Corrective Action Plans

Finding 1182026 (2025-002)

Material Weakness 2025

Morrison Community Unit School District No. 6

IL

Procurement, Suspension & Debarment § 200.303

Condition - The District, as a subrecipient of federal awards, contracted with multiple vendors, both directly and indirectly through the use of a purchasing cooperative, without verifying that the vendor was not suspended or debarred or otherwise excluded from participating in covered transactions....

Condition - The District, as a subrecipient of federal awards, contracted with multiple vendors, both directly and indirectly through the use of a purchasing cooperative, without verifying that the vendor was not suspended or debarred or otherwise excluded from participating in covered transactions. Plan - Bid specifications will include a statement that, by returning a bid, vendors are self-certifying that they are not suspended or debarred from participating in covered transactions. If a formal quote is not returned, we will use SAM.gov to ensure that vendors are not suspended or debarred. This search will be documented. We will verify that the purchasing cooperative is following the same procedures for all vendors. Anticipated Date of Completion - December 2025; Name of Contact Person - Dr. Matthew DeBaene, Superintendent; Management Response - We will ensure that all vendors utilized are not suspended or debarred, whether that be through vendor self-certification or the documented use of SAM.gov.

View Audit 393391

Finding 1181986 (2025-002)

Material Weakness 2025

Fremont County School District Re-2

CO

Procurement, Suspension & Debarment § 200.303

The District will implement internal controls over the suspension and debarment requirement and add this requirement to the procurement process at the District. In addition, we recommend that the District periodically review federal expenditure reports to identify vendors that may have been paid wit...

The District will implement internal controls over the suspension and debarment requirement and add this requirement to the procurement process at the District. In addition, we recommend that the District periodically review federal expenditure reports to identify vendors that may have been paid with federal grants in excess of the $25,000 suspension and debarment threshold to prevent potential noncompliance. All district employees who are approved to obtain bids for purchases have already been informed and trained on the expectation on obtaining proof of suspension and debarment requirements from any vendor they receive bids from or plan on making purchases from that will exceed the $25,000 threshold. Responsible Official: Mandee Campbell, Director of Business Services Anticipated Completion Date: April 1, 2026

View Audit 393345

Finding 1181953 (2025-001)

Material Weakness 2025

Lawrence Union Free School District

NY

School Nutrition Programs § 200.303

Significant Deficiency 2025-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010A United States Department of Agriculture, passed through New York State Department of Education Child Nut...

Significant Deficiency 2025-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010A United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster Non-Cash Assistance (food distribution) National School Lunch Program ALN: 10.555 Cash Assistance School Breakfast Program ALN: 10.553 National School Lunch Program ALN: 10.555 Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District has developed a policy entitled “Procurement: Uniform Grant Guidance for Federal Awards” that addresses the Uniform Guidance requirements related to procurement. This policy was presented to the Board of Education at the August 28, 2025 Board meeting and formally adopted by the Board of Education at the November 17, 2025 Board meeting. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated completion date: The required policy was adopted by the Board of Education at its November 17, 2025 meeting.

View Audit 393231

Finding 1181942 (2025-003)

Material Weakness 2025

Rensselaer Central School Corporation

IN

Matching / Level of Effort / Earmarking § 200.207 § 200.303

Views of Responsible Offocials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Non-Public Proportionate Share Finding (FY 2024) • Revised Procedures o Internal procedures will be updated to plan, track, and ensure non-public proportionate share expenditures m...

Views of Responsible Offocials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Non-Public Proportionate Share Finding (FY 2024) • Revised Procedures o Internal procedures will be updated to plan, track, and ensure non-public proportionate share expenditures meet minimum requirements before grant funds are fully expended. • Monitoring and Verification o Fiscal staff will monitor non-public expenditures throughout the grant period and verify documentation demonstrates direct benefit to eligible non-public students. • Staff Training o Staff and Cooperative personnel will receive training on non-public proportionate share requirements and allowable expenditures. • Future Compliance Measures o Strategies will be implemented to prevent shortfalls in future grant periods, including early adjustments to spending plans to ensure full compliance. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.

