Corrective Action Plans

Finding 1205707 (2025-006)

Material Weakness 2025

Paine College

GA

Student Financial Aid Internal Control / Segregation of Duties Questioned Costs

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns.

View Audit 397416

Finding 1205703 (2025-005)

Material Weakness 2025

Paine College

GA

Student Financial Aid Questioned Costs Subrecipient Monitoring

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. Corrective Action 2025-005: Administrative and Fiscal Affairs 1235 Fifteenth Street, Augusta, GA 30901 Implement the Return to Title IV monitoring system, weekly credit balance tracking, counseling verification procedures, and strengthen coordination between Financial Aid, Registrar, and Business Office Target resolution: Spring-Summer 2026

View Audit 397416

Finding 1205691 (2025-001)

Material Weakness 2025

Miles College

AL

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

Finding 2025 - 001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): Information on the federal program - (Federal Award Identification): - Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL ...

Finding 2025 - 001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): Information on the federal program - (Federal Award Identification): - Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025. Institutions must determine a student's financial need by subtracting the expected family contribution and estimated financial assistance from the cost of attendance. 34 CFR 668.2 and 34 CFR 637.S(a). 1. Corrective Action Description The College has engaged a financial aid consultant to support the development of cost-of-attendance budgets and ensure they align with industry best practices, thereby making improvements to the College's financial aid operating system. After evaluating the auditors' sample of forty students, the College confirmed that no instances of over/under awarding occurred. There were clarifications and changes made to the initial cost of attendance budgets provided to the auditors that led to the questioned cost. The College will implement ongoing monitoring each semester to further enhance operational efficiency and effectiveness. The cost of attendance budgets has been uploaded into the College's financial aid system to prevent the recurrence of this issue for the current and future years. a. Responsible Person and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu b. Implementation Timeline January 18, 2026, for the spring semester c. Planned Preventive Measures The College hired a financial aid consultant to assist the financial aid Director with best practices and to make modifications to the ERP system to provide better operating efficiency and effectiveness. d. Disagreement with the Finding None

View Audit 397405

Finding 1205671 (2025-001)

Material Weakness 2025

Madison Interfaith Residential Community, Inc.

CT

Subrecipient Monitoring Reporting

Management acknowledges the finding regarding the replacement reserve account not being funded at the minimum level required by the USDA‑RD approved budget. To address this issue, the Project will make a deposit to fully restore the replacement reserve to the required threshold in accordance with US...

Management acknowledges the finding regarding the replacement reserve account not being funded at the minimum level required by the USDA‑RD approved budget. To address this issue, the Project will make a deposit to fully restore the replacement reserve to the required threshold in accordance with USDA‑RD guidelines. In addition, we will continue to monitor reserve balances throughout the year and communicate with USDA‑RD if significant variances arise.

View Audit 397381

Finding 1205660 (2025-001)

Material Weakness 2025

Pyramid Learning Corp.

PR

Subrecipient Monitoring

CORRECTIVE ACTION PLAN In past years the accounting services provided to Pyramid Learning Corp. were contracted and external accounting companies. We acquired specialized accounting software to be utilized internally. Since we started utilizing this new software, our staff has made significant effor...

CORRECTIVE ACTION PLAN In past years the accounting services provided to Pyramid Learning Corp. were contracted and external accounting companies. We acquired specialized accounting software to be utilized internally. Since we started utilizing this new software, our staff has made significant efforts to update the system. However, the data needed to fully update the new accounting and financial software labor intensive and time consuming making it difficult to maintain a month to month database. Currently with the new system all the new current data has been recorded and is up to date. This new system provides us with the capability to maintain accounting and financial reports such as Balance Sheets, Statements Activities and Bank Reconciliation forms. Thus, providing a monthly snapshot of all the company accounts with the most current information. Improving transparency and the capacity to correct any discrepancies in a timely manner.

View Audit 397354

Finding 1205645 (2025-009)

Material Weakness 2025

Tougaloo College

MS

Eligibility Internal Control / Segregation of Duties Questioned Costs

Finding 2025-009-U.S. Department of Education (ED) TRIO Cluster Programs (significant deficiency) Information on the federal program-Educational Talent Search, FAL 84.044A This memorandum serves as management’s response to the audit finding regarding internal control weaknesses in participant eligib...

