Implementation Date: 1/27/2026

View Audit 390824

Finding 1176904 (2025-001)

Material Weakness 2025

Benjamin Franklin Cummings Institute of Technology

MA

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2025 Corrective Action Plan Contact Person: Sabina Yesman, Director of Financial Aid A PELL Grant was awarded and disbursed for one ineligible...

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2025 Corrective Action Plan Contact Person: Sabina Yesman, Director of Financial Aid A PELL Grant was awarded and disbursed for one ineligible student during the 2024-2025 Academic Year at Benjamin Franklin Cummings Institute of Technology (FC Tech). The error resulted from incomplete synchronization between enrollment and financial aid systems during the system transition period. Specifically, enrollment status and census-date verification were not fully integrated into the automated disbursement workflow, allowing aid to disburse before final eligibility confirmation. FC Tech has taken corrective measures and implemented monitoring and system controls to prevent future errors from occurring. Corrective Action Taken  FC Tech reviewed the student’s record and confirmed the ineligibility.  The PELL Grant award was adjusted to $0, and the disbursement was reversed.  The student account was corrected, and all required accounting and G5 drawdown adjustments were completed. The amount of $3,697 was returned on 12/18/2025  The case was documented internally for training purposes. Preventive Measures Implemented (February 2026) To prevent recurrence, FC Tech has implemented the following controls:  Enrollment Verification Prior to Disbursement All PELL-eligible students must be actively enrolled and confirmed in the Student Information System (Jenzabar) prior to disbursement.  Census-Date Verification Through Multiple Systems Enrollment status at census date is now validated through an integrated, multi-system verification process involving the Jenzabar, our Financial Aid System (PowerFAIDS), and Registrarconfirmed Enrollment Reports.  Delayed Disbursement Timeline Federal Aid disbursements are scheduled to occur no earlier than one week after census date to allow sufficient time for enrollment stabilization, drops, corrections and reconciliation  System Edit/Control Automated system edits have been implemented to prevent a PELL disbursement if census-date enrollment status is missing, unconfirmed, or inconsistent across systems.

View Audit 390762

Finding 1176859 (2025-001)

Material Weakness 2025

Harrisburg Area Community College

PA

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring

Corrective Action Plan Thursday, February 12, 2026 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the June 30, 2025 audit report dated February 13, 2026 schedule of findings and questioned cost are discu...

Corrective Action Plan Thursday, February 12, 2026 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the June 30, 2025 audit report dated February 13, 2026 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding): U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants, 804 Wayne Avenue, Chambersburg, Pennsylvania 17201 Finding Type: (per Finding) Federal Awards: Material Weakness in Internal Control over Compliance and Noncompliance Internal Control Type: (please choose the type per the finding)  Material Weakness(es) o Significant Deficiencies Audit Finding No.: 2025-001 Federal Program: (per Finding) Student Financial Assistance Cluster Compliance Requirement: (per Finding) Return of Title IV Funds Audit Finding Title/Statement of Condition: (copy from audit findings documentation): The College did not comply with federal requirements related to the timely return of Title IV funds. Specifically, the College failed to return aid for four students who never attended within the 30-day period required under 34 CFR 668.21(b). In addition, the College did not return funds for one student who began attendance but subsequently required a refund within the 45-day timeframe mandated under 34 CFR 668.173(b). Auditor Recommendation: (copy from audit findings documentation) The College should strengthen its internal controls and monitoring procedures to ensure compliance with federal return-of-funds requirements. This should include timely verification that calculated refund amounts match what is actually returned, improved review processes to confirm that students who never attended are identified promptly, and training for relevant staff to ensure consistent understanding and execution of federal aid return requirements. Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). The College has made several enhancements that should prevent future problems with the return of funds. 1) In fall 2025, the College instituted a new process for collecting data for attendance/participation of students. This process includes a data collection approximately one week into the part of term (the “Academic Participation Data Collection) – and before the disbursement of Title IV aid. It also includes follow up with faculty at several intervals throughout the semester to encourage them to withdraw students who have stopped attending. This improved process gives us clearer and more transparent data on attendance/participation so that aid recalculations and returns can be managed in a more timely manner 2) As of January 2025, the College has implemented a process to prevent the disbursement of Title IV (TIV) aid to students who are not enrolled in a future semester or are not considered actively attending. For example, if a student attended the Fall semester but is not enrolled for the Spring semester, Title IV funds cannot be disbursed if the aid was not originated before the student became ineligible. This process applies in both directions, as disbursement includes both paying funds to a student’s account and reversing funds when appropriate. Accordingly, the Previous Semester Fund Request process is designed to ensure that Title IV funds are either paid or reversed in compliance with federal requirements. 3) The Financial Aid team will continue processing returns at the time that an R2T4 occurs to prevent miscommunications and ensure timely completion. 4) The Financial Aid team and Finance teams will collaborate and engage Bank Mobile to improve the processing of stale checks and timed out funds. Anticipated Completion Date: May 1, 2026 Name(s) and Title(s) of contact person(s) responsible for correction action: Tim Barshinger, Associate Vice-president of Student Enrollment Services Juan Cordoba, Financial Aid Director