View Audit 393212

Finding 1181939 (2025-002)

Material Weakness 2025

Rensselaer Central School Corporation

IN

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.309 § 200.461

Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Period of Performance Finding (FY 2024) • Improved Internal Controls o Rensselaer Central and Cooperative School Services will implement additional review procedures to ensure all ...

Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Period of Performance Finding (FY 2024) • Improved Internal Controls o Rensselaer Central and Cooperative School Services will implement additional review procedures to ensure all federal grant obligations occur within the allowable grant period and that vendor payments align with the original approved purchase orders. • Verification of Obligation Dates o Fiscal staff will verify that purchase orders, vendor invoices, and final payments reflect an obligatory date that occurs prior to the applicable grant deadline. • Staff Training o Rensselaer Central and Cooperative School Services Fiscal personnel involved in grant management will receive training on federal grant period of performance requirements and proper documentation of obligations. • Monitoring Procedures o Rensselaer Central and Cooperative School Services will conduct periodic reviews of federal grant expenditures to ensure ongoing compliance with grant timelines. • Statement of Isolated Occurrence o Rensselaer Central and Cooperative School Services reviewed the circumstances surrounding this finding and determined that the issue was isolated to fiscal year 2024. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.

View Audit 393212

Finding 1181935 (2025-001)

Material Weakness 2025

Rensselaer Central School Corporation

IN

Allowable Costs / Cost Principles § 200.303 § 200.403

Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Audit Finding (FY 2023–2024) • Revision of Written Procedures o The Rensselaer Central, in coordination with Cooperative School Services, will revise and implement written procedur...

Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Audit Finding (FY 2023–2024) • Revision of Written Procedures o The Rensselaer Central, in coordination with Cooperative School Services, will revise and implement written procedures governing the administration of proportionate share funds for non-public schools to ensure compliance with federal grant requirements. (see IDEA Procurement Plan Earmarking for Non Pub CEIS Funds hyperlinked above) • Strengthening Internal Controls o Additional internal controls will be implemented requiring review and approval by the Director of Special Education, Bookkeeper, and Rensselaer Central Treasurer prior to any reimbursement related to non-public school expenditures funded through the Special Education grant. • Reimbursement Process Changes o Non-public schools will no longer receive reimbursements directly from Cooperative School Services. Cooperative School Services will receive approval and verification from the Non-Public School LEA. o All reimbursement requests must include detailed documentation demonstrating that the expenditure directly benefits eligible non-public school students receiving special education services. • Allowable Cost Verification o Rensselaer Central and Cooperative School Services will implement a verification process to ensure all expenditures comply with federal allowable cost requirements and that funds are used solely for the benefit of eligible non-public school students. • Staff Training o Rensselaer Central and Cooperative School Services personnel responsible for federal grant oversight will receive training on federal grant compliance requirements, including allowable and unallowable expenditures (e.g., gift cards and similar incentives). • Monitoring and Oversight o Rensselaer Central will conduct periodic monitoring of expenditures made on its behalf by Cooperative School Services and maintain documentation demonstrating compliance with oversight responsibilities. • Implementation Timeline o These corrective actions and revised procedures have already been implemented and will apply to all future federal Special Education grant expenditures. • Ongoing Compliance Monitoring o Rensselaer Central and Cooperative School Services will conduct annual reviews of federal grant expenditures and internal controls to ensure continued compliance with IDOE and federal grant requirements. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.

View Audit 393212

Finding 1181874 (2025-001)

Material Weakness 2025

Urban Collaborative

RI

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

February 24, 2026 Cognizant or Oversight Agency for Audit Urban Collaborative respectfully submits the following corrective action plan for the fiscal year ended June 30, 2025. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01748 Audit peri...

