Corrective Action Plans

Finding 1171505 (2025-012)

Material Weakness 2025

MD

Matching / Level of Effort / Earmarking Reporting Significant Deficiency § 200.303

Finding 2025-012 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOED will strengthen its fiscal reporting ...

Finding 2025-012 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOED will strengthen its fiscal reporting controls to ensure all required fiscal reports are submitted timely and in accordance with the grantor’s established timetable. This corrective action includes formal distribution of the grantor’s fiscal reporting schedule to responsible staff, implementation of internal calendar tracking for all fiscal reporting deadlines, and enhanced monitoring procedures to ensure deadlines are met and escalated when necessary. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: June 30, 2026

View Audit 384683

Finding 1171473 (2025-010)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.330 § 200.331 § 200.332 § 200.501

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and ...

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and formalize subrecipient monitoring procedures to ensure full compliance with Uniform Guidance requirements. Subrecipient agreement templates will be revised to require inclusion of the subrecipient’s Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) for all subawards, in accordance with 2 CFR §§25.300 and 200.332. MOHS has previously developed subrecipient risk assessment and monitoring tools for the Continuum of Care (CoC) program. These tools and procedures will be reviewed, updated as needed, and expanded to apply to all MOHS grants, including HOPWA. This includes documented risk assessments, monitoring plans, and verification that required Single Audit reports are obtained, reviewed, and retained when applicable. MOHS will maintain centralized subrecipient monitoring files containing executed agreements, audit reviews, monitoring documentation, and follow-up actions. Program and fiscal staff will receive training on updated subrecipient monitoring policies and documentation standards to ensure consistent implementation across all funding sources. MOHS will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, MOHS will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOHS will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. MOHS will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: September 30, 2026

View Audit 384683

Finding 1171472 (2025-009)

Material Weakness 2025

City of Baltimore, Maryland

MD

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Finding 2025-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-013 Auditee’s Corrective Action Plan: MOHS will strengthen internal contro...

Finding 2025-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-013 Auditee’s Corrective Action Plan: MOHS will strengthen internal controls over federal reporting to ensure accuracy, completeness, and compliance with HUD and Uniform Guidance requirements. Specifically, MOHS will implement a documented reconciliation process requiring all HOPWA expenditures reported in the Federal Financial Report (FFR) to be reconciled to the general ledger prior to regular submission, with supervisory review and approval documented. MOHS will establish a formal reporting calendar and standardized checklist to ensure timely preparation, review, and submission of all required HUD reports, including the FFR, Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting (FSRS), and the Consolidated Annual Performance and Evaluation Report (CAPER). • Written procedures will be developed to clearly define staff roles and responsibilities for federal reporting and FFATA compliance, including identification of reportable first-tier subawards and documentation of FSRS submissions. MOHS will also provide targeted training to program and fiscal staff responsible for federal reporting and will conduct periodic internal monitoring to verify compliance with 2 CFR §200.303 and 2 CFR Part 170. MOHS will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. • Per the GMO’s guidance, MOHS will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: June 30, 2026

View Audit 384683

Finding 1171413 (2025-008)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking HUD Housing Programs Reporting § 200.303

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, t...

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, the Consolidated Planning Division has been conducting a widespread effort to ensure programmatic compliance with all City and Federal requirements. To date, it has prioritized: • Reducing the grant’s at-risk financial exposure from approximately $28M in FY23 to $1.03M in FY25. • Implemented moving all NPO operating contracts to the same Period of Performance (July 1 – June 30 of the grant year) to ensure timely expenditure of funds and reduce compliance burden on staff. • Implemented the use of a form agreement approval process for the Board of Estimates (BOE) which reduced the lag time for contract execution and subsequent reimbursement from over 12 months, to approximately 2 months once the executed grant agreement has been received from HUD and approved by the BOE. • Standardized required subrecipient activity reporting and requests for reimbursement in Neighborly (the City’s reporting system of record for the CDBG grant program) to a quarterly basis. • Required all supporting documentation be submitted and reviewed quarterly to eliminate the possibility of overpayment or reimbursement for ineligible activities. • Hired a Director of CDBG finance to improve fiduciary and compliance oversight of federal funds. • Ensured the HUD-required Cash-on-Hand report is entered into a new screen in HUD’s system of record - Integrated Disbursement and Information System (IDIS) - (reporting that was previously collected through Federal Financial Report (FFR)/Standard Form 425 (SF-425) on a timely basis. Corrective Action Plan: • A new Director of CDBG Finance will be hired before the end of FY26. • The new Director of CDBG Finance will be provided training to complete the Cash on Hand Report and will cross-train additional staff on the completion of this report to ensure redundancy. • Supporting documents will be kept on the divisional shared drive in a clearly named subfolder. Contact Person: Mary Correia, Deputy Commissioner David Fielder, Assistant Commissioner Completion Date: June 30, 2026

View Audit 384683

Finding 1171365 (2025-004)

Material Weakness 2025

South Putnam Community School Corporation

IN

Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program(s): School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Numbers: 10.553, 10.555, 10.5...