View Audit 390704

Finding 1176843 (2025-002)

Material Weakness 2025

San Joaquin Delta Community College District

CA

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Views of Responsible Officials and Corrective Action Plan We concur. Management has formed an Academic Calendar Committee for pre-year review, as well as implemented automated short-term date detection in SIS and instituted a secondary review process for all R2T4 calculations.

View Audit 390685

Finding 1176837 (2025-001)

Material Weakness 2025

San Joaquin Delta Community College District

CA

Student Financial Aid Subrecipient Monitoring Eligibility

Views of Responsible Officials and Corrective Action Plan We concur. The Financial Aid Office and IT have Implemented a “Just-In-Time” eligibility verification in MyDelta. Additional manual reconciliation before disbursement has also been implemented.

View Audit 390685

Finding 1176831 (2025-004)

Material Weakness 2025

Silver Creek School Corporation

IN

Cash Management Internal Control / Segregation of Duties Subrecipient Monitoring § 200.208 § 200.302 § 200.303 § 200.305 § 200.328

FINDING 2025-004 Subject: COVID -19 - Education Stabilization Fund - Cash Management Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the find...

FINDING 2025-004 Subject: COVID -19 - Education Stabilization Fund - Cash Management Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation will implement and consistently apply a standardized two-level review and approval process for all grant reimbursements to ensure proper accounting, documentation, and compliance. The grants administrator (or designee) will prepare and conduct the initial review of each grant reimbursement to verify that all expenses and receipts contain the correct accounting information, are properly documented, and are recorded in the appropriate accounts within the Financial Management System (FMS). The Corporation Treasurer (or designee) will perform an independent secondary review of all grant reimbursements, including a review of supporting documentation and account coding, and will provide final approval and signature as evidence of authorization. On a monthly basis, grant accounts will be reviewed by the grants administrator for accuracy and completeness, with the Corporation Treasurer (or designee) conducting a secondary monthly review to confirm accuracy and compliance. This two-level review process ensures adequate segregation of duties, strengthens internal controls, and provides documented oversight of all grant reimbursement activity. Anticipated Completion Date: The ESSER grant is finished. If we were to receive this grant in the future, Silver Creek School Corporation would apply the procedures in the corrective action plan.

View Audit 390679

Finding 1176828 (2025-003)

Material Weakness 2025

Silver Creek School Corporation

IN

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2025-003 Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views...

FINDING 2025-003 Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation will implement and consistently apply a standardized two-level review and approval process for all grant reimbursements to ensure proper accounting, documentation, and compliance. The grants administrator (or designee) will prepare and conduct the initial review of each grant reimbursement to verify that all expenses and receipts contain the correct accounting information, are properly documented, and are recorded in the appropriate accounts within the Financial Management System (FMS). The Corporation Treasurer (or designee) will perform an independent secondary review of all grant reimbursements, including a review of supporting documentation and account coding, and will provide final approval and signature as evidence of authorization. On a monthly basis, grant accounts will be reviewed by the grants administrator for accuracy and completeness, with the Corporation Treasurer (or designee) conducting a secondary monthly review to confirm accuracy and compliance. This two-level review process ensures adequate segregation of duties, strengthens internal controls, and provides documented oversight of all grant reimbursement activity. Anticipated Completion Date: The ESSER grant is finished. If we were to receive this grant in the future, Silver Creek School Corporation would apply the procedures in the corrective action plan.

View Audit 390679

Finding 1176813 (2025-003)

Material Weakness 2025

Rural Resources Community Action

WA

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness

FINDING 2025-003 – Reporting Material Weakness in Internal Control over Compliance and Instance of Material Noncompliance Views of responsible officials and planned corrective actions: Management agrees with the assessment. To address this issue, management has reinforced and formalized its reportin...

