Corrective Action Plans

Finding 1172932 (2025-001)

Material Weakness 2025

WY

Subrecipient Monitoring Internal Control / Segregation of Duties

ALTHOUGH THE ACCOUNTING STAFF IS TOO SMALL TO PROVIDE FOR ADEQUATE SEGREGATION OF DUTIES, THERE ARE EFFECTIVE COMPENSATING CONTROLS IN PLACE. PHYSICAL CONTROL OF DOCUMENTS AND CONTROL OF CHECK SIGNATURE AUTHORITY ARE TWO EXAMPLES OF MEASURES USED TO COMPENSATE FOR THE SEGREGATION ISSUE. VOUCHERS ALL...

ALTHOUGH THE ACCOUNTING STAFF IS TOO SMALL TO PROVIDE FOR ADEQUATE SEGREGATION OF DUTIES, THERE ARE EFFECTIVE COMPENSATING CONTROLS IN PLACE. PHYSICAL CONTROL OF DOCUMENTS AND CONTROL OF CHECK SIGNATURE AUTHORITY ARE TWO EXAMPLES OF MEASURES USED TO COMPENSATE FOR THE SEGREGATION ISSUE. VOUCHERS ALL REQUIRE MANAGEMENT APPROVAL, AS WELL AS INVOICES PROCESSED FOR PAYMENT. ON A MONTHLY BASIS, EXPENDITURES ARE REVIEWED BY THE BOARD AND AIRPORT MANAGER, AND BANK STATEMENTS ARE RECONCILED AND REVIEWED. THESE CONTROLS PROVIDE ADEQUATE AND EFFECTIVE SAFEGUARDS TO COMPENSATE FOR THE LACK OF SEGREGATION OF RESPONSIBILITIES IN THE ACCOUNTING DEPARTMENT. STEVE GOOD, AIRPORT MANAGER, IS ABLE TO PROVIDE INFORMATION ON THE STATUS OF THIS CORRECTIVE ACTION.

View Audit 386317

Finding 1172919 (2025-003)

Material Weakness 2025

Randall University

OK

Student Financial Aid Subrecipient Monitoring Cash Management

84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit...

84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit Balance was held for more than 14 days for one of the seventeen students in our sample. Corrective Action Plan: There is no longer a credit balance on the account of the student in question. If time allows, the business office will review student accounts to determine if any additional credit balances should be refunded. Procedures should be improved to ensure the University is following the HCM2 regulations. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172905 (2025-004)

Material Weakness 2025

Lutheran Family Services of Virginia, Inc. Dba Encircle

VA

Reporting Subrecipient Monitoring Material Weakness

Action Taken enCircle noted during the audit that federal expenditures were being billed into multiple revenue accounts depending on the nature of the expenditure (internal expense, client reimbursable expense, foster parent payments). These accounts have all been consolidated into one account to en...

Action Taken enCircle noted during the audit that federal expenditures were being billed into multiple revenue accounts depending on the nature of the expenditure (internal expense, client reimbursable expense, foster parent payments). These accounts have all been consolidated into one account to ensure internal and external reporting does not exclude billed expenditures.

View Audit 386282

Finding 1172902 (2025-001)

Material Weakness 2025

Lutheran Family Services of Virginia, Inc. Dba Encircle

VA

Subrecipient Monitoring

Action Taken enCircle has developed a new budget tracking tool at the correct budget line items to ensure all categories do not go over budget before budget amendments are submitted and approved. Included in this tool is predictive analytics to determine where budget amendments might be needed proac...

Action Taken enCircle has developed a new budget tracking tool at the correct budget line items to ensure all categories do not go over budget before budget amendments are submitted and approved. Included in this tool is predictive analytics to determine where budget amendments might be needed proactively instead of reactively.

View Audit 386282

Finding 1172867 (2025-001)

Material Weakness 2025

Atwood Elder Housing, Inc.

