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Finding 1205391 (2025-102)
Material Weakness 2025
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.
Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct ...
Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026
Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct ...
Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026
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
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
Home Investment Partnerships Program Assistance Listing No. 14.239 Recommendation: The City should review and enhance its internal controls and procedures to ensure that all required information is included in subawards at the time of issuance and maintained in subsequent modifications. Explanation ...
Home Investment Partnerships Program Assistance Listing No. 14.239 Recommendation: The City should review and enhance its internal controls and procedures to ensure that all required information is included in subawards at the time of issuance and maintained in subsequent modifications. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will undertake additional training for departments in FY 2026, to include providing departments with a grants responsibility checklist. Name(s) of the contact person(s) responsible for corrective action: Kevin Greenlief, Director of Finance. Planned completion date for corrective action plan: Q2, 2026.
Highway Planning and Construction Assistance Listing No. 20.205 Recommendation: We recommend that the City review and enhance current procedures to ensure that the vendor's suspension and debarment status is documented prior to contracting with the vendor. Explanation of disagreement with audit find...
Highway Planning and Construction Assistance Listing No. 20.205 Recommendation: We recommend that the City review and enhance current procedures to ensure that the vendor's suspension and debarment status is documented prior to contracting with the vendor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City's Transporation Department erroneously thought the City's Purchasing Department performed the suspension and debarment check. Purchasing reported that since we were riding the contract of another jurisdiction that they rely on that jurisdiction to check for debarment and the other jurisdiction confirmed that they only award contracts to active vendors on the State's eVA system, hence an indication of no debarment). Regardless, the City will conduct additional training in this area for prime award recipients and for Purchasing staff. The City will also check for suspensions and debarment even if riding contracts from other jurisdictions. Name(s) of the contact person(s) responsible for corrective action: Davidia Thompson, Wynndell Bishop, Department of Finance. Planned completion date for corrective action plan: Q2, 2026.
HeadStart Assistance Listing No. 93.600 Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation o...
HeadStart Assistance Listing No. 93.600 Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation of supporting compliance should be readily available for review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The reporting has been completed. New employees will be trained in the procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation will be available for review during the audit period. Name(s) of the contact person(s) responsible for corrective action: Noah Abraham, DCHS Operations Director. Planned completion date for corrective action plan: Complete
Explanation of disagreement with audit finding: Prior finding was specific to change to withdrawal status not being timely reported in relation to students who never attended and/or stopped attending. Additional scenarios in this finding, to our knowledge, have not been found in a previous audit. We...
Explanation of disagreement with audit finding: Prior finding was specific to change to withdrawal status not being timely reported in relation to students who never attended and/or stopped attending. Additional scenarios in this finding, to our knowledge, have not been found in a previous audit. We acknowledge that they fall within the same finding, but the scenarios that fall within the overall finding are not repeats. Action taken in response to finding: WAU acknowledges the importance of effective internal controls in regards to compliance. As a result, the following corrective action steps will be implemented: • Enrollment Date Discrepancies: o The Registrar’s Office will review finding and determine the best course of action to ensure the degree conferral date for a graduate (Effective date per Institutional Record) and the Effective date per NSLDS Campus Record align. After determination of action an SOP will be created. o The Registrar’s Office will create an SOP and add to the withdrawal policy a statement regarding what the effective date will be when students are unofficially withdrawn for not attending and then later submit an official university withdrawal form. o The Registrar’s Office will research the option of continuous enrollment for students who receive a DG and/or Incomplete grade at the end of a term and do not enroll in the next term. Also, the DG and Incomplete policy will be reviewed to determine if the removal of DG and Incomplete deadline needs to be adjusted. • Program Start Date Discrepancies: o The Registrar’s Office will review finding and determine the best course of action to ensure academic program start dates in institutional records align with NSLDS program start dates. After determination of action an SOP will be created. • Missed Enrollment Certification: o See action plan for Enrollment date discrepancies above (bullet 3) • Enrollment Stats discrepancies: o The Registrar will confirm in NSC that all students who graduated but were not enrolled in the term they graduated from are reported as graduated in NSC in a timely manner and work with financial aid to determine the graduation information is recorded timely and accurately in NSLDS as well. After determination of action an SOP will be created. • Inaccurate Institutional Records: o The Registrar’s Office will review finding and determine the best course of action to ensure that students who we send University Withdrawal forms to, upon their request, get withdrawn even if the form is not returned in a timely manner. After determination of action an SOP will be created. Name(s) of the contact person(s) responsible for corrective action: • Team Lead: Registrar (Lynn Zabaleta) • Internal Control Team: Office staff • Senior Management: AVP Enrollment Management (Dirk Whatley) Planned completion date for corrective action plan: June 30, 2026
1. Drawdown- Financial Director will authorize drawdown with the AVP of Enrollment reviewing and approving the drawdown. 2. Reconciliation- An SOP will be developed having the Financial Advisor/Pell Grant Officer who manages reconciliation of Pelll, SEOG, and Federal work study. Director financial a...