Finding 2025-009-U.S. Department of Education (ED) TRIO Cluster Programs (significant deficiency) Information on the federal program-Educational Talent Search, FAL 84.044A This memorandum serves as management’s response to the audit finding regarding internal control weaknesses in participant eligibility documentation for the Educational Talent Search Program under 34 CFR § 643.3. Acknowledgment of Finding Management acknowledges the condition identified in which two participants’ applications lacked incorrect information to verify age eligibility requirements. Management notes, this condition reflects a perceived control weakness that may impact compliance with TRIO Talent Search Program requirements. Management Response During the initial application process, parent and student data is entered into a system-generated application. Management acknowledges that, in instances where inaccurate information is entered (e.g., date of birth), established procedures require verification against official documentation, such as the student’s transcript. Supporting documentation for Shayla Adams and Madison Wallace is provided as evidence. Upon identifying omissions or incorrect information during the review process, management verifies the applicants’ information directly with the participants’ school as part of the secondary review process. Official documentation is obtained and reviewed, and the verified date of birth is recorded as documented on the students’ official transcripts and maintained in the participant files. The applicants’ information is entered correctly in the student database (Blumen) prior to acceptance, ensuring compliance with eligibility documentation requirements under 34 CFR § 643.3. Management is committed to addressing this issue promptly and strengthening internal controls to ensure full compliance with federal regulations. Procedures governing participant intake, eligibility verification, documentation retention, and supervisory oversight will be consistently monitored. These measures include standardized processes, increased staff accountability, and ongoing monitoring to maintain program integrity. Corrective Action Plan 1. Standardized Eligibility Verification Process A comprehensive eligibility checklist will be implemented and required for all participant files to ensure consistent documentation collection and verification prior to acceptance. Before an acceptance letter is provided to students, and the information is entered into Blumen, birthdates will be checked by the school transcript. Responsible Party: Assistant Director and Program Director Implementation Date: Immediately upon receiving the application 2. Secondary Review and Approval Control A mandatory secondary review process will continue. Participants’ acceptance will not be approved until all eligibility documentation is verified as accurate complete. Responsible Party: Assistant Director Accountable: Program Director Implementation Date: Immediate 3. Staff Training and Procedure Reinforcement All staff will participate in mandatory training on eligibility requirements and documentation standards. Written procedures and required intake documentation will be provided to reinforce compliance expectations. Responsible Party: Assistant Director and Program Director Accountable: Program Director Implementation Date: Monthly 4. Documentation Tracking System Management will implement a tracking procedure to identify and monitor missing or incomplete documentation, ensuring deficiencies are resolved prior to participant approval. Responsible Party: Assistant Director and Senior Counselors Accountable: Program Director Implementation Date: Immediately upon receiving the application 5. Ongoing Monitoring and Internal Reviews Quarterly internal file reviews will be conducted to assess compliance with eligibility requirements. Findings will be documented and corrective actions enforced. Responsible Party: Assistant Director and Senior Counselor Accountable : Program Director Implementation Date: Quarterly 6. Documentation Retention Controls Uniform file management protocols will be established to ensure all eligibility documentation is properly maintained, organized, and readily accessible. Responsible Party: Assistant Director Accountable Program: Director Implementation Date: Ongoing Conclusion Management takes this matter seriously and is committed to ensuring that all corrective actions are fully implemented within the stated timeframes. These measures are designed to strengthen internal controls, ensure compliance with federal requirements, and enhance the integrity of participant eligibility determinations. The College has already initiated corrective action by hiring entirely new staff in key positions and is committed to fostering a culture of compliance through rigorous procedures and training. 1. Staff Expertise: Financial Aid team members are becoming certified in the enterprise resource program module, specifically related to financial aid, as a first step. 2. SOP Implementation: The core of this plan involves the creation of seven new or updated Standard Operating Procedures (SOPs) (as highlighted above) to standardize compliance activities and reduce reliance on individual employee experience. 3. Proactive Monitoring: We are implementing mandatory monthly and quarterly reconciliation and audit reports to ensure adherence to timelines and documentation requirements, moving from reactive to proactive compliance management. 4. Cross-Training: Training will be conducted across multiple departments (Financial Aid, Business Office, Registrar) to ensure shared understanding and accountability for Title IV compliance.

View Audit 397293

Finding 1205637 (2025-001)

Material Weakness 2025

Tougaloo College

MS

Student Financial Aid Eligibility Internal Control / Segregation of Duties

Finding 2025-001 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Satisfactory Academic Progress (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit for the fiscal year ending June 30, ...