MA

Eligibility HUD Housing Programs Internal Control / Segregation of Duties

Atwood Elder Housing, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: November 1, 2024 - October 31, 2025 The finding fr...

Atwood Elder Housing, Inc. respectfully submits the following corrective action plan for the year ended October 31, 2025: Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street Suite 1200 Braintree MA 02184 Audit period: November 1, 2024 - October 31, 2025 The finding from the October 31, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Federal Award Findings and Questioned Costs Finding 2025-001 - Eligibility - Significant Deficiency Recommendation: Management should review its internal controls over performing tenant recertification procedures to ensure compliance with eligibility requirements. Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility is done in accordance with guidelines specified by federal regulations. Action Taken: Management agrees with the assessment and resulting finding. Corrective actions have been implemented to strengthen compliance controls, including calendar reminders for compliance team members, enhanced documentation in recertification checklists to clarify specific program requirements, and routine review of compliance expectations during monthly staff training and meetings. Management has also increased supervisory oversight and implemented periodic internal file audits to monitor adherence to recertification procedures and prevent future occurrences.

View Audit 386273

Finding 1172851 (2025-003)

Material Weakness 2025

California State University

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.214 § 200.303

Compliance Requirement: Procurement, Suspension and Debarment Campus: Sacramento Recommendation: KPMG recommends the University implement controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension an...

Compliance Requirement: Procurement, Suspension and Debarment Campus: Sacramento Recommendation: KPMG recommends the University implement controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor. Corrective Action Plan: California State University, Sacramento The University concurs with the recommendations. The University will review and enhance its procedures and internal controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor. Estimated Completion Date: July 2026 Contact person: California State University, Sacramento Tabitha Leeds Senior Director of Accounting Services (916) 278-4679 leeds@csus.edu

View Audit 386207

Finding 1172832 (2025-001)

Material Weakness 2025

City of Council Bluffs

IA

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles

We have reviewed procedures and plan to make the necessary changes to improve reporting timeliness. Staff will update its internal policy to submit the FFATA within 30 days of execution of the CDBG annual budget, Annual Action Plan, and subaward agreements, along with any amendments to these agreeme...

We have reviewed procedures and plan to make the necessary changes to improve reporting timeliness. Staff will update its internal policy to submit the FFATA within 30 days of execution of the CDBG annual budget, Annual Action Plan, and subaward agreements, along with any amendments to these agreements. Contact Person, Title, Phone Number Christopher Gibbons, Interim Director of Community Development, (712) 890-5358 Anticipated Date of Completion January 30, 2026

View Audit 386178

Finding 1172786 (2025-002)

Material Weakness 2025

Mt. San Antonio Community College District

CA

Subrecipient Monitoring Student Financial Aid Significant Deficiency

Views of Responsible Officials and Corrective Action Plan During Fall 2024, the Financial Aid Office experienced the departure of two key senior staff members who were primarily responsible for Return to Title IV (R2T4) processing and the reversal of federal funds. As a result, new staff were tempor...