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program(s): School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years: FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principals Audit Finding: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Costs Principles compliance requirement. The School Corporation entered into a Fixed Price meal Contract with a food service management company (FSMC). For each meal type, a fixed price was established and billed by the FSMC based on meal counts served. The School Corporation failed to compare the invoices received from the FSMC to the School Corporations software reports to ensure the number of meals invoiced agreed to the meals served. Two invoices with the FSMC were selected for testing totaling $213,048.96. . Contact Person Responsible for Corrective Action: Erin Roach Contact Phone Number and Email Address: 765-653-3119 eroach@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The food service director will compare the invoices received from the FSMC to the School Corporations software reports prior to submission for payment. Anticipated Completion Date: February, 2026

View Audit 384655

Finding 1171360 (2025-003)

Material Weakness 2025

South Putnam Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2025-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Number(s) and Year(s) (or Other Identifying Numbers): S425...

FINDING 2025-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Number(s) and Year(s) (or Other Identifying Numbers): S425D200013, S425U200013 Audit Finding: Significant Deficiency This is a repeat finding from the immediately prior audit report. The prior finding number was 2023-003. Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the prior audit period, the School Corporation submitted two ESSER I reports, two ESSER II reports, and two EESER III reports, for a total of six reports. The Superintendent of Schools submitted all the reports without an oversight or review process in place to prevent, detect and correct errors. As a follow up in the current audit period, it was found that this issue was not resolved. The lack of internal controls was a systematic issue throughout the audit period. . Contact Person Responsible for Corrective Action: Erin Roach Contact Phone Number and Email Address: 765-653-3119 eroach@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The grants director will print out the reports for review and approval prior to submission. Anticipated Completion Date: February, 2026

View Audit 384655

Finding 1171320 (2025-005)

Material Weakness 2025

Eastern Greene Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.208 § 200.303

FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Contact Person Responsible for Corrective Action: Superintendent and Title I Program Director Mr. Todd Tanksley Contact Phone Number and Email Address: 812-849-4...

FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Contact Person Responsible for Corrective Action: Superintendent and Title I Program Director Mr. Todd Tanksley Contact Phone Number and Email Address: 812-849-4481 – tanksleyto@mitchell.k12.in.us Views of Responsible O􀆯icial: We concur with the finding. Description of Corrective Action Plan The School Corporation has implemented enhanced internal control procedures to ensure compliance with Assessment System Security requirements and applicable state and federal regulations. E􀆯ective immediately, the School Corporation will: 1. Require all employees who administer, handle, or have access to secure test materials to complete annual assessment security training in accordance with the Indiana Assessment Policy Manual. 2. Require all such employees to sign the Indiana Testing Security and Integrity Agreement annually by an established deadline. INDIANA STATE BOARD OF ACCOUNTS 34 3. Establish a standardized process to collect, review, and retain signed testing security agreements at the building level. 4. Maintain a centralized tracking log of all employees required to complete training and sign agreements. 5. Conduct an annual verification review to ensure that all required documentation is complete prior to the testing window. 6. Retain all assessment security training documentation and signed agreements in accordance with federal record retention requirements under 2 CFR 200.334. Planned Evidence of Correction The School Corporation will maintain the following documentation as evidence of corrective action: ● Annual assessment security training agendas and attendance record ● Signed Indiana Testing Security and Integrity Agreements for all applicable sta􀆯 ● Centralized tracking logs indicating completion of training and agreement signatures ● Building-level verification checklists signed and dated by administrators ● Written internal procedures related to assessment system security compliance Anticipated Completion Date Implemented and ongoing beginning with the FY2026 assessment cycle.

View Audit 384594

Finding 1171318 (2025-004)

Material Weakness 2025

Eastern Greene Schools

IN

Subrecipient Monitoring Eligibility Material Weakness § 200.303 § 200.334 § 200.77 § 200.78

Finding 2025-004 Title I Grants to Local Educational Agencies – Eligibility Contact Person Responsible for Corrective Action: Superintendent and Title I Program Director Mr. Todd Tanksley Contact Phone Number and Email Address: 812-849-4481 – tanksleyto@mitchell.k12.in.us Views of Responsible Offici...