FINDING 2025-003 – Reporting Material Weakness in Internal Control over Compliance and Instance of Material Noncompliance Views of responsible officials and planned corrective actions: Management agrees with the assessment. To address this issue, management has reinforced and formalized its reporting reconciliation controls. All financial and performance reports submitted for WIOA programs will be reconciled to supporting documentation prior to submission. Management has clarified roles and responsibilities to ensure that report preparation and review are performed by separate individuals. All reports required by contract must be submitted timely and must include two levels of documented review. Reports will be reviewed by the preparer’s Director (or their designee); if the Director is the preparer, the review will be conducted by the Chief Operating Officer or in their absence, the Chief Executive Officer. All financial reports required by contract must have documented review by a member of the fiscal department. Supporting documentation related to report reconciliations will be retained to ensure traceability and availability for review. During the year, the department experienced a leadership transition, and the new Director is receiving additional training on reporting requirements and internal control expectations. Management will also provide periodic training to staff involved in report preparation and review to reinforce control requirements and expectations. Management expects significant improvement for the fiscal year ending in 2026. Contact Persons: Ryan Berendsen, Chief Operating Officer Delana Kromer, Controller

View Audit 390662

Finding 1176751 (2025-004)

Material Weakness 2025

Crothersville Community Schools

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2025-004 Finding Subject: COVID-19 - Education Stabilization Fund - Earmarking Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Ellen Prince and Chrystal Street Contact Phone Number and Email Address: ellenprince@crothersville.k12.in.us; c...

FINDING 2025-004 Finding Subject: COVID-19 - Education Stabilization Fund - Earmarking Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Ellen Prince and Chrystal Street Contact Phone Number and Email Address: ellenprince@crothersville.k12.in.us; cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district has implemented enhanced documentation procedures requiring written justification for all future ESSER-funded purchases, including identification of the program purpose and connection to learning loss when applicable. The district’s centralized grant binder will serve as the official tracking document for federal programs. The binder includes grant identification details, funding source, compliance requirements, and expenditure documentation. Anticipated Completion Date: January 2026

View Audit 390661

Finding 1176718 (2025-002)

Material Weakness 2025

Pensdale Housing, Inc.

CA

Subrecipient Monitoring Eligibility HUD Housing Programs

Comments on the Finding and Each Recommendation The Property received a NSPIRE inspection dated August 1, 2024. The inspection resulted in a score of 59 (out of a possible 100). Scores below 60 are referred to the Departmental Enforcement Center. Management must maintain the Property in decent, safe...

Comments on the Finding and Each Recommendation The Property received a NSPIRE inspection dated August 1, 2024. The inspection resulted in a score of 59 (out of a possible 100). Scores below 60 are referred to the Departmental Enforcement Center. Management must maintain the Property in decent, safe, and sanitary condition and good repair. Management must respond to HUD in three days of receiving the inspection report and confirm all lifethreatening deficiencies have been corrected. Action(s) taken or planned on the finding Management and the Board of Directors concur with the finding and the auditor's recommendations. Management has responded to HUD in regard to this inspection report and on July 8, 2025 another inspection was conducted that resulted in a final score of 95 (out of a possible 100).

View Audit 390616

Finding 1176716 (2025-001)

Material Weakness 2025

Pensdale Housing, Inc.

CA

Subrecipient Monitoring

Comments on the Finding and Each Recommendation The Form SF-SAC Single Audit Data Collection Form for the year ended May 31, 2022 was not submitted to the federal audit clearinghouse in the required timeframe. The Corporation should submit the Form SF-SAC Single Audit Data Collection Forms for the y...

Comments on the Finding and Each Recommendation The Form SF-SAC Single Audit Data Collection Form for the year ended May 31, 2022 was not submitted to the federal audit clearinghouse in the required timeframe. The Corporation should submit the Form SF-SAC Single Audit Data Collection Forms for the year ended May 31, 2022 as soon as practical. Action(s) taken or planned on the finding Management and the Board of Directors concur with the finding and the auditor's recommendations. Form SF-SAC Single Audit Data Collection Form for the year ended May 31, 2022 will be submitted to the federal audit clearinghouse as soon as practical.

View Audit 390616

Finding 1176647 (2025-002)

Material Weakness 2025

Vanderbilt University Medical Center

TN

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

Federal Program: Department of Homeland Security Assistance Listing: 97.036 Federal Agency: COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Entity: State of Tennessee Grant Award Number: All FEMA Projects (Projects 435263,550461, 684580) Award Per...