Views of Responsible Officials and Corrective Action Plan During Fall 2024, the Financial Aid Office experienced the departure of two key senior staff members who were primarily responsible for Return to Title IV (R2T4) processing and the reversal of federal funds. As a result, new staff were temporarily assigned to manage these responsibilities during the transition period, which contributed to delays in returning funds within the required regulatory timeframe. A comprehensive review of all R2T4 calculations completed during the 2024–2025 aid year determined that records processed prior to mid-November 2024 had over awarded funds returned within the applicable 45- and 30-day regulatory timeframes. This timeframe aligns with the period when the responsible staff members announced their retirements. To resolve this matter and prevent recurrence, the District has implemented the following corrective measures. Targeted R2T4 Training: Staff responsible for Return to Title IV (R2T4) processing and disbursement reversals are in the process of completing the National Association of Student Financial Aid Administrators (NASFAA) R2T4 credential training. This certification will ensure staff possess consistent, up-to-date knowledge of federal requirements around the R2T4 process to include the timelines required to return over-awarded funds to the department. Automated Monitoring Report: A recurring monitoring report has been established to identify students with pending Returns of Title IV (R2T4) funds. The report automatically flags cases exceeding 30 days and, for students who withdrew prior to the start of the term, those exceeding 20 days. Department managers will generate and review this report on a weekly basis to ensure timely compliance with federal return requirements. In instances where pending returns are identified as being past the alert threshold, Financial Aid management will promptly coordinate with Fiscal Services to expedite the return of funds and document resolution actions. Cross-Training for Continuity of Operations: Ongoing cross-training has been implemented among Financial Aid staff to ensure sufficient coverage during vacations, extended leaves, or unexpected absences. At least two designated staff members will be fully trained and authorized to perform R2T4 calculations and return processing to prevent delays in compliance during personnel transitions. These measures strengthen accountability, monitoring, and collaboration between the Financial Aid and Fiscal Services departments to ensure full compliance with federal cash management and return regulations.

View Audit 386075

Finding 1172769 (2025-001)

Material Weakness 2025

Moore College of Art & Design

PA

Student Financial Aid Subrecipient Monitoring

Management recognizes that staff had incorrectly interpreted the length of break that would necessitate a change in the refund calculation. Staff are now aware of the correct interpretation of the rule and will use it for all future calculations. Management will also identify a consultant to work wi...

Management recognizes that staff had incorrectly interpreted the length of break that would necessitate a change in the refund calculation. Staff are now aware of the correct interpretation of the rule and will use it for all future calculations. Management will also identify a consultant to work with the College’s Director of Financial Aid, Controller and Registrar to review all rules regarding return to title IV calculations so a guide can be created to lessen the chance of incorrect calculations going forward.

View Audit 386042

Finding 1172727 (2025-001)

Material Weakness 2025

Towpath Trail High School

OH

Subrecipient Monitoring Reporting Significant Deficiency § 200.208 § 200.328

Finding Number: 2025-001 Planned Corrective Action: Towpath Trail High School will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 2/14/2026 Responsible Contact Person: Dave Massa, Treasurer

View Audit 385998

Finding 1172677 (2025-002)

Material Weakness 2025

University of Puerto Rico

PR

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Finding Number: 2025-002 Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Control Requirement - Return of Title IV Funds Management’s Response The University of Puerto Rico concurs with this finding. Institutional units have identified opportunities for improvement in intern...