Finding 2025-004 Title I Grants to Local Educational Agencies – Eligibility Contact Person Responsible for Corrective Action: Superintendent and Title I Program Director Mr. Todd Tanksley Contact Phone Number and Email Address: 812-849-4481 – tanksleyto@mitchell.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan The School Corporation has established and implemented written internal control procedures to ensure that enrollment and poverty data reported in the October Real Time Reports are reviewed for accuracy and compared to the Title I application prior to submission. Beginning with the current grant cycle, the School Corporation will: 1. Obtain and retain copies of the October Real Time Report data used for each Title I application year. 2. Perform and document a detailed review of enrollment and poverty counts by school utilizing a worksheet that itemizes total enrollment at each school within the district, compares the low-income count according to the Real Time report, the utilized lunch software, and the counts indicated on the Title I application, and indicates a match (or variance in the event of data discrepancy) of the data among those three data sources. INDIANA STATE BOARD OF ACCOUNTS 32 3. Compare the poverty and enrollment data from the October Real Time Reports to the Eligible School Summary within the Title I application. 4. Verify poverty data using source documentation from the school lunch software system. 5. Investigate and resolve any discrepancies identified prior to submission. 6. Maintain documentation supporting the review, comparison, and verification process in accordance with federal record retention requirements under 2 CFR 200.334. Planned Evidence of Correction The School Corporation will maintain the following documentation as evidence of corrective action: ● October Real Time Reports ● Poverty and enrollment comparison worksheets ● School lunch software reports ● Signed and dated review checklists ● Copies of submitted Title I application Anticipated Completion Date Implemented and ongoing beginning with the 2026 Title I application.

View Audit 384594

Finding 1171316 (2025-003)

Material Weakness 2025

Eastern Greene Schools

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2025-03 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Dr. Emily Dykstra Contact Phone Number and Email Address: 812-849-4481 / dykstrae@mitchell.k12.in.us Views of Responsible Officials: “We concur with the finding.” Descript...

FINDING 2025-03 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Dr. Emily Dykstra Contact Phone Number and Email Address: 812-849-4481 / dykstrae@mitchell.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: Mitchell Community Schools will utilize time and effort logs to track time that personnel spend working with non-public students. These logs will be turned into the Director of Special Education at the end of each school year, so that they will be available for future audits. A time and effort log template will be created by March 6, 2026 to be utilized with personnel for future IDEA grants. Anticipated Completion Date: March 6, 2026

View Audit 384594

Finding 1171313 (2025-002)

Material Weakness 2025

Eastern Greene Schools

IN

Procurement, Suspension & Debarment § 200.303

FINDING 2025-002 Finding Subject: Child Nutrition Cluster-Procurement, Suspension and Debarment Contact Person Responsible for Corrective Action: Alda L. McIntosh Contact Phone Number and Email Address: 812-849-3663 x 1232, mcintosha@mitchell.k12.in.us Views of Responsible Officials: We concur with ...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster-Procurement, Suspension and Debarment Contact Person Responsible for Corrective Action: Alda L. McIntosh Contact Phone Number and Email Address: 812-849-3663 x 1232, mcintosha@mitchell.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Procurement • Create and maintain an internal control spreadsheet signed by the Food Service Director or Head of Maintenance, along with the Superintendent. • This procedure will ensure adequate price/rate quotations are obtained for small purchases over $10,000 and under $150,000 for all goods and services. Anticipated Completion Date: Immediately Description of Corrective Action Plan: Suspension and Debarment • Create and maintain an internal control spreadsheet signed by the Food Service Director or Head of Maintenance, along with the Superintendent. • This procedure will ensure proper verification that contractors and sub-recipients are not suspended, debarred, or otherwise excluded prior to entering into any contracts or sub-awards. Anticipated Completion Date: Immediately

View Audit 384594

Finding 1171137 (2025-001)

Material Weakness 2025

Volunteers of America Colorado

CO

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

Management did not have documented controls in place to ensure contractors are not suspended or debarred from participating in federally funded activity Planned Corrective Action: To strengthen compliance documentation and ensure consistent audit support, VOAC has implemented the following correctiv...