Federal Program: Department of Homeland Security Assistance Listing: 97.036 Federal Agency: COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Entity: State of Tennessee Grant Award Number: All FEMA Projects (Projects 435263,550461, 684580) Award Period: Project 435263: 1/1/2020-7/31/2021 Project 550461: 1/1/2020-7/31/2021 Project 684580: 8/1/2020-6/30/2022 Management understands that additional audit evidence must be retained at a detailed enough level to allow the auditor to meet their reperformance standard. All expenses claimed were eligible and were reviewed by management prior to the submission. The control issue identified is due to the lack of evidence to support approval. Should management have a future FEMA claim we will retain additional audit evidence to enable auditor reperformance of the controls regarding approval of expenditures. Paula Yarbrough, VUMC Director – Grants and Contracts will be responsible for the implementation by fiscal year-end 2026.

View Audit 390522

Finding 1176646 (2025-001)

Material Weakness 2025

Vanderbilt University Medical Center

TN

Subrecipient Monitoring Procurement, Suspension & Debarment Reporting § 200.303

Federal Program: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing: 93.110 Federal Agency: Maternal and Child Health Federal Consolidated Programs (MCH) Grant Award Number: 5 T73MC30767-09 Award Period: 7/1/2024-6/30/2025 Management ...

Federal Program: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing: 93.110 Federal Agency: Maternal and Child Health Federal Consolidated Programs (MCH) Grant Award Number: 5 T73MC30767-09 Award Period: 7/1/2024-6/30/2025 Management agrees with the finding and has strengthened our internal controls and procedures to ensure required FFATA reports are submitted timely in compliance with the Federal Transparency Act. Paula Yarbrough, VUMC Director – Grants and Contracts will be responsible for the implementation by fiscal year-end 2026.

View Audit 390522

Finding 1176645 (2025-011)

Material Weakness 2025

Second Judicial District Court

NM

Subrecipient Monitoring Reporting Significant Deficiency

The agency concurs with this finding as the documents provided by the agency showed that some contracts that were modified and met the required threshold for FFATA reporting was not done when the modifications were approved. FFATA reporting has been done by the agency but a breakdown in the reportin...

The agency concurs with this finding as the documents provided by the agency showed that some contracts that were modified and met the required threshold for FFATA reporting was not done when the modifications were approved. FFATA reporting has been done by the agency but a breakdown in the reporting process by the agency did not include reporting contracts that has modification. The agency is revising internal policies and procedures to ensure all staff responsible for FFATA reporting understand that all contracts, including contracts that have modifications that increase funding up to the threshold of FFATA reporting, must be included in the FFATA reporting. Continuous training will be done for all financial staff responsible for FFATA training.

View Audit 390502

Finding 1176644 (2025-010)

Material Weakness 2025

Second Judicial District Court

NM

Subrecipient Monitoring § 200.332

The agency concurs with this finding as subrecipient monitoring has increased significantly with increase federal funding award to the agency. Subrecipient monitoring has been in place but with new staff being hired the agency processes were not monitored and followed to ensure subrecipient monitori...

The agency concurs with this finding as subrecipient monitoring has increased significantly with increase federal funding award to the agency. Subrecipient monitoring has been in place but with new staff being hired the agency processes were not monitored and followed to ensure subrecipient monitoring requirements were completed. The agency is in the process of strengthening its policies as they are related to subrecipient monitoring. The agency is in the process of reviewing and strengthening its internal policy related to subrecipient monitoring. The agency is working with the State Controller’s Office to include subrecipient monitoring training which will take place in early 2026. The agency is implementing standardized processes to include subrecipient checklist that will be included in all agreements that will identify if the agreement is a subrecipient or contract. The agency is working to ensure all agreement templates have correct subrecipient language Per 2 CFR §200.332 prior to submission for signatures.

View Audit 390502

Finding 1176629 (2025-001)

Material Weakness 2025

Brooklyn Law School

NY

Student Financial Aid Subrecipient Monitoring Reporting

Brooklyn Law School Single Audit Corrective Action Plan For the Year Ending June 30, 2025 Section III - Federal Awards Findings and Questioned Costs Finding 2025-001: Significant Deficiency - NSLDS Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of a...