Finding 2025-001 U.S. Department of Education (USDE), Title IV Student Financial Aid Programs – Satisfactory Academic Progress (material weakness): Management’s Response and Corrective Action Plan Tougaloo College acknowledges the findings identified in the audit for the fiscal year ending June 30, 2025, regarding Finding 2025-001 (Material Weakness). We recognize the gravity of the systemic issues related to the monitoring of Satisfactory Academic Progress (SAP) and the associated questioned costs of $346,764.00. The College is committed to full compliance with 34 CFR 668.34 and is implementing the following corrective actions to ensure the integrity of our Title IV Student Financial Aid Programs. • Automation and System Integration: The College is transitioning from manual SAP monitoring to an automated tracking system within our Student Information System (SIS). This will ensure that academic standing—specifically GPA and completion rates are calculated systematically at the end of each Spring Semester. • Audit of Appeal Documentation: We are establishing a centralized digital repository for all SAP appeals. Effective immediately, no Title IV funds will be disbursed to students on financial aid probation without a documented, approved appeal and a corresponding academic plan on file. • Staff Training and Accountability: The Office of Financial Aid will undergo mandatory training focused specifically on federal SAP criteria. We have revised our internal "Check and Balance" protocol, requiring a secondary review by the Director of Financial Aid before any student failing SAP is cleared for disbursement. • Annual Policy Review: In alignment with the Auditor’s Recommendation, Tougaloo College will conduct a comprehensive annual evaluation of all students. This evaluation will be reconciled against the Registrar’s records to ensure data consistency. • We have updated our SAP policy to allow us to review at end of each Spring The College has already begun the look-back process to review the eligibility of the 16 students identified in the sample. We anticipate that the new automated monitoring and revised internal controls will be fully operational by the start of the Fall 2026 semester to prevent any further repeat findings.

View Audit 397293

Finding 1205577 (2025-004)

Material Weakness 2025

County of San Joaquin

CA

Subrecipient Monitoring § 200.332 § 200.502

The County acknowledges the importance of proper documentation for subrecipient monitoring. To address this finding, the County will implement the following: 1. Enhanced Review Process – County departments responsible for subrecipient agreements will conduct a thorough review of subrecipient monitor...

The County acknowledges the importance of proper documentation for subrecipient monitoring. To address this finding, the County will implement the following: 1. Enhanced Review Process – County departments responsible for subrecipient agreements will conduct a thorough review of subrecipient monitoring activities to ensure compliance with federal and regulations. This will include verifying that all required monitoring steps, including risk assessments and are properly conducted and documented. 2. Documentation and Record-Keeping Improvements – County departments will be required to maintain clear and consistent documentation of all subrecipient monitoring activities. This includes risk assessments, financial reports, site visit records (if applicable), and any corrective actions taken.

View Audit 397280

Finding 1205573 (2025-002)

Material Weakness 2025

Prince George's County, MD

MD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: a. Utilizing the verification method of checking SAM.gov Exclusions provided in 2 CFR 180.300 (a), the County determined that no contracts were awarded to any individ...

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: a. Utilizing the verification method of checking SAM.gov Exclusions provided in 2 CFR 180.300 (a), the County determined that no contracts were awarded to any individual, firm or organization debarred from Government contracts pursuant to 2 CFR 200.332 (a). Note this finding did not determine any contracts were awarded improperly by the County or the Clean Water Partnership. b. The County is in the process of its procedures and internal controls with the Clean Water Partnership to ensure that all vendors’ suspension and debarment status will be verified utilizing the methods provided in 2 CFR 180.300 prior to all contract awards, as well as in conformance with state and local laws. The Clean Water Partnership is in the process of developing the documentation required for the certifications and clauses and conditions requirements for each covered transaction. Name(s) of the contact person(s) responsible for corrective action: James Lyons Planned completion date for corrective action plan: May 31, 2026

View Audit 397259

Finding 1205546 (2025-001)

Material Weakness 2025

National Park Foundation

DC

Subrecipient Monitoring Reporting Questioned Costs § 200.303

2025-001 – Internal Control over Compliance and Compliance with Reporting Contact Name: Bryant Davis Position: Controller Telephone Number: (202) 796 2500 Corrective Action Plan – Management will continue to work with Federal agencies to resolve any grants that a FAIN was not issued. Estimated Compl...

2025-001 – Internal Control over Compliance and Compliance with Reporting Contact Name: Bryant Davis Position: Controller Telephone Number: (202) 796 2500 Corrective Action Plan – Management will continue to work with Federal agencies to resolve any grants that a FAIN was not issued. Estimated Completion – September 30, 2026

View Audit 397243

Finding 1205539 (2025-002)

Material Weakness 2025

THE NETWORK OF BEHAVORIAL HEALTH PROVIDERS, INC.

TX

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Subrecipient Monitoring

Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing #: 21.027, Contract #: 220163. Condition and context: In testing 1 out of 6 vendors subject to ...

Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing #: 21.027, Contract #: 220163. Condition and context: In testing 1 out of 6 vendors subject to procurement, NBHP had not verified and documented that the Houston Health Department was not suspended or disbarred. Recommendation: Amend the procurement policy to require verification that person or organization is not suspended or disbarred. Planned corrective action: NBHP will modify its procurement policy to include verification that persons or organizations are not suspended or disbarred. Responsible officer: Lisa Albert, Executive Director. Estimated completion date: April 30, 2026.

View Audit 397225

Finding 1205518 (2025-004)

Material Weakness 2025

Michigan City Area Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2025-004 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We wil...

FINDING 2025-004 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure the proper documentation is in place for any students removed from the graduation cohort. Anticipated Completion Date: We anticipate that this correction will be in place by August 2026

View Audit 397194

Finding 1205499 (2025-003)

Material Weakness 2025

Trustees of the College of the Holy Cross

MA

Allowable Costs / Cost Principles Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.430

Corrective Action Plan: The identified conditions related to timesheets for hourly employees. To mitigate the risk of missing approval documentation for payroll charged to Federal R&D awards, the College is formalizing procedures requiring PI or supervisor review of applicable timesheets, configurin...

Corrective Action Plan: The identified conditions related to timesheets for hourly employees. To mitigate the risk of missing approval documentation for payroll charged to Federal R&D awards, the College is formalizing procedures requiring PI or supervisor review of applicable timesheets, configuring the approval workflow in Workday to require and retain evidence of approval, and implementing periodic monitoring to identify and correct missing approvals. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented before the end of fiscal year 2026.

View Audit 397172

Finding 1205485 (2025-001)

Material Weakness 2025

Metropolitan Familly Services

IL

Procurement, Suspension & Debarment Reporting Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN FOR FINDING 2025-001 Identifying Number: 2025-001 Finding: For the Federal Award Identification Number: 84.215, contract number (S215J230147), the reporting requirement for FFAFTA reporting, due August 31, 2024 was not met. Required reporting was submitted on January 28, 2026,...

CORRECTIVE ACTION PLAN FOR FINDING 2025-001 Identifying Number: 2025-001 Finding: For the Federal Award Identification Number: 84.215, contract number (S215J230147), the reporting requirement for FFAFTA reporting, due August 31, 2024 was not met. Required reporting was submitted on January 28, 2026, which was after the submission due date. Corrective Action Taken: Metropolitan Family Services will implement a process to ensure new contracts are reviewed so we are adhering to reporting requirements. The Assistant Budget Directors have been notified to review the reporting requirements more closely. The initial review of the reporting requirements will be conducted by the Assistant Budget Directors, and a final review will be by the Budget Director. Responsible Individuals: This will be completed by the following Assistant Budget Directors: Casey Maher Leticia Reyes Jeff Sklenar Emilia Vargas Gaz Meni Ramiro Chavez Reviews will be performed by the Budget Director (Don Pyznarski). Anticipated Completion Date: The anticipated completion date is June 1, 2026.

View Audit 397170

Finding 1205467 (2025-001)

Material Weakness 2025

Southwest Region Planning Commission

NH

Reporting Subrecipient Monitoring § 200.501 § 200.510

Corrective Action Planned: The auditee acknowledges that it did not have adequate procedures in place to identify all federal funding sources, track cumulative federal expenditures, and determine the applicability of Single Audit requirements.• Federal Funding Identification Procedures: Establish fo...

Corrective Action Planned: The auditee acknowledges that it did not have adequate procedures in place to identify all federal funding sources, track cumulative federal expenditures, and determine the applicability of Single Audit requirements.• Federal Funding Identification Procedures: Establish formal procedures to review all grant agreements, contracts, and funding documents to identify federal funding sources, including Assistance Listing (ALN) numbers and pass-through entity information. • Centralized Tracking of Federal Expenditures: Implement a tracking mechanism ( e.g., spreadsheet or accounting system enhancement) to record and monitor all federal expenditures by program throughout the fiscal year. • Periodic Monitoring of Single Audit Threshold: Perform quarterly reviews of cumulative federal expenditures to determine whether the dollar threshold (currently $1 million) for a Single Audit has been met. • SEFA Preparation and Review Controls: Develop a standardized process for preparing the Schedule of Expenditures of Federal Awards (SEFA), including a supervisory review to ensure completeness and accuracy prior to issuance. • Training and Awareness: Provide training to key personnel involved in financial reporting and grant management on Uniform Guidance requirements, including SEFA preparation and Single Audit thresholds. Anticipated Completion Date: September 30, 2026 Planned Monitoring and Follow-Up: Management will periodically review compliance with the new procedures and controls to ensure that all federal funding is properly identified, tracked, and reported, and that Single Audit requirements are evaluated timely.