February 24, 2026 Cognizant or Oversight Agency for Audit Urban Collaborative respectfully submits the following corrective action plan for the fiscal year ended June 30, 2025. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01748 Audit period: July 1, 2024 - June 30, 2025 The finding from the June 30, 2025 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING - FINANCIAL STATEMENT AUDIT FINDINGS Significant Deficiency 2025-001 Internal Control - Payroll and Cash Disbursement Recommendation: AAFCPAs recommends the Collaborative strengthen internal controls by requiring supervisory approval of all timesheets prior to payroll processing, implementing review procedures to ensure payroll amounts agree to authorized pay rates, and reconciling disbursements to invoices and monitoring outstanding reimbursement checks to ensure resolution. The Collaborative acknowledges the findings related to internal controls over payroll and cash disbursements. While the monetary values of the identified variances were minor, management recognizes the importance of maintaining rigorous oversight to ensure full compliance with federal laws and to mitigate the risk of misstatement. To address these concerns, the Collaborative is continuing to implement the following corrective actions: 1. Enhanced Payroll Approval Process: Timesheets are approved by the respective supervisor and then sent to the Executive Director for final approval prior to payroll submission. 2. Pay Rate Verification: The finance department will implement a secondary review procedure to ensure that all payroll amounts align precisely with authorized pay rates. This cross-verification will occur prior to each payroll cycle to prevent future rate variances. 3. Disbursement Reconciliation: Management is updating its cash disbursement procedures to require a formal reconciliation of every check or payment against its original invoice. This process will ensure that no payment exceeds the authorized invoiced amount. 4. Monitoring Reimbursements: The Collaborative will establish a monthly review of all outstanding reimbursement checks and related documentation to ensure timely and accurate resolution of all financial obligations. If the Department of Education has questions regarding this plan, please call Lynn Prentiss, Executive Director at 401-272-0881. Sincerely yours, Lynn Prentiss Executive Director

View Audit 393175

Finding 1181872 (2025-001)

Material Weakness 2025

State System of Higher Education, Commonwealth of Pennsylvania

PA

Questioned Costs Student Financial Aid Reporting § 200.303

2025-001 Student Financial Aid Cluster – Assistance Listing Numbers 84.063 and 84.268 In general, Cheyney University continues its trajectory of cross-functional and interrelated institutional improvements, particularly those impacting the National Student Loan Data System (NSLDS) that is reported t...