Brooklyn Law School Single Audit Corrective Action Plan For the Year Ending June 30, 2025 Section III - Federal Awards Findings and Questioned Costs Finding 2025-001: Significant Deficiency - NSLDS Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary of the Department of Education (Secretary), institutions must update all information included in the report and return the report to the Secretary: (I) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless the institution expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The Law School did not notify the National Student Loan Data System (NSLDS) in a timely manner for 23 students with status changes in our sample of 25 students. For 2 out of 25 students selected in the sample, the effective date that was reported to the NSLDS did not match the date that the student changed status. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The Law School's controls surrounding the reporting of students’ statuses and status effective dates to the NSLDS did not appropriately ensure the information was submitted accurately or timely. Effect: The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: We recommend that the Law School review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the Law School to ensure accurate and timely reporting. Management Response: Management agrees with the finding, The Director of Financial Aid and the Registrar will implement procedures and controls in fiscal 2026 to ensure accurate and timely updating of the enrollment reports to NSLDS. Anticipated Completion Date: June 30, 2026 Responsible Person: John K. Zhang, Vice President for Finance and Board Treasurer (718)-780-7503 - john.zhang@brooklaw.edu

View Audit 390480

Finding 1176625 (2025-008)

Material Weakness 2025

Oregon Association of Relief Nurseries

OR

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles § 200.305

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the sub...

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the subrecipient's behalf. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective October 1, 2025, all subrecipients were notified that payments would be made only to them, requiring them to directly pay their contractors and vendors. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: October 1, 2025

View Audit 390474

Finding 1176622 (2025-005)

Material Weakness 2025

Oregon Association of Relief Nurseries

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring the review and approval of performance, with such review and approval clearly documented. Ex...

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring the review and approval of performance, with such review and approval clearly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective January 1, 2026, the Executive Director will review a PDF copy and document approval via email of OARN's Semi-Annual Progress Reports prior to uploading into the EHB. Name(s) of the contact person(s) responsible for corrective action: Kendra Jones, Executive Director Planned completion date for corrective action plan: January 1, 2026

View Audit 390474

Finding 1176620 (2025-003)

Material Weakness 2025

Oregon Association of Relief Nurseries

OR

Procurement, Suspension & Debarment Subrecipient Monitoring

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend the Association design controls to ensure an adequate review process is in place to review potential subrecipients, contractors, or vendors to determine they are no...

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend the Association design controls to ensure an adequate review process is in place to review potential subrecipients, contractors, or vendors to determine they are not suspended or debarred prior to entering into transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OARN's vendor approval process has included the following steps:● Review and Verification: Review the Vendor Approval Form to ensure it is complete and includes all necessary documentation. Verify that the vendor is not excluded from receiving federal contracts by checking for debarment on SAM.gov. ● Decision: Approve or deny the Approval Form. ● Communication and Record-Keeping: Return a signed and dated copy to the vendor, indicating approval or denial. Enter information for all approved vendors into the grant management tracking system. OARN recognizes that an essential best practice for federal compliance is conducting semi-annual checks on SAM.gov to confirm a vendor's continued eligibility for federal funds. Effective January 1, 2026, OARN implemented a policy to review all vendors' status on SAM.gov. This initial review is scheduled for completion by February 28, 2026. A subsequent review will take place in July 2026 for any vendors involved in projects that are still ongoing. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: February 28, 2026

View Audit 390474

Finding 1176619 (2025-002)

Material Weakness 2025

Oregon Association of Relief Nurseries

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement policies and procedures to ensure the performance of subrecipient monitoring and that the monitoring is formally documented and appro...

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement policies and procedures to ensure the performance of subrecipient monitoring and that the monitoring is formally documented and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OARN's current monitoring of Subrecipients has included reviewing budgets and progress reports, approving vendors, and processing drawdown requests to confirm the appropriate use of subaward funds in compliance with Federal regulations and subaward terms. However, OARN recognizes the need for a more comprehensive review process to ensure full subrecipient compliance. Therefore, we plan to request audits or financial reviews from all subrecipients. We will also require documentation demonstrating that the subrecipient has taken prompt and necessary corrective action in response to any deficiencies identified through audits, on-site reviews, or other methods related to the Federal program. OARN has created and will maintain a Subrecipient Monitoring and Approval Form that tracks receipt and review of 1) audit reports and corrective actions along with 2) checks on SAM.gov to confirm the subrecipient's continued eligibility for federal funds. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: March 30, 2026

View Audit 390474

Finding 1176608 (2025-002)

Material Weakness 2025

Rushmore Electric Power Cooperative, Inc.