1. Drawdown- Financial Director will authorize drawdown with the AVP of Enrollment reviewing and approving the drawdown. 2. Reconciliation- An SOP will be developed having the Financial Advisor/Pell Grant Officer who manages reconciliation of Pelll, SEOG, and Federal work study. Director financial aid will review and approve reconciliation. For Direct Loans the Direct of Financial aid will prepare the reconciliation to review by the Controller and AVP of Enrollment on a monthly basis. 3. Financial aid Packages- Third party service provider Financial Aid Services (FAS) will complete all financial aid packages with the Director of Financial aid reviewing packaging accuracing by pulling samples of at minimum 25 students for both fall and spring semester. 4. Professional Judgement- An SOP for professional judgment will be created. The Financial aid Director or Pell Grant Officer will prepare the professional judgement. The review and approval to complete by AVP of Enrollment. 5. RT24- Third party service provider (FAS) will prepare RT24 calculations with review and approval by Director of Financial aid and the Associate Vice President of Enrollment. 6. Credit Balances- An SOP will be created to ensure that credit balances are distributed to students within 14 days by verifying enrollment during disbursement. 7. Incentive Compensation – We were unable to verify whether the control to ensure that no incentive compensation is made to employees in the student recruiting and admission, and financial aid departments, is designed and operating effectively. 8. Eligibility – We identified instances in which the Cost of Attendance (COA) used to calculate financial need was inaccurate due to insufficient review and oversight over COA calculations. 9. NSLDS – We noted instances where the University’s records do not match the information shown in the Colleague system, particularly the effective withdrawal dates. Name(s) of the contact person(s) responsible for corrective action: Team Lead: Interim Director of Financial Aid (Alfred Taylor), Director of Student Accounts (Keisha Dublin) ● Internal Control team: Associate Director of Financial Aid (Associate Director of Student Accounts (Arlene Joy Canong), Financial Aid Advisor (Don Lodenquai) ● Senior Management: AVP of Enrollment Management (Dirk Whatley), Controller (Ronald Somervell) ● Financial Aid Services (FAS) Planned Completion Date for Corrective Action Plan: April 26, 2026
THE CITY WILL IMPROVE GRANT EXPENDITURES RECORDKEEPING BY USING CASELLE, OUR ENTERPRISE GENERAL LEDGER (GL) SYSTEM, AS THE PRIMARY SYSTEM OF RECORD FOR TRACKING ALL GRANT-RELATED REVENUE, EXPENDITURES, AND PROJECT ACTIVITY. THE CITY WILL UTILIZE THE CASELLE PROJECT ACCOUNTING MODULE AS THE OFFICIAL ...
THE CITY WILL IMPROVE GRANT EXPENDITURES RECORDKEEPING BY USING CASELLE, OUR ENTERPRISE GENERAL LEDGER (GL) SYSTEM, AS THE PRIMARY SYSTEM OF RECORD FOR TRACKING ALL GRANT-RELATED REVENUE, EXPENDITURES, AND PROJECT ACTIVITY. THE CITY WILL UTILIZE THE CASELLE PROJECT ACCOUNTING MODULE AS THE OFFICIAL GRANT/PROJECT TRACKING MECHANISM AND WILL FORMALIZE A CONSISTENT GRANT ACCOUNTING STRUCTURE WITHIN CASELLE (INCLUDING APPROPRIATE FUND/PROJECT/GRANT CODES AND EXPENDITURE ACCOUNTS) SO THAT GRANT TRANSACTIONS ARE CLEARLY IDENTIFIED, ACCURATELY CODED, AND FULLY SUPPORTED BY DOCUMENTATION. TO ENSURE THE ONGOING ACCURACY OF THE GENERAL LEDGER AND PROJECT RECORDS, THE CITY WILL IMPLEMENT ROUTINE RECONCILIATION AND REVIEW PROCEDURES THAT TIE AMOUNTS RECORDED IN CASELLE (INCLUDING PROJECT ACCOUNTING ACTIVITY) TO SUPPORTING DOCUMENTATION AND REIMBURSEMENT ACTIVITY AND WILL CORRECT ANY MISCODING OR OMISSIONS PROMPTLY. THE CITY WILL ALSO UPDATE WRITTEN GRANT ACCOUNTING PROCEDURES AND PROVIDE TRAINING TO STAFF INVOLVED IN PURCHASING, ACCOUNTS PAYABLE, AND GRANT ADMINISTRATION TO REINFORCE CODING REQUIREMENTS, DOCUMENTATION STANDARDS, AND REVIEW RESPONSIBILITIES.