Management did not have documented controls in place to ensure contractors are not suspended or debarred from participating in federally funded activity Planned Corrective Action: To strengthen compliance documentation and ensure consistent audit support, VOAC has implemented the following corrective actions: 1.Policy Enhancement: The procurement procedure has been updated to explicitly require saving and retaining a time-stamped screenshot or PDF confirmation of each SAM.gov verification showing the verification date and results. Where applicable, contractors subject to 2 CFR 200.214 must also provide a self-certification statement within the executed agreement. 2.Centralized Recordkeeping: Verification evidence will be maintained in both the individual contract file and the centralized grant management system. 3.Annual Training and Refresher: Procurement and grants management staff will participate in annual training to reinforce 2 CFR 200.214 requirements and best practices for documentation and record retention. Contact person responsible for corrective action: Ian Kile, Director of Internal Control, and Chiyoko Yokota, Chief Financial Officer Anticipated Completion Date: 2/28/26

View Audit 384538

Finding 1170906 (2025-002)

Material Weakness 2025

United Social and Mental Health Services, Inc. and Subsidiaries

CT

Cash Management Significant Deficiency § 200.302 § 200.303 § 200.305

Recommendation The Organization should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding No Action Taken A new federal cash draw down form has been created that will ensure all cash draw downs are reviewed and approved by the CEO. If there are ...

Recommendation The Organization should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Repeat Finding No Action Taken A new federal cash draw down form has been created that will ensure all cash draw downs are reviewed and approved by the CEO. If there are any question regarding this plan, please e-mail Diane Manning at dvdlmanning@usmhs.org.

View Audit 384191

Finding 1170887 (2025-002)

Material Weakness 2025

Hood College of Frederick, Maryland and Affiliates

MD

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency § 200.303

Corrective Action Plan Finding Number: 2025-002 – Return of Title IV Funds Controls Finding: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Corrective Action Planned Given the size of the Financial Aid Office, the College will implement comp...

Corrective Action Plan Finding Number: 2025-002 – Return of Title IV Funds Controls Finding: There is no evidence of a control in place by the College to review Return of Title IV Fund calculations. Corrective Action Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure R2T4 calculations are accurate, timely, and compliant with federal regulations. Effective immediately, the College will implement the following controls: 1. Standardized R2T4 Processing All R2T4 calculations will be performed using the Department of Education Common Origination & Disbursement (COD) system to ensure consistent application of federal formulas. Official withdrawal dates will be confirmed using Registrar records prior to calculation. 2. Independent Post-Calculation Review Each R2T4 calculation will be reviewed by an individual other than the preparer, where feasible, or through supervisory review when staffing is limited. The review will confirm the accuracy of withdrawal dates, days attended, calculation inputs, and Title IV funds included. 3. Coordination and Reconciliation The Office of Financial Aid will coordinate with Student Accounts to ensure R2T4 results are applied correctly to the student account and that returned funds are processed within required timelines. 4. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained for each R2T4 calculation. A simple R2T4 review checklist or log will be maintained. 5. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to ensure R2T4 calculations and reviews are completed accurately and timely. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: Implemented effective August 1, 2025 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been identified. While formal independent review controls were not documented during the audit period, there were no identified R2T4 compliance issues, late returns, or calculation errors. The corrective actions above are intended to formalize review processes and further reduce compliance risk.

View Audit 384186

Finding 1170880 (2025-001)

Material Weakness 2025

Hood College of Frederick, Maryland and Affiliates

MD

Matching / Level of Effort / Earmarking Student Financial Aid Allowable Costs / Cost Principles § 200.303

Corrective Action Plan Finding Number: 2025-001 – Enrollment Reporting Controls – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to NSLDS for student enrollment status changes. Corrective Actions Planned Given the size of the F...

Corrective Action Plan Finding Number: 2025-001 – Enrollment Reporting Controls – Student Financial Aid Special Test Finding: There is no control in place by the College to review information submitted to NSLDS for student enrollment status changes. Corrective Actions Planned Given the size of the Financial Aid Office, the College will implement compensating internal controls to ensure accurate and timely enrollment reporting while maintaining operational efficiency. Effective immediately, the College will implement the following controls: 1. Continued Use of the National Student Clearinghouse (NSC) The College will continue to rely on the National Student Clearinghouse as its third-party servicer for enrollment status reporting to NSLDS. 2. Independent Post-Submission Review On a monthly basis, the Office of Financial Aid will review NSC enrollment reporting confirmation files to verify that enrollment status changes were submitted to NSLDS accurately and within the required 60-day timeframe. This review will be performed by an individual other than the primary preparer, where feasible, or through supervisory review when staffing is limited. 3. Documentation and Retention Evidence of review, including reviewer initials and date, will be retained. A simple enrollment reporting review log will be maintained to document compliance. 4. Ongoing Oversight The Director of Financial Aid will conduct periodic spot checks to confirm controls are operating as intended. Responsible Official: De Rodrick Jonkins, Director of Financial Aid Anticipated Completion Date: February 1, 2026 Additional Context The Director of Financial Aid assumed the role effective April 1, 2025, after prior corrective actions had been initiated. While formal independent review controls were not documented during the audit period, there were no identified instances of late enrollment reporting or inaccurate enrollment status submissions to NSLDS. The corrective actions above are intended to formalize controls and ensure sustained compliance with federal requirements.