View Audit 397142

Finding 1205464 (2025-001)

Material Weakness 2025

Vocational Education and Extension Board of the County of Nassau, Ny

NY

Student Financial Aid Questioned Costs Subrecipient Monitoring

Management agrees with the finding and has indicated that corrective actions will be implemented to improve monitoring and timeliness of R2T4 returns. Management’s corrective action plan is included in the accompanying schedule.

View Audit 397139

Finding 1205449 (2025-002)

Material Weakness 2025

Notre Dame of Maryland University, INC

MD

Questioned Costs Special Tests & Provisions Student Financial Aid

Management Response The University concurs with this finding. Management has reviewed its processes for monitoring and issuing Title IV credit balance refunds and has implemented procedures to ensure refunds are processed within the required 14-day timeframe. The Financial Aid and Student Accounts o...

Management Response The University concurs with this finding. Management has reviewed its processes for monitoring and issuing Title IV credit balance refunds and has implemented procedures to ensure refunds are processed within the required 14-day timeframe. The Financial Aid and Student Accounts offices will review credit balance reports on a regular basis to identify students eligible for refunds and confirm timely disbursement. In addition, staff have been reminded of federal requirements related to credit balance refunds. Management will monitor this process periodically to ensure ongoing compliance. Corrective Action The University reviewed the federal requirements for refunds with applicable members of the Business Office and Financial Aid departments to ensure a thorough understanding of the refund rules. The University enhanced its weekly credit balance review process to require explicit review by the Controller and Director of Financial Aid if uncertainty exists on whether a student is eligible for a refund. This review must be completed within the 14 day period with either the refund issued or the loan removed from the student’s account. Contact Person Responsible Name – Richard Jones Title – Controller Phone – 410-532-5367 Email – rjones13@ndm.edu Anticipated Completion Date – April 30, 2026

View Audit 397132

Finding 1205443 (2025-001)

Material Weakness 2025

Marillac Community Health Centers

LA

Special Tests & Provisions Questioned Costs Subrecipient Monitoring

The organization has implemented additional levels of review and prescreening of slide patient data to ensure accuracy and that the data is complete. Routine reviews done by front desk supervisors will be further documented in order to provide additional training to staff as needed. Results of mont...

The organization has implemented additional levels of review and prescreening of slide patient data to ensure accuracy and that the data is complete. Routine reviews done by front desk supervisors will be further documented in order to provide additional training to staff as needed. Results of monthly audits performed by service line leaders will be reported to senior leadership. An internal audit will be done by the compliance team and presented to leadership on a quarterly basis. All appropriate admitting staff will go through training to reinforce our slide process and review procedures for all FQHC services.

View Audit 397122

Finding 1205427 (2025-103)

Material Weakness 2025

County of Yavapai

AZ

Subrecipient Monitoring § 200.344

Improve Controls over Subrecipient Monitoring Name of contact person: Connie DeKemper Anticipated completion date: 06/30/2026 Condition – During our audit, we noted the County did not complete the required monitoring until six months after the fiscal year end. Response - Subrecipient monitoring will...

Improve Controls over Subrecipient Monitoring Name of contact person: Connie DeKemper Anticipated completion date: 06/30/2026 Condition – During our audit, we noted the County did not complete the required monitoring until six months after the fiscal year end. Response - Subrecipient monitoring will be completed during the fiscal year.

View Audit 397094

Finding 1205424 (2025-102)

Material Weakness 2025

County of Yavapai

AZ

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Improve Controls over Earmarking Name of contact person: Connie DeKemper Anticipated completion date: 06/30/2026 Condition – During our audit, we noted that the County utilized 74.4% of the expenditures on out-of-school youth, a deficiency of .6%. Furthermore, the County utilized 15.8% of youth expe...

Improve Controls over Earmarking Name of contact person: Connie DeKemper Anticipated completion date: 06/30/2026 Condition – During our audit, we noted that the County utilized 74.4% of the expenditures on out-of-school youth, a deficiency of .6%. Furthermore, the County utilized 15.8% of youth expenditures for paid and unpaid work experience, a 4.2% deficiency. Response - Expenditures will be reviewed on a monthly basis to ensure earmarking requirements are met. If not, a waiver for the earmarking requirements will be requested from the grantor.

View Audit 397094

Finding 1205421 (2025-101)

Material Weakness 2025

County of Yavapai

AZ

Subrecipient Monitoring Reporting § 200.327

Improve Internal Controls over Reporting Name of contact person: Connie DeKemper Anticipated completion date: 12/31/2026 Condition – During our audit, we noted the quarterly report ended March 31, 2025, was not filed. The expenditures for that period were included on the quarterly report ended June ...