Corrective Action Plan Fiscal Year 2025 Finding Number: 2025-001 – Pell Grant Special Tests and Provisions – NSLDS Reporting The District acknowledges the findings related to NSLDS enrollment reporting and has conducted an internal review of processes, systems, and oversight structures contributing ...
Corrective Action Plan Fiscal Year 2025 Finding Number: 2025-001 – Pell Grant Special Tests and Provisions – NSLDS Reporting The District acknowledges the findings related to NSLDS enrollment reporting and has conducted an internal review of processes, systems, and oversight structures contributing to the finding. To ensure compliance with federal reporting requirements, the District will implement the following corrective actions: 1. Enhanced Review Procedures: The District will strengthen internal controls over enrollment reporting by implementing procedures to ensure all enrollment status changes are accurately recorded, reconciled between internal systems and third-party servicer reports, and submitted to NSLDS within required time frames. Additionally, The District is actively restructuring internal systems and workflows within the department to strengthen oversight, improve accuracy, and ensure timely reporting of enrollment status changes. 2. Training: The District recognizes that staff turnover and inconsistent training contributed to the finding. To address this, the District will implement a comprehensive training plan in partnership with the third-party servicer. 3. Monitoring Controls: The District will formally reestablish expectations with its third-party servicer to ensure all contracted services are implemented. Implementation Timeline: • Enhanced review procedures will be implemented immediately. • The District will implement an ongoing comprehensive training plan in partnership with third-party servicer. • Staff will meet with third-party servicer to re-establish expectations and to ensure compliance with federal reporting requirements before fiscal year-end. Responsible Party: Dr. Dywayne B. Hinds, Sr., Area Superintendent, Dr. Jakub Prokop, Director, PTC- Clearwater, and Dr. Jason Shedrick, Director, PTC-St. Petersburg Anticipated Completion Date: June 30, 2026 Dywayne B. Hinds, Sr., Ed.D. Area Superintendent, Area 3
We will be hiring an accountant to assist with the workload of submitting reports in a timely manner. This addition to the team will help ensure that all deadlines are met and improve overall efficiency.
We will be hiring an accountant to assist with the workload of submitting reports in a timely manner. This addition to the team will help ensure that all deadlines are met and improve overall efficiency.
Finding 2025-004 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Participation of Private School Children Summary of Finding: The School Corporation did not provide supporting documentation for the amounts disbursed for Participation of Private School C...
Finding 2025-004 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Participation of Private School Children Summary of Finding: The School Corporation did not provide supporting documentation for the amounts disbursed for Participation of Private School Children. No time sheets or logs were provided to support the hours paid to employees for working with the Private School Children. Contact Person Responsible for Corrective Action: Randi Libby, Chief Operating Officer Contact Phone Number and Email Address: (260)431-2030, rlibby@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement procedures to ensure consistent documentation supporting Title I services provided to non-public school students. All Title I staff providing services to non-public schools will be required to submit consistent, detailed timesheets documenting hours and/or days worked by non-public school, activity, and grant year. Timesheets will be completed, reviewed, and approved prior to payroll processing. The Payroll Manager will not process payroll for Title I non-public services unless the required timesheets are submitted and approved. Approved timesheets will be retained in the payroll files and organized by payroll dates, and will be made available for audit review. Anticipated Completion Date: July 1, 2026 _________________________ _Randi Libby (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)
Finding 2025-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: The School Corporation and we could not verify the unused Homeless set-aside funds were transferred to the next grant award. Contact Person Responsible for Corrective Action: Randi Libby, ...