View Audit 384186

Finding 1170767 (2025-001)

Material Weakness 2025

Unified School District Number 494

KS

Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

Recommendations: The District should include infrastructure items in the current inventory system. Action Taken: We agree with the recommendation. Our targeted implementation date is January 2026.

View Audit 384012

Finding 1170530 (2025-004)

Material Weakness 2025

West Harvey-Dixmoor School District 147

IL

Allowable Costs / Cost Principles Cash Management Reporting § 200.303

Condition: Three (3) monthly claims for reimbursement reported meal counts in excess of those supported by records of the District. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. In addition, und...

Condition: Three (3) monthly claims for reimbursement reported meal counts in excess of those supported by records of the District. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. In addition, underlying claim support will undergo review before claims are submitted to the ISBE. Responsible Person: Janiesa Owens, Chief School Business Official Anticipated Completion Date: June 30, 2026

View Audit 383801

Finding 1170521 (2025-003)

Material Weakness 2025

Northern Kentucky University

KY

Internal Control / Segregation of Duties § 200.303

Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will review and revise policies and procedures related to reviewing and approving Research & Development ...

Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective action will be taken: The University will review and revise policies and procedures related to reviewing and approving Research & Development grant scholarships prior to disbursement. The University will do the following:  Implement a review process to verify scholarships are reviewed and approved by Grant Administration prior to disbursement.  Provide training to relevant staff on proper documentation procedures to forward to Grant Administration to enhance compliance and accuracy.

View Audit 383774

Finding 1170520 (2025-002)

Material Weakness 2025

Northern Kentucky University

KY

Eligibility Internal Control / Segregation of Duties § 200.303

Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective actions have been taken: During the 2023-2024 academic year, EngageKY implemented a new process for recordkeeping related to the recruitment a...

Views of responsible officials and planned corrective actions: The University agrees with the auditors' finding and recommendations. The following corrective actions have been taken: During the 2023-2024 academic year, EngageKY implemented a new process for recordkeeping related to the recruitment and selection of Kentucky College Coaches. As part of the implementation, site supervisors and program staff began to use Salesforce to maintain notes from screening interviews and general interviews. The missing documentation referenced in this finding was for individuals hired prior to the new process. EngageKY will continue to use Salesforce to document the recruitment and selection of Kentucky College Coaches.

View Audit 383774

Finding 1170465 (2025-002)

Material Weakness 2025

East Allen County Schools

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) – Suspension and Debarment Contact Person Responsible for Corrective Action: Jeremiah Hruschak, Assistant Director of Financial Services; 260-0100x1006; jhruschak@eacs.k12.in.us Views of Responsible Officials: ...

CORRECTIVE ACTION PLAN FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) – Suspension and Debarment Contact Person Responsible for Corrective Action: Jeremiah Hruschak, Assistant Director of Financial Services; 260-0100x1006; jhruschak@eacs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: East Allen County Schools will establish and document a formal internal control procedure to ensure compliance with federal suspension and debarment requirements for all covered transactions (contracts, subawards, or purchases ≥ $25,000 using federal funds). The procedure will include the following: • Prior to entering any covered transaction expected to equal or exceed $25,000 with federal funds, the purchasing or accounts payable staff will verify the vendor’s status by checking SAM.gov Exclusions. • Zoom training with Directors and Grant Coordinators to verify SAM.gov for vendor disbarment. A screenshot or PDF export of the SAM.gov search results (showing the vendor is not excluded) will be obtained and attached to the purchase requisition or contract file. If not listed on SAM.gov, coordinators will request signed letters from vendors regarding status. • A standardized suspension and debarment verification checklist will be incorporated into the purchasing process for all federal-fund expenditures meeting the threshold. • Annual training (pending employee turnover) will be provided to staff involved in federal purchasing/procurement on the suspension and debarment requirements and the new verification process. • The Assistant Director of Finance perform periodic reviews of a sample of federal purchases ≥ $25,000 to confirm compliance. These controls will prevent future noncompliance with 2 CFR 180.300 and 2 CFR 200.214. Anticipated Completion Date: March 31, 2026

View Audit 383622

Finding 1170443 (2025-003)

Material Weakness 2025

Crown Point Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

FINDING 2025-003 Contact Person Responsible for Corrective Action: Diana Smith Contact Phone Number: 219-663-3371 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Along with continuing current control processes, the Registrar will include the Director...