Improve Internal Controls over Reporting Name of contact person: Connie DeKemper Anticipated completion date: 12/31/2026 Condition – During our audit, we noted the quarterly report ended March 31, 2025, was not filed. The expenditures for that period were included on the quarterly report ended June 30, 2025. Response - The County is in the process of reviewing the terms of the subrecipient agreement for reporting and is developing systems for timely reporting.

View Audit 397094

Finding 1205414 (2025-002)

Material Weakness 2025

University of Maryland Medical System Corporation

MD

Questioned Costs Allowable Costs / Cost Principles Cash Management

C. Cash Management; L. Reporting Evidence of Review and Approval of the Reported Expenditures Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressional...

C. Cash Management; L. Reporting Evidence of Review and Approval of the Reported Expenditures Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Health and Human Services Department of Justice Recommendation: Management should reassess the design of its controls to ensure documentation is retained that evidences the review and approval of expenditures submitted to the DOJ and DHHS for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. ORSPA and Corporate Financial Reporting are developing standard operating procedures and policies for the required review and reconciliation of grant expenditures per the accounting system to the financial submissions to the granting agency, including requirements for maintaining evidence of the review(s). A shared central repository for financial submissions was created. For each grant, this repository includes the financial submission and evidence of review and approval of the financial report submissions. The ORSPA and Corporate Financial Reporting will monitor the repository and work with grant managers to ensure evidence of financial submission review and approval is maintained. Anticipated Completion Date – June 30, 2027 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

View Audit 397091

Finding 1205391 (2025-102)

Material Weakness 2025

Pima County

AZ

Cash Management Questioned Costs Procurement, Suspension & Debarment § 200.303 § 200.328 § 200.334

2025-102 The County did not develop internal control procedures over program reporting and cash management requirements, increasing risk of report errors to awarding agencies and wrongly receiving monies Cluster Name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings number...

2025-102 The County did not develop internal control procedures over program reporting and cash management requirements, increasing risk of report errors to awarding agencies and wrongly receiving monies Cluster Name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and program names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award Numbers and years: IGA DI21-002286 July 1, 2024 through June 30, 2025 IGA DI23-002389 July 1, 2023 through June 28, 2028 Assistance Listings numbers and program name: 21.027 COVID-19—Coronavirus State and Local Fiscal Recovery Funds Award Numbers and years: 1505-0271 March 3, 2021 through December 31, 2024 CT-FM-22-149 October 1, 2024 through September 30, 2025 SLFRFP1962 January 5, 2023 through December 31, 2026 CTR069300 January 1, 2024 through December 30, 2026 GTAW-FM-23*123 October 3, 2022 through July 3, 2026 ACJC-VC-25-001A July 1, 2024 through December 31, 2024 Assistance Listings numbers and program name: 93.268 Immunization Cooperative Agreements Award numbers and years: CTR062571 July 1, 2022 through June 30, 2025 CTR059891 July 1, 2022 through June 30, 2027 Name of contact person: Art Cuaron, Director, Finance and Risk Management Anticipated completion date: June 30, 2027 The County recognizes the need to strengthen internal controls over federal reporting and cash management requirements. F&RM will complete the following actions to ensure compliance with 2 CFR Part 200: 1. Establish written internal control policies and procedures for federal program reporting. All federal financial reports will undergo an independently documented review before submission to ensure accuracy, allowability, and proper reporting periods. 2. Implement documentation standards requiring staff to retain supporting materials such as system reports, financial queries, screenshots, and reconciliations, in accordance with federal and County retention requirements. 3. Pima County has been working with each of its grant implementing entities to use Euna Grants calendaring and reminders to prompt the entities’ timely reporting activities. Grants Management and Innovation (GMI) Department sets the reminders schedule at the onset of the performance period. The reminders are then automatically emailed to the grants manager and the assigned accountant for each grant on a set schedule throughout the course of the grant. GMI and Finance – Grants will continue to work with grant implementing entities to use these reminders to trigger the necessary actions in a timely manner. Pima County was still in the process of institutionalizing this system during FY25. 4. Provide training for staff who prepare and review federal reports, focusing on reporting requirements, documentation standards, internal controls, and record retention. 5. Conduct periodic management oversight reviews to confirm that internal controls are followed and that reports are complete, accurate, and submitted on time. The County is also planning to implement the Workday Grants Module with an anticipated go-live of July 1, 2027. This solution will enhance our ability to manage the full fiscal lifecycle of grant awards and ensure compliance with federal reporting requirements. The Workday Grants Module is a native Workday solution, purpose-built to support the full fiscal grant lifecycle. The module supports the following financial grant objectives: • Grant setup and award and fiscal tracking • Cost allocation and allocability controls • Real-time grant financial reporting • Compliance with federal Uniform Guidance (2 CFR 200) • Integration with Workday Financial Management, Procurement and Human Capital Management (HCM) In addition, F&RM has submitted FY 2026/27 budget requests to fund three additional Accountant III positions in our Finance – Grants Division. These positions will expand our capacity to manage our grant portfolio and strengthen our reconciliation, billing and SEFA preparation processes. The contract for the Workday Grants Module is scheduled to go before the Board of Supervisors for approval in April. These new positions will be included in the County Administrator’s Recommended Budget and will be considered by the Board as part of the full budget adoption process in June.