2025-001 Student Financial Aid Cluster – Assistance Listing Numbers 84.063 and 84.268 In general, Cheyney University continues its trajectory of cross-functional and interrelated institutional improvements, particularly those impacting the National Student Loan Data System (NSLDS) that is reported through National Student Clearinghouse (NSC). Cited in the CLA Single Audit, nonetheless, are instances of inaccurate, late, or not reported enrollment and program level data to NSLDS. This response is intended to explain these reporting deficiencies and offer a corrective plan of action including timelines. Point Of Contact: • Dr. Denise Pearson, Provost – dpearson@cheyney.edu • Stephanie Stevens, Associate Registrar – sstevens@cheyney.edu • Jean Dixon, Associate Registrar – jedixon@cheyney.edu Explanations: This section represents Cheyney University’s effort to explain the causes for CLA Single Audit finding. Although the reporting deficiencies span multiple years, it is instructive to note that they are attributed to various and differing circumstances. While Cheyney University was on HCM2, the delay in Claims processing impacted the reporting in Common Origination and Disbursement (COD) and the reporting to NSLDS. The delays in approved claims caused an impact on NSLDS postings for enrollment reporting. This required Cheyney University administration to transfer from NSC to manual enrollment entry into NSLDS. The idea was to manually enter students’ records in NSLDS so that students’ enrollment could be reported more quickly. This is referenced in Single Audit Report, June 30, 2022; page 132. Cheyney is acutely focused on working toward compliance with NSLDS reporting requirements. Through this lens, it was discovered that during the 2024-2025 conversion to the Ellucian Banner system certain decisions were made regarding the conversion of student academic histories. During the research of errors and warning records received from the NSC upload, it was determined that program level information was not properly ported over to the new system. Cheyney University is pursuing a corrective course of action to improve this data to ensure accuracy in reporting. In May 2025, Cheyney University and NSC amended its agreement resulting in a shift in reporting student enrollment and program level data back to NSC from NSLDS that resulted in an additional delay in reporting. Due to these circumstances, the university dedicated significant resources to building capacity and capability in the Office of the Registrar, the functional area responsible for NSLDS reporting. These resources are being deployed in a variety of ways as noted in the Corrective Action Plan below. Corrective Action Plan Overview: 1. Hired a season University Registrar with superior, proven, leadership and technical skills. Emphasis has been placed on performance metrics that align with operational goals and objectives. STATUS: Anticipated March 2026. 2. Targeted professional development for Office of the Registrar and other staff including Banner training, NSC/NSLDS Reporting, and other dependencies. STATUS: Ongoing 3. Establishment of a dedicated compliance unit to support the university’s policies, standards, and procedures ecosystem. STATUS: Completed December 2025. 4. Hired a dedicated Chief Information and Technology Officer (as opposed to the use of third-party vendors). STATUS: Completed, March 2026. 5. Prioritized strengthening communication and collaboration with other enrollment management areas to establish cross-functional responsibilities and timelines (e.g., financial aid, admissions, and bursar offices). STATUS: Ongoing. Key Performance Indicators: During the Spring and Fall 2026 semesters: 1. The University Registrar will show outcomes-driven leadership practices that foster improved departmental performance, including audit citations. 2. Registrar and adjacent staff will demonstrate comprehensive capability and capacity in all areas related to NSC and NSLDS operations and reporting on a timely schedule. An organizational calendar is being developed to ensure this goal is met. 3. Utilizing the NSLDS instructional guide, train the Registrar and adjacent staff to improve the knowledge of the step-by-step process procedures for enrollment reporting, error correction, warning management, and internal audit review of NSLDS files. 4. Develop NSC instructional guide on reporting, error and warning management, and submission of monthly reporting data. 5. The Director of Policy and Compliance will collaborate with the Office of the Provost and Registrar Office staff to create and maintain a policy, procedures, and standards environment that supports operational excellence and efficiency (including more timely and accurate reporting). 6. The Chief Information and Technology Officer will conduct a comprehensive assessment of technology needs in the Office of the Registrar, including outcomes driven recommendations. 7. The Provost will establish Office of the Registrar protocols for collaboration with the Office of Communications to reinforce clarity, consistency, and transparency in all related matters. 8. The University Registrar will demonstrate that all staff have the requisite knowledge and skills to effectively mitigate future reporting deficiencies. Cheyney University acknowledges and affirms that this corrective action will be implemented, assessed, and become a standard operating procedure.

View Audit 393174

Finding 1181872 (2025-001)

Material Weakness 2025

State System of Higher Education, Commonwealth of Pennsylvania

PA

Questioned Costs Student Financial Aid Reporting § 200.303

Recommendation: The University should review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findin...

Recommendation: The University should review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Increased frequency of NSC Submissions. Completing the error files returned to NSC quickly within the first 1-4 days of receipt after sending the files back. • We met with another PASSHE school on 4/22/25 and they helped us to strategize ensuring we meet the 60-day window for withdrawals by individually updating the withdrawal information in NSC on a weekly basis using our withdrawal report to identify each student withdrawal between our regular submissions. (Because we met with them so late in the audit cycle, we were not able to correct course for FY25 in time.) • We have adjusted our degree verification timeline, ensuring that the large bulk of our degree verification submission to NSC is completed within 2 weeks of the end of the graduating semester, ensuring that the bulk of our graduating students are moved from NSC to NSLDS sooner. • We updated our change of major policy to ensure that students are not changing majors after the end of the drop/add period. Prohibiting mid-semester major changes for the current semester will greatly reduce the number of status change errors reflected in NSC. This cleaner approach ensures less risk of error or delay related to volume. This was formalized with KU Policy ACA-029, approved at Senate on 9/4/25. Name(s) of the contact person(s) responsible for corrective action: Ben Trout, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 393174

Finding 1181869 (2025-001)

Material Weakness 2025

Young at Heart Resources

MO

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.430

Finding Reference Number: 2025-001 Federal Agency: U.S. Department of Health and Human Services Program Name: Aging Cluster Assistance Listing Number: 93.044/93.045/93.053 Responsible Official: Penny Crawford, Chief Executive Officer; Kelsey Swinderman, Financial Manager Views of Responsible Individ...