Finding Number: 2025-002 Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Control Requirement - Return of Title IV Funds Management’s Response The University of Puerto Rico concurs with this finding. Institutional units have identified opportunities for improvement in internal controls related to the timely return of Title IV funds and have implemented, or are in the process of implementing, corrective measures to ensure compliance with the regulatory timeframe of 45 days. The Cayey unit identified that the delay in the return of Title IV funds was related to an unintentional administrative error in the handling and filing of R2T4 documentation, within a context of operational transition and temporary staffing limitations. As a corrective action, the Fiscal Office will strengthen periodic reviews of total withdrawal reports generated in the NEXT system, ensure proper classification and monitoring of R2T4 cases, and provide continuous follow-up until funds are effectively returned within the 45 days regulatory timeframe. As a control mechanism, direct oversight of the R2T4 process by the Finance Director has been established, including recurring reviews of total withdrawal reports and reconciliation of these reports with refund vouchers, in order to ensure that all cases are processed and returned in a timely manner. The Humacao unit acknowledged that the cases identified by the auditors were related to specific circumstances, including system errors, technical limitations, and operational workload associated with the implementation of the shared services model. As a corrective measure, the unit implemented changes to the total withdrawal request form and process to ensure coordinated handling between the Office of Financial Aid and the Fiscal Office, allowing for early identification of cases subject to R2T4. Additionally, the Fiscal Office will review total withdrawal reports generated by the NEXT system on a recurring basis, perform R2T4 calculations timely, and coordinate with the Office of Finance to process returns within the regulatory timeframe. Oversight of the process has been strengthened through the designation of responsible personnel and continuous monitoring of active cases through completion. The Carolina unit identified that delays in the return of Title IV funds were due to discrepancies in attendance reports that were subsequently amended. As a corrective action, the Office of Financial Aid will formally notify the Fiscal Office of any corrections or amendments to attendance reports to ensure that R2T4 cases are identified timely. In addition, the use of “Never Attended” reports has been reinforced at the conclusion of the census period and upon completion of the grade submission period. Once the R2T4 calculation is completed in the COD system and a return is determined, the refund process will be initiated immediately, accompanied by continuous follow-up and the scheduling of key dates to ensure compliance with the 45 days regulatory requirement. The Central Administration Finance Office will conduct a meeting with Finance Directors, Financial Aid Directors, the Office of the Registrar, and Fiscal Directors to discuss this finding and establish a uniform procedure to address the following scenarios: • Students who request a total withdrawal. • Students who stopped attending. • Students who never attended. Additionally, a control mechanism will be implemented through the SharePoint platform, whereby each Fiscal Director will certify that system reviews have been performed for cases approaching the 45 days regulatory deadline. This control will be performed on a bi-weekly basis and will allow for timely monitoring of active cases, ensuring proper compliance with the required return of funds. For cases related to grade-based census determinations, which are processed once faculty submit grades in the system, an additional control mechanism will be established. Specifically, the SharePoint tool will be used for Fiscal Directors to document the academic calendar deadlines for grade submission. Furthermore, Fiscal Directors will schedule Outlook calendar events with these deadlines, including the Director of Financial Aid and the Office of the Registrar, and will establish automated reminders to ensure timely follow-up. These procedures will be documented and incorporated into the internal control manual applicable to the R2T4 process. Responsible Person or Office: Central Administration Finance Office and the finance offices of each of the eleven (11) institutional units. Implementation Timeline: 2026-2027

View Audit 385928

Finding 1172613 (2025-001)

Material Weakness 2025

Centro Legal De La Raza

CA

Subrecipient Monitoring

Finding 2025-001: Subrecipient Monitoring Information on the Federal Programs: Department of Treasury, Assistance Listing Number 21.023 Criteria: Compliance requires a debarment search to be completed for subrecipients and to verify with the subrecipients if they are expected to obtain a financial a...

Finding 2025-001: Subrecipient Monitoring Information on the Federal Programs: Department of Treasury, Assistance Listing Number 21.023 Criteria: Compliance requires a debarment search to be completed for subrecipients and to verify with the subrecipients if they are expected to obtain a financial audit. Condition: Centro Legal de la Raza, Inc. has indicated a debarment search was completed for each subrecipient awarded during the current period, however there was no retention of the search or a review of the search results. In addition, staff did not verify with subrecipients if they were expected to obtain a financial and/or compliance audit. Cause: Centro Legal de la Raza, Inc. staff were not aware that retention of the search or the review of its results was required or that as part of their compliance they should be verifying the subrecipient’s expectation for a financial and/or compliance audit. Context: Without retention, there is no support for the completion of the search or the review of its results. Failure to be aware and following through to obtain (if expected) financial or compliance audits does not allow the Organization to ensure their subawards comply with federal rules. Effect: Centro Legal de la Raza, Inc. may have missed completing a search on a subrecipient or missed reviewing a financial or compliance audit of a subrecipient to ensure compliance of the subaward. Questioned Costs: None noted. Identification as a Repeat Finding: n/a Recommendation: We recommend Centro Legal de la Raza, Inc. staff retain the debarment searches and they develop a procedure in which the searches are reviewed before accepting subrecipients. In addition, Centro Legal de la Raza, Inc. staff should inquire and document of subrecipients their expectation of a financial and/or compliance audit and follow through if one is expected to ensure subawards are complying with federal rules. Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. All relevant staff have also undergone training to ensure compliance at all stages of the debarment process. Name and Title of Responsible Official: Brenda Orellana, Grants Director Planned Completion Date: March 31, 2026.