View Audit 397080

Finding 1205372 (2025-003)

Material Weakness 2025

South Carolina State University

SC

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.303

Finding 2025-003 – Reporting – Special Reports for Federal Funding Accountability and Transparency Act (“FFATA”) Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-003 regarding noncompliance with reporting requirements under the Federal Funding Accountabi...

Finding 2025-003 – Reporting – Special Reports for Federal Funding Accountability and Transparency Act (“FFATA”) Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-003 regarding noncompliance with reporting requirements under the Federal Funding Accountability and Transparency Act. Specifically, the University did not submit a first-tier subaward agreement/amendment/modification within the required timeframe to the System for Award Management (SAM.gov). The University concurs with the findings and is committed to strengthening its internal controls, procedures, and oversight mechanisms to ensure full compliance with all FFATA reporting requirements moving forward. II. Criteria Under FFATA requirements: • Recipients of federal grants or cooperative agreements must report first-tier subawards of $30,000 or more to SAM.gov. • Reporting must be completed timely and accurately in accordance with federal guidelines. • Institutions must maintain sufficient internal controls to ensure that all reportable subawards are identified, tracked, and submitted within required deadlines. III. Condition The audit determined that a subaward agreement, amendment, or modification meeting FFATA reporting thresholds was not submitted within the required timeframe. This reflects a lapse in the University’s internal processes governing subrecipient monitoring and reporting compliance. IV. Root Cause Analysis The University has identified the following contributing factors: • Inadequate tracking mechanisms for subaward reporting deadlines • Insufficient coordination between Grants Administration and responsible program personnel • Lack of automated alerts and centralized monitoring systems • Gaps in internal review and approval workflows prior to submission • Limited oversight to ensure timely compliance with FFATA requirements V. Corrective Actions and Implementation Plan The University will implement the following corrective measures effective immediately: 1. Internal Audit Oversight and Governance • The Internal Audit function will assume leadership responsibility for overseeing FFATA compliance and subrecipient reporting processes. • Quarterly compliance reports will be prepared and submitted directly to the Vice President and Chief Finance Officer until sustained compliance is achieved. • Internal Audit will conduct periodic reviews and testing of subaward reporting to ensure adherence to federal requirements. 2. Enhanced Tracking and Monitoring Systems • A centralized tracking system will be implemented to monitor all subawards, including thresholds, reporting deadlines, and submission status. • Automated alerts and reminders will be established to notify responsible personnel of upcoming reporting deadlines. 3. Strengthening Policies and Procedures • Standard Operating Procedures (“SOPs”) for FFATA reporting will be updated and formally documented. • Procedures will clearly define roles, responsibilities, timelines, and escalation protocols for noncompliance. • A compliance checklist will be required prior to execution and modification of all subaward agreements. 4. Improved Interdepartmental Coordination • Formal communication protocols will be established between Grants Administration, Principal Investigators, and Finance to ensure timely identification and reporting of subawards. • Designated compliance liaisons will be assigned to ensure accountability across departments. 5. Training and Capacity Building • Mandatory training will be conducted for all staff involved in grants management and subrecipient oversight. • Training will focus on FFATA requirements, reporting timelines, system usage, and compliance expectations. 6. Pre-Submission Review and Quality Assurance • A secondary review process will be implemented prior to submission to SAM.gov to ensure accuracy and completeness. • Documentation supporting all submissions will be retained in a centralized repository for audit and compliance purposes. VI. Timeline for Implementation • Immediate: o Initiate Internal Audit oversight o Implement interim tracking and reporting processes o Begin staff training • Short-Term: o Deploy centralized tracking system and automated alerts o Finalize and implement updated SOPs o Begin quarterly reporting to the Vice President and Chief Finance Officer • Long-Term (Ongoing): o Conduct continuous monitoring and compliance reviews o Maintain quarterly reporting until full and sustained compliance is achieved VII. Monitoring and Ongoing Compliance The Internal Audit function will provide ongoing monitoring and validation of FFATA reporting compliance. Quarterly reports will include status updates, identified issues, corrective actions, and recommendations for continuous improvement. VIII. Conclusion The University is committed to addressing the deficiencies identified in Finding 2025-003 through enhanced oversight, improved processes, and strengthened internal controls. These actions will ensure timely and accurate subaward reporting, uphold compliance with FFATA requirements, and reinforce the University’s commitment to transparency and accountability in federal grant management. Anticipated Completion Date: September 1, 2026