FINDING 2025-003 Contact Person Responsible for Corrective Action: Diana Smith Contact Phone Number: 219-663-3371 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Along with continuing current control processes, the Registrar will include the Director of Grants and Assessments in the email to the Data Specialist regarding the withdrawal. A monthly report will be generated by the Data Specialist and given to the Director of Grants and Assessments to verify the withdrawals have been completed appropriately. Anticipated Completion Date: February 2026

View Audit 383598

Finding 1170441 (2025-002)

Material Weakness 2025

Crown Point Community School Corporation

IN

School Nutrition Programs Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

FINDING 2025-002 Contact Person Responsible for Corrective Action: Christine Clarahan Contact Phone Number: 219-663-3371 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A monthly checklist was created that will be used by those in the Food Services a...

FINDING 2025-002 Contact Person Responsible for Corrective Action: Christine Clarahan Contact Phone Number: 219-663-3371 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A monthly checklist was created that will be used by those in the Food Services administration team office. The checklist includes the task, line for initials and date that task was completed. Tasks include Direct Certification download, spot checking after the Direct Certification download, verifying Food Service deposits, and other monthly tasks. Anticipated Completion Date: November 18, 2025

View Audit 383598

Finding 1170413 (2025-003)

Material Weakness 2025

Elmwood Park Community Unit School District 401

IL

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

Finding No: 2025-003 Condition: The District does not have an adequate review process in place for meal count claims prior to submission. Claims prepared by one individual are submitted without independent verification. As a result, the district reported an incorrect lunch count for January 2025. Th...

Finding No: 2025-003 Condition: The District does not have an adequate review process in place for meal count claims prior to submission. Claims prepared by one individual are submitted without independent verification. As a result, the district reported an incorrect lunch count for January 2025. This error appears to be isolated to January; however, it would likely have been prevented if a review process were in place. Plan: The District will implement a system in which meal count claims will have secondary approval by the CSBO. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Mark Orszula, CSBO

View Audit 383589

Finding 1170406 (2025-003)

Material Weakness 2025

Great Plains Food Bank

ND

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.568 All Awards Federal Financial Assistance Listing # 10.569 All Awards Food Distribution Cluster Finding Summary: ...

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.568 All Awards Federal Financial Assistance Listing # 10.569 All Awards Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations and reviews for The Emergency Food Assistance Programs. Responsible Individuals: Kate Molbert, COO David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP programs have proper signatures by necessary parties going forward. An electronic signature process has been implemented to make the dissemination, review and storage of this process easier. Also, additional staffing has been hired to manage this process in the form of a Programs and Operations Compliance Manager with substantial compliance experience. Anticipated Completion Date: Immediate

View Audit 383563

Finding 1170400 (2025-004)

Material Weakness 2025

Great Plains Food Bank

ND

Allowable Costs / Cost Principles § 200.303

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.565 All Awards Federal Financial Assistance Listing # 10.568 All Awards Food Distribution Cluster Finding Summary: ...

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.565 All Awards Federal Financial Assistance Listing # 10.568 All Awards Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, multiple payroll allocation errors to programs were identified. Responsible Individuals: Kate Molbert, COO David Stachon, CFO Corrective Action Plan: This issue was fixed in FY25. The finding still exists due to July and August payrolls that occurred prior to the fix. After this was brought to our attention in the prior audit, it has been fixed going forward. We discussed this issue with our outsourced payroll provider, PRO Resources. We’ve opted into their upgraded online portal and now have access to better view, change and review allocations ourselves. Anticipated Completion Date: Completed

View Audit 383563

Finding 1170378 (2025-005)

Material Weakness 2025

Clinton Community Unit School District 15

IL

Procurement, Suspension & Debarment § 200.303

The District will review federal procurement requirements to ensure proper documentation of suspension and debarment checks of vendors, prior to contracts and purchases over the covered transaction threshold

View Audit 383519

Corrective Action Plans

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