View Audit 385888

Finding 1172591 (2025-002)

Material Weakness 2025

Neighborhood Properties, Inc.

OH

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

Continuum of Care Program – Assistance Listing No. 14.267 Recommendation: Management should establish and implement written procedures to verify suspension and debarment status prior to executing vendor contracts. The SAM.gov verification procedure should be documented and retained in the procuremen...

Continuum of Care Program – Assistance Listing No. 14.267 Recommendation: Management should establish and implement written procedures to verify suspension and debarment status prior to executing vendor contracts. The SAM.gov verification procedure should be documented and retained in the procurement file. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management of the Organization has developed and implemented a formal suspension and debarment policy. • New vendor report will be reviewed by Compliance Officer and Director of Finance. • Compliance Officer will verify vendor legitimacy based on new vendor report. • New vendor creation is now separated from invoice creation and under different staff members. Vendor creation will be forwarded to the Compliance Officer to check vendor on Sam.gov • New, formal suspension and department policy has been created. Name(s) of the contact person(s) responsible for corrective action: Susan Keshen, Fractional CFO Planned completion date for corrective action plan: February 28, 2026

View Audit 385864

Finding 1172574 (2025-001)

Material Weakness 2025

Neighborhood Properties, Inc.

OH

HUD Housing Programs Subrecipient Monitoring Significant Deficiency

Continuum of Care Program – Assistance Listing No. 14.267 Recommendation: Management should strengthen internal controls to ensure timely updates of tenant subsidy amounts based on the contract terms and implement a review process to verify that HAP payments align with the most recent annual contrac...

Continuum of Care Program – Assistance Listing No. 14.267 Recommendation: Management should strengthen internal controls to ensure timely updates of tenant subsidy amounts based on the contract terms and implement a review process to verify that HAP payments align with the most recent annual contract documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management of the Organization has established a system of internal control monitoring and review to ensure HAP payments align with the most recent annual contract documentation. Compliance Officer reviews annual reports for all clients every month. Spreadsheet is reviewed for variance and adjustments made as needed. Name(s) of the contact person(s) responsible for corrective action: Susan Keshen, Fractional CFO Planned completion date for corrective action plan: August 31, 2025.

View Audit 385864

Finding 1172557 (2025-002)

Material Weakness 2025

City of Yerington

NV

Subrecipient Monitoring Reporting

The City Agrees with the recommendation and the finance department will implement a formal review and approval process over recognition and recording of certain revenues. This process will include:Accounting staff with received additional training on accounting software accounting program regarding ...

The City Agrees with the recommendation and the finance department will implement a formal review and approval process over recognition and recording of certain revenues. This process will include:Accounting staff with received additional training on accounting software accounting program regarding generated internal billing over non-typical billed revenues;Accounting staff will receive one-on-one training with accounting software training consultants over accounts receivable subsidiary ledger maintenance;Accounting staff with perform monthly review of subsidiary ledger balances.Planned Completion Date:

View Audit 385855

Finding 1172557 (2025-002)

Material Weakness 2025

City of Yerington

NV

Subrecipient Monitoring Reporting

2026-02-28 00:00:00

View Audit 385855

Finding 1172535 (2025-003)

Material Weakness 2025

Mill Creek Community School Corporation

IN

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

FINDING 2025-003 Finding Subject: Education Stabilization Fund - Earmarking Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Correct...