Finding 2025-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: The School Corporation and we could not verify the unused Homeless set-aside funds were transferred to the next grant award. Contact Person Responsible for Corrective Action: Randi Libby, Chief Operating Officer Contact Phone Number and Email Address: (260)431-2030, rlibby@sacs.k12.in.us Views of Responsible Official: We disagree with the finding. Explanation and Reasons for Disagreement The School Corporation respectfully disagrees with the conclusion that it failed to comply with Title I homeless setaside requirements. Title I, Part A requires local educational agencies to reserve “such funds as are necessary” to serve homeless children and youth (20 U.S.C. § 6313(c)(3)). Neither the statute nor implementing regulations require that homeless set-aside funds be fully expended each fiscal year, nor do they require unspent homeless set-aside funds to be rolled forward and maintained as a cumulative earmark across successive grant years. During the audit period, the School Corporation increased its homeless set-aside allocation each year based on annual needs assessments. The existence of unspent balances is attributable to year-over-year increases in allocation rather than failure to reserve or obligate funds. Requiring the perpetual rollover of unspent homeless set-aside funds would be inconsistent with Title I’s annual reservation framework and would eventually consume the full 15% Title I carryover limitation, a result not contemplated by federal statute or guidance. While the auditors were unable to verify homeless set-aside expenditures to their satisfaction due to documentation and monitoring gaps, the School Corporation does not agree that this constitutes noncompliance with the earmarking requirement itself. The statutory obligation is to reserve funds based on need, which the School Corporation did. Description of Corrective Action Plan: Although the School Corporation disagrees with the compliance conclusion, it recognizes the need to strengthen internal controls and documentation related to Title I set-aside monitoring. Going forward, the School Corporation will implement enhanced procedures to document: • the annual determination of the homeless set-aside amount, • periodic monitoring of expenditures against the approved reservation, and • year-end reconciliation of reserved versus expended funds within each grant year. These procedures are intended to improve audit transparency and documentation while maintaining compliance with Title I statutory requirements. INDIANA STATE BOARD OF ACCOUNTS 31 Preparing today’s learners for tomorrow’s opportunities. Anticipated Completion Date: January 31, 2026 _________________________ _Randi Libby (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)
Finding 2025-002 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or dete...
Finding 2025-002 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting material noncompliance. Contact Person Responsible for Corrective Action: Erika Horner, Director of Food Service Contact Phone Number and Email Address: (260)431-2030, ehorner@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All direct certification information shall be initiated by the Director of Food Service: pulling the information monthly from CNP Web. The list of students to be directly certified will be printed, signed and dated by the Director of Food Service. Once information is imported into the student management system, the Assistant Food Service Director would then cross reference the printed list of information to benefits assigned in the student management system to ensure accuracy. The Assistant Food Service Director will initial next to the students they spot check on the list. The printed document with signatures of both parties will be retained with the school years applications.􀯗 The Director of Food Service has the responsibility to ensure that all vendors are free from suspension, debarment, or aren’t otherwise excluded. Suspension and debarment documents are to be collected on a yearly basis. If such documents are not available through the SFA Cooperative, it will be the responsibility of the Director of Food Service to acquire them through SAM.gov website or contacting the vendor directly. All documents are to be signed, dated, and retained by school year by both the Director of Food Services and the Asst. Director of Food Services. Anticipated Completion Date: January 31, 2026 _________________________ Randi Libby_ (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)
2025-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Pro...
2025-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Program Titles and Assistance Listing Numbers (ALN): Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Perkins Loans (ALN 84.038), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268), Nurse Faculty Loan Program (ALN 93.264), Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students (ALN 93.342), Nursing Student Loans (ALN 93.364), Scholarships for Health Professions Students from Disadvantaged Backgrounds (ALN 93.925) Federal Grant Numbers: E P007A252602 (7/1/2024 – 6/30/2025), E P033A252602 (7/1/2024 – 6/30/2025), E P038A132602 (7/1/2024 – 6/30/2025), E P063P250272 (7/1/2024 – 6/30/2025), P268K260272 (7/1/2024 – 6/30/2025), E-01HP28821-02-02, E-01HP31830-01-00,(7/1/2024 – 6/30/2025), E4CHP42498-01-00 (7/1/2024 – 6/30/2025), E26HP25750, E36HP25751, E11HP27284, E36HP26092, E36HP25751, E26HP25748 (7/1/2024 – 6/30/2025) Contact Person: Robert Fahy, AVP of University Enrollment Services, 848-932-2603 Corrective Action: Since the audit period, the University has strengthened governance and oversight over OSFP by formalizing access controls and reinforcing monitoring practices. Management has established and documented OSFP system roles and responsibilities. A review of user access was performed to ensure alignment with job responsibilities, and users holding multiple or incompatible roles were corrected. In addition, the University implemented an audit log to track user provisioning and deprovisioning activity, providing documented evidence of access changes and removals. The University has also enhanced its change management process to ensure that all updates to OSFP follow the documented change management procedures. These measures collectively strengthen logical access and change management controls and support effective internal control over system operations. Management will continue to monitor the effectiveness of these controls. Anticipated Completion Date: Completed
Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of West Warwick’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence Management concurs...
Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of West Warwick’s procurement standards do not include the essential elements as outlined in 2 CFR sections 200.318 through 200.326. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action The error will be corrected as of the beginning for fiscal year ending June 30, 2027. We will add the paragraph to our existing purchasing policy. This must be done by resolution and given the timeline that takes, we anticipate having this implemented the end of June 2026. Name of Contact Person Kristen Benoit, Finance Director Projected Completion Date 7/1/2026
Finding Number: 2025-033 ALN Number(s) and Program Title(s): 97.036 – Disaster Grants (Public Assistance) Views of Responsible Officials and Planned Corrective Action: Arkansas Division of Emergency Management (ADEM) Public Assistance (PA) staff will receive training on FFATA reporting requirements ...
Finding Number: 2025-033 ALN Number(s) and Program Title(s): 97.036 – Disaster Grants (Public Assistance) Views of Responsible Officials and Planned Corrective Action: Arkansas Division of Emergency Management (ADEM) Public Assistance (PA) staff will receive training on FFATA reporting requirements and will follow established Department of Public Safety guidelines to ensure first-tier subawards are reported as required. ADEM PA staff will also establish internal Standard Operating Procedures to ensure that consistent FFATA reporting is accomplished as required. Anticipated Completion Date: 4/30/26 Contact Person: Name: Jodi Lee Title: Deputy Director, Recovery and Mitigation Agency: Arkansas Division of Emergency Management Address: Building 9501 Camp Joseph T Robinson City, State, Zip: North Little Rock, AR 72199 Phone Number: (501) 683-6700 Email Address: Jodi.Lee@adem.arkansas.gov
Finding Number: 2025-007 ALN Number(s) and Program Title(s): 14.228 – Community Development Block Grants Views of Responsible Officials and Planned Corrective Action: The AEDC Grants Division has established internal controls and procedures to ensure compliance with the Federal Funding Accountabilit...
Finding Number: 2025-007 ALN Number(s) and Program Title(s): 14.228 – Community Development Block Grants Views of Responsible Officials and Planned Corrective Action: The AEDC Grants Division has established internal controls and procedures to ensure compliance with the Federal Funding Accountability and Transparency Act (FFATA), primarily focused on AEDC’s responsibility for accurate and timely reporting of CDBG subawards of $30,000 or more. AEDC’s established compliance controls for FFATA include, as reported to ALA staff at the beginning of their field work in this area, are: • Grants Coordinator and/or Division Director checks SAM.gov at the beginning of the grant funding year (after HUD Grant Awards have been signed) or upon the need to report on the first subaward to ensure HUD’s award to the State of Arkansas is entered as a Prime Contract. • All CDBG applicants are required to submit application Exhibit K, FFATA (Federal Funding Accountability & Transparency Act) Reporting Form. This form and ACEDP Policies & Procedures require subrecipients to have an active registration in the System for Award Management (SAM.gov) and obtain a Unique Entity Identifier and AEDC verifying the accuracy of this information before issuing a subaward. • If funding is awarded, completed FFATA Reporting Form is included in the grant agreement packet, prepared by the Grants Manager and approved by the Division Director. A Grant Review Form checklist includes a check that this form is included. • Once a Grant Agreement is executed and the packet returned to the Grants Coordinator for processing, the Grants Coordinator will use the FFATA Reporting Form and information from the Grant Agreement to enter the subaward in SAM.gov, as a subaward associated with the applicable Prime Award (annual allocation). Also included in the packet is a copy of the subawardee’s active Registration and UEI, as well as a Data Collection Sheet which includes a space for the Grants Coordinator to write the date the subaward was entered in SAM.gov. • A timely submission procedure ensures that subaward information is entered into the FSRS at SAM.gov no later than the end of the month following the month in which the subaward obligation was made. To ensure AEDC meets this timely submission requirement, subawards are entered upon return of the AEDC executed grant agreement from the Deputy Director to the Grants Coordinator, who enters the date of the Deputy Director’s signature as the Award Date. • In the ACEDP Grant Agreement the subawardee agrees to comply with The Federal Funding Accountability and Transparency Act, and related federal requirements. • Project closeout procedures include a File Composition Checklist which lists the FFATA Form and the Data Collection Sheet (with subaward reporting date). By the Anticipated Completion Date, the Grants Coordinator and/or the Division Director will ensure each previously awarded subaward has been reported to SAM.gov, and will follow the above controls going forward to ensure compliance. Anticipated Completion Date: 06/30/2026 Contact Person: Name: Jean Noble Title: Director, Grants Division Agency: Arkansas Economic Development Commission Address: 1 Commerce Way, Ste. 601 City, State, Zip: Little Rock, AR 72201 Phone Number: (501) 682-7389 Email Address: jnoble@arkansasedc.com
Finding Number: 2025-006 ALN Number(s) and Program Title(s): 10.646 – Summer Electronic Benefit Transfer Program for Children Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. The agency has updated its internal procedures to comply with FNS guidance on com...