SD

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

Finding 2025-002: Internal Controls over Compliance Responsible Individuals: Mark Miller, Accounting Manager Corrective Action Plan: Management is currently implementing review procedures and proper oversight of compliance. Anticipated Completion Date: 2026

View Audit 390424

Finding 1176593 (2025-002)

Material Weakness 2025

Sabin Group 1 Hud Project No. 101-Hh003-Np-Cmi-L8

CO

HUD Housing Programs Subrecipient Monitoring Eligibility

February 25, 2026 CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2025 AUDITOR FINDING: 2025-002 – AL# 14.157 Supportive Housing for the Elderly (Section 202) Area: Eligibility In accordance with 24 CFR section 891.410, section 5.230, and OMB No. 2502-0204, owner shall re-examine tenant elig...

February 25, 2026 CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2025 AUDITOR FINDING: 2025-002 – AL# 14.157 Supportive Housing for the Elderly (Section 202) Area: Eligibility In accordance with 24 CFR section 891.410, section 5.230, and OMB No. 2502-0204, owner shall re-examine tenant eligibility at least every 12 months with respect to family income, composition and is required to obtain signed consent forms from assistance applicants. In accordance with HUD Multifamily Occupancy Handbook, Chapter 7, annual certification should be completed and submitted through TRACS within 15 months from previous year’s anniversary date. Based on testing performed recertifications did not occur within the required time period. It is recommended to add monitoring controls to help ensure recertifications are completed in accordance with 24 CFR section 891-410, section 5.230, and OMB No. 2502-0204. CLIENT PLANNED ACTION: (1) Annual recertification report will be reviewed monthly with ComCap Management to ensure timely completion of all recertifications. Demands will be given to tenants if recertifications are not completed within 60 days of initial notification. (2) Monthly dashboards will continue to be produced and reviewed with ComCap Management. The monthly dashboards include annual recertifications, occupancy/vacancy, and move-in/move-outs. CLIENT RESPONSIBLE PARTY: Darla Goddard, Director of Real Estate COMPLETION DATE: 01/01/2026

View Audit 390410

Finding 1176555 (2025-002)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Reporting Internal Control / Segregation of Duties

Corrective Action Plan: To address the deficiencies identified in Finding 2025-002, the University has implemented and is continuing to formalize a comprehensive corrective action strategy focused on strengthening disbursement scheduling, improving system integration, institutionalizing reconciliati...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-002, the University has implemented and is continuing to formalize a comprehensive corrective action strategy focused on strengthening disbursement scheduling, improving system integration, institutionalizing reconciliation and quality assurance processes, and enhancing cross-functional oversight of COD reporting. Primary Control Enhancements. A standardized disbursement and reporting calendar has been established, and system integration between Ellucian Colleague and Jenzabar has been strengthened to improve consistency of cost-of-attendance and disbursement data transmitted to COD. For the 2025–2026 academic year, the Office of Financial Aid and the Office of Student Accounts are disbursing Title IV aid on the second and fourth Tuesday of each month. This schedule has been jointly approved and will continue to be followed by both departments to ensure consistency between disbursement activity and COD reporting. Supporting Controls and Training. Staff participate in targeted training related to COD reporting and cash management through NASFAA and FSA to reinforce knowledge of reporting timelines and requirements. Monitoring and Quality Assurance. A formal financial aid compliance calendar has been developed and institutionalized, outlining required quality assurance (QA) reviews by month, identifying responsible departments, and requiring documented supervisory sign-off. Reviews of COD reporting timelines are conducted twice per semester, and any discrepancies identified are documented, reviewed, and resolved in a timely manner. A systematic monthly reconciliation process has been instituted and is maintained involving the Office of Financial Aid, the Office of Student Accounts, and Budgets & Grants Accounting to ensure consistency across internal systems and COD reporting. Sustained Oversight. Any discrepancies identified through reconciliation are documented, communicated to relevant departments, and resolved, with formal supervisory sign-off required from the Assistant Director of Financial Aid and the Director of Budgets & Grants Accounting. In addition, Financial Aid maintains standing bi-weekly coordination meetings with Student Accounts and Business Office staff to support ongoing alignment related to Title IV disbursement activity and COD reporting timelines. Anticipated Completion Date: June 2026

View Audit 390365

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