FINDING 2025-003 Finding Subject: Education Stabilization Fund - Earmarking Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: While the school corporation no longer has any active funds with the COVID-19 Education Stabilization Fund the school corporation will ensure that the designed or implemented a system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance for any future federal program. Anticipated Completion Date: January 1, 2026 INDIANA STATE

View Audit 385771

Finding 1172533 (2025-002)

Material Weakness 2025

Mill Creek Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.303

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description o...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will require that suspension and debarment verification be done for all appropriate vendors prior entering into and paying an invoice at the start of each year. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Documentation will be included with the first voucher each year for that qualifying vendor. Anticipated Completion Date: January 2026

View Audit 385771

Finding 1172529 (2025-001)

Material Weakness 2025

University of Kentucky

KY

Allowable Costs / Cost Principles Subrecipient Monitoring

Contact Person(s) Responsible: Cara Nelson, Director Accounts Payable Services Corrective Action Planned for Reference 2025-001 – Duplicate accrual posting: Management acknowledges an invoice identified during the Single Audit was accrued twice for fiscal year 2025. This occurred when an invoice ret...

Contact Person(s) Responsible: Cara Nelson, Director Accounts Payable Services Corrective Action Planned for Reference 2025-001 – Duplicate accrual posting: Management acknowledges an invoice identified during the Single Audit was accrued twice for fiscal year 2025. This occurred when an invoice returned to the vendor for correction was resubmitted and not flagged as a duplicate accrual. To reduce the risk of future errors, management is implementing an automated report that detects potential duplicate accruals by matching key attributes such as purchase order number, document number, invoice amount, and cost object. All flagged items will be investigated and resolved or documented. Given the minimal rate of occurrence, this automated process is expected to efficiently and effectively reduce the risk of undetected duplicate accruals. Anticipated Completion Date: January 31, 2026

View Audit 385756

Finding 1172496 (2025-001)

Material Weakness 2025

Oregon City School District No. 62

OR

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

5. SA-2025-01 a. Deficiency: Employees funded with Title I grant funds should document their time worked for the grant in line with time and effort requirements of the grant. b. Cause: The District did not consistently meet Title I time and effort documentation requirements for certain employees dur...

5. SA-2025-01 a. Deficiency: Employees funded with Title I grant funds should document their time worked for the grant in line with time and effort requirements of the grant. b. Cause: The District did not consistently meet Title I time and effort documentation requirements for certain employees during the audit period. This occurred due to staffing changes and turnover within the federal grant which resulted in retro pay and funding corrections, which resulted in inconsistent time and effort documentation. In addition, there was a lack of centralized oversight to ensure that time and effort records were completed timely and retained in accordance with federal requirements. c. Corrective Action: The District has taken steps to review time and effort allocations, processes and requirements. Training will be provided to applicable employees and supervisors to reinforce federal requirements and expectations.

View Audit 385685

Finding 1172447 (2025-001)

Material Weakness 2025

Alamosa School District Re-11j

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Action Taken: The District has updated internal control procedures to add additional segregation of duties and documentation. A standard time sheet has been implemented District wide until the District can purchase and implement the timeclock management system add on to its current employee tracking...

Action Taken: The District has updated internal control procedures to add additional segregation of duties and documentation. A standard time sheet has been implemented District wide until the District can purchase and implement the timeclock management system add on to its current employee tracking software. Timesheets are only allowed to be turned in to the Payroll Clerk by the approving supervisor, and after timesheets are entered by the Payroll Clerk they are scanned to the supervisor to review and make sure they agree to what was turned in. The Chief Operations and Financial Officer, Director of Child Nutrition, and Payroll Clerk have all completed internal control training, and The District is evaluating the Child Nutrition Department’s staffing and job descriptions and looking into adding a clerical position to help with reporting and add to segregation of duties/checks and balances.

View Audit 385590

Finding 1172439 (2025-002)

Material Weakness 2025

Bay De Noc Community College

MI

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Noncompliance with Enrollment Status Change Reporting. Auditor Description of Condition and Effect. Of 18 enrollment status changes tested, we noted 1 change that was not reported to the National Student Loan Data System (NSLDS) within 60 days due to a student being assigned a different coding struc...