Finding Number: 2025-006 ALN Number(s) and Program Title(s): 10.646 – Summer Electronic Benefit Transfer Program for Children Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. The agency has updated its internal procedures to comply with FNS guidance on completion of the FNS-46 S-EBT and FNS-388 S-EBT reports. All noted reports have been revised, if necessary, reviewed, and certified. Staff have been trained on the updated procedures. Anticipated Completion Date: Complete Contact Person: Name: Renee Ikard Title: Chief Financial Officer Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-681-8985 Email Address: Renee.Ikard@dhs.arkansas.gov
Finding Number: 2025-005 ALN Number(s) and Program Title(s): 10.646 – Summer Electronic Benefit Transfer Program for Children Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. The agency has updated its internal procedures to comply with FNS guidance on com...
Finding Number: 2025-005 ALN Number(s) and Program Title(s): 10.646 – Summer Electronic Benefit Transfer Program for Children Views of Responsible Officials and Planned Corrective Action: DHS concurs with this finding. The agency has updated its internal procedures to comply with FNS guidance on completion of the FNS-425 S-EBT annual financial report. Staff have been trained on the updated procedures. Anticipated Completion Date: Complete Contact Person: Name: Renee Ikard Title: Chief Financial Officer Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-681-8985 Email Address: Renee.Ikard@dhs.arkansas.gov
The PRDOH agreed with the findings and is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, PRDOH is working and verifying our written procedures to ensure ...
The PRDOH agreed with the findings and is working with the Finance Department to establish and strengthen our internal controls to ensure all payments comply with the guidelines established by the Federal Government. On the other hand, PRDOH is working and verifying our written procedures to ensure that payments are issued promptly after the drawdown is made.
Identifying Number: 2025-001 Finding: For sixteen out of forty students tested who had enrollment changes at the University, the student’s status effective dates at the campus level and program level were not reported to the NSLDS timely. Corrective Actions Taken or Planned: We agree with the findin...
Identifying Number: 2025-001 Finding: For sixteen out of forty students tested who had enrollment changes at the University, the student’s status effective dates at the campus level and program level were not reported to the NSLDS timely. Corrective Actions Taken or Planned: We agree with the finding. The delays in reporting were identified beginning in December 2024 with the hire of a new registrar and since that time we have caught up with reporting requirements are now timely. We have also increased our cross-training efforts in the department, training multiple individuals on NSC reporting procedures, in order to ensure that if turnover were to occur again in the future there are other individuals who can perform the required functions. Person(s) Responsible for Corrective Actions: Katie Soter, Registrar Anticipated Completion Date: Completed
Condition: During eligibility testing of loan disbursements under the RMAP program, one of eight disbursements tested was made to a borrower located outside of the eligible area. The loan was disbursed in fiscal year 2025 for $10,000. Planned Corrective Action: The ECDI processing and loan allocatio...
Condition: During eligibility testing of loan disbursements under the RMAP program, one of eight disbursements tested was made to a borrower located outside of the eligible area. The loan was disbursed in fiscal year 2025 for $10,000. Planned Corrective Action: The ECDI processing and loan allocation teams will not exclusively leverage it’s CRM system for determining USDA eligibility based on borrower/business address. The team will use the USDA website in determining eligibility prior to allocating USDA funds to a project. Related to the specific ineligible $10,000 USDA loan, the team has communicated to its USDA partner to make them aware of this specific issue and ECDI is in the process of removing USDA funds and replacing with another source. Contact Person Responsible for Corrective Action: Brian Barrett and Sean Henderson Completion Date: In process
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