View Audit 397073

Finding 1205370 (2025-101)

Material Weakness 2025

Cochise County

AZ

Subrecipient Monitoring Eligibility Questioned Costs § 200.303

Cochise County Corrective Action Plan Year ended June 30, 2025 2025-101 Assistance Listings number and name: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award number and years: CTR067930, October 1, 2023 through September 30, 2028 Federal agency: U.S. Departmen...

Cochise County Corrective Action Plan Year ended June 30, 2025 2025-101 Assistance Listings number and name: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award number and years: CTR067930, October 1, 2023 through September 30, 2028 Federal agency: U.S. Department of Agriculture Pass-through grantor: Arizona Department of Health Services Compliance requirement: Eligibility Questioned costs: Unknown The County did not perform eligibility certification requirements, resulting in an increased risk of program participants receiving benefits they are not eligible to receive Contact: Barbara Lang Completion date: March 2026 Corrective Action: Cochise County WIC leadership and staff are committed to full adherence with WIC policy and will continue to implement training, monitoring, and communication to ensure compliance with federal and state regulation. This audit timeframe produced findings primarily related to issues that have already been corrected through the departure of staff that contributed to the findings (to include the previous Directors), hiring of new staff with a more thorough and comprehensive training plan implemented, and staff effort to retroactively collect all required signatures at subsequent appointments to ensure all WIC clients have current signatures and understanding of Rights & Obligations and Consents for their certification period. We recognize that these new processes were not put into plan until June 2025, due to the timing of the previous audit, and therefore did not reflect on the July 1, 2024 – June 30, 2025 audit period. In addition to the above resolved issues, a new WIC director was hired in September 2025 and new policies and procedures were immediately developed and put into place. These new policies and procedures that serve as our already implemented corrective action plan are as follows: Staff Training a. All staff are required to complete the full ADHS WIC-sponsored live cohort training courses upon hire, and every 3 years of their employment to ensure competencies are maintained over time. b. All staff complete their annual Civil Rights, Conflict of Interest, and Confidentiality upon hire and annually. Last annual training was completed Fall 2025. c. A staff dedicated as Training Coordinator monitors training logs and ensure all training requirements are met, with additional oversight by the WIC Director and the ADHS WIC State office. d. In-person staff meetings are held monthly, with a significant portion of time dedicated to staff training on programmatic expectations to ensure all staff obtain the same information so that tasks are carried out in a standardized method. e. Weekly team huddles to review any timely findings or discuss issues as a group. f. Weekly 1:1’s with each staff to discuss areas where the employee may need additional training or to discuss any deficiencies the WIC manager has noticed, (i.e. note-taking/documentation, single income verifications, chart review findings, etc.). Separation of Duties g. Cert List for Audits report run every 2 weeks for each clinic/staff person to review adherence to Separation of Duties. i. Follow up with certain percentage of clients per policy to assess how the certification went and verify client information. ii. Follow up with staff if any issues are identified. h. Staff have been training on during staff meetings in July 2025, August 2025, October 2025, and during new employee training on how to properly use the HANDS system to ensure the system accurately records who completed the 2nd income verification. i. Revision of Separation of Duties policy and implementation of new “protected time” procedure to ensure there is a staff person available at almost all times of day to complete the 2nd IV. *Since approval of this policy the ADHS WIC state office on 1/5/2026 and implementation of this policy/procedure, the Cert List for Audit report of single-income verifications has decreased substantially (from 60 in 2 weeks, to 5), all with documented reasons why 2nd IV was unable to be obtained during certification appointment and notes verifying 2nd IV was completed on another date. Rights and Obligations and Consent Forms a. All staff received a refresher training on 8/26/25, will be retrained annually, and are regularly reminded to obtain both required signatures at certification b. If staff are unable to obtain digital signatures due to tech issues, they are required to obtain e-document signatures via the clients email, or written signatures the staff then scans into the client file c. Chart reviews and staff observations are completed on a monthly-bimonthly basis to ensure ongoing staff compliance with policy and procedure

View Audit 397064

Corrective Action Plans

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