Noncompliance with Enrollment Status Change Reporting. Auditor Description of Condition and Effect. Of 18 enrollment status changes tested, we noted 1 change that was not reported to the National Student Loan Data System (NSLDS) within 60 days due to a student being assigned a different coding structure within the College's system which resulted in the student being excluded from the standard status-change reporting process. As a result of university personnel using the incorrect semester start dates. As a result of this condition, the College was temporarily out of compliance with enrollment reporting requirements. Auditor Recommendation. We recommend the College review and update its enrollment reporting processes to ensure that all students-including those with unique or foreign-student coding-are captured in routine status-change monitoring and NSLDS reporting procedures. The College should implement controls to detect nonstandard coding and ensure that all enrollment changes are identified and reported within required federal timelines. Corrective Action. Bay College took swift action after determining some students were being excluded in our enrollment reporting. Our reporting process was excluding students who were noted as being a citizen of a foreign county. We now review these students prior to each reporting cycle to determine if they should be included in the reporting. The Financial Aid team reviews this report to determine if the student is eligible for federal student aid. Students who are eligible are indicated and provided to the Institutional Effectiveness team to include in the enrollment reporting. This process is completed prior to each reporting cycle. For students who were not included in our prior reporting, the Financial Aid team working directly with the Institutional Effectiveness team, determined which should be reported and completed their enrollment reporting directly through NSLDS. Responsible Person. Ruth Carlson, Director of Financial Aid. Anticipated Completion Date. June 30, 2026

View Audit 385572

Finding 1172415 (2025-001)

Material Weakness 2025

Holmes County Consolidated School District

MS

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Equipment & Real Property Management

Finding Correction Action Plan Details 2025-001 a. Name of Contact Person Responsible for Corrective Action: Michelle Cage – Chief Financial Officer b. Corrective Action Planned: Management will continue to implement policies or procedures to establish an internal control system that will ensure str...

Finding Correction Action Plan Details 2025-001 a. Name of Contact Person Responsible for Corrective Action: Michelle Cage – Chief Financial Officer b. Corrective Action Planned: Management will continue to implement policies or procedures to establish an internal control system that will ensure strong financial accountability, proper safeguarding of assets, and compliance with federal grant requirements. c. Anticipated Completion Date: Immediately.

View Audit 385530

Finding 1172394 (2025-001)

Material Weakness 2025

HOUSING AUTHORITY OF THE CITY OF STERLING, COLORADO

CO

Cash Management HUD Housing Programs Subrecipient Monitoring

In accordance with HUD requirements, the Authority plans to begin drawing down operating-subsidy funds on a monthly basis. The Executive Director and Board will continue to review monthly financial statements prepared by the accountants and will research and evaluate potential investment options to ...

In accordance with HUD requirements, the Authority plans to begin drawing down operating-subsidy funds on a monthly basis. The Executive Director and Board will continue to review monthly financial statements prepared by the accountants and will research and evaluate potential investment options to increase the return on available funds. The Authority intends to develop and adopt formal written procedures for cash management and investment monitoring during the next fiscal year.

View Audit 385443

Finding 1172392 (2025-001)

Material Weakness 2025

Magnolia Housing Corporation of Natchitoches, Inc.

LA

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management

Magnolia Manor Corporation has taken steps to ensure that the Replacement Reserve account will not be underfunded by withdrawing funds to cover the Operating Account. The underfunded amount of $2,688.00 has been deposited on August 20, 2025, and $306.00 has been deposited on September 15, 2025. Magn...

Magnolia Manor Corporation has taken steps to ensure that the Replacement Reserve account will not be underfunded by withdrawing funds to cover the Operating Account. The underfunded amount of $2,688.00 has been deposited on August 20, 2025, and $306.00 has been deposited on September 15, 2025. Magnolia Manor Corporation has reviewed the auditors' recommendation and will ensure that more thorough monthly reviews will be implemented.

View Audit 385441

Corrective Action Plans

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