Finding Reference Number: 2025-001 Federal Agency: U.S. Department of Health and Human Services Program Name: Aging Cluster Assistance Listing Number: 93.044/93.045/93.053 Responsible Official: Penny Crawford, Chief Executive Officer; Kelsey Swinderman, Financial Manager Views of Responsible Individuals: The Agency acknowledges the documentation deficiencies identified related to payroll and contract management. These issues were largely due to leadership transitions and changes in operational processes. The Agency has evaluated these gaps and is actively implementing corrective actions to strengthen internal controls and ensure compliance with Uniform Guidance requirements. Corrective Action Plan: Corrective actions currently in progress include: • Standardizing documentation requirements for all employee pay rates, including maintaining supporting documentation within personnel files • Implementing internal review procedures to ensure payroll changes align with Board-approved actions • Centralizing contract management and maintaining all executed service provider agreements in a secure, accessible location • Establishing documentation retention procedures to ensure all supporting records for federal award expenditures are complete and readily available for audit review The Agency is committed to fully resolving these issues and strengthening internal processes to ensure ongoing compliance and accountability. The Agency is implementing enhanced internal control procedures to ensure that all costs charged to federal awards are properly authorized, documented, and maintained in accordance with federal requirements. These improvements include the development of standardized processes for payroll documentation, contract management, and documentation retention. Internal review procedures are also being strengthened to ensure alignment between Board approvals and financial records. Anticipated Completion Date: June 30, 2026

View Audit 393170

Finding 1181861 (2025-002)

Material Weakness 2025

Springs Valley Community Schools Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.303 § 200.317 § 200.318 § 200.327

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the fi...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In the future, the Treasurer will check the SAM exclusion list prior to entering into a covered transaction with federal awarded funds. There will also be a documented, secondary review to ensure the suspension and debarment requirement has been checked. Anticipated Completion Date: 02/04/2026

View Audit 393146

Finding 1181839 (2025-003)

Material Weakness 2025

Lutheran Social Services of Central Ohio

OH

Material Weakness Internal Control / Segregation of Duties Questioned Costs § 200.303

Condition: During the current year, the Organization did not apply the sliding fee scale discount to certain patient claims accurately. During our testing, we noted 13 instances of the sliding fee scale not being accurately applied to patient services out of the 40 transactions tested. Planned Corre...

Condition: During the current year, the Organization did not apply the sliding fee scale discount to certain patient claims accurately. During our testing, we noted 13 instances of the sliding fee scale not being accurately applied to patient services out of the 40 transactions tested. Planned Corrective Action: Management acknowledges the sliding fee scale discount should have been applied consistently and accurately and plan to improve the process going forward. Management corrected the patient accounts by applying the sliding fee scale discount. Contact person responsible for corrective action: Julie Fratianne, CFO Anticipated Completion Date: June 30, 2026

View Audit 393120

Finding 1181831 (2025-003)

Material Weakness 2025

Idaho State University

ID

Questioned Costs Student Financial Aid Allowable Costs / Cost Principles § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the University review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanatio...

Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the University review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is prepared to return the FY25 FWS Unspent portion of the 7% Community Service required spending (7% of Final FWS Funding of $742,211 = $51,954.77 (rounded to $51,955) [Community Service spending requirement] minus $25,061 (FWS funds spent in community service as reported on FISAP) = $26,894 (Unspent portion of 7% to be returned to ED). Since the pandemic year, ISU’s off-campus (community service) participation has been dwindling and overall FWS participation has suffered since many students and employers are opting to be involved in the University’s Career Path Internship (CPI) program over FWS. Due to the struggles in recent years to meet the 7% Community Service requirement, ISU has been applying for a waiver of the Community Service requirement but thus far our waiver requests have been denied. The Financial Aid Office is reviewing current processes related to tracking FWS Community Service spending and partnering with the Career Center to proactively identify off-campus participants and looking at ways to cooperate with the University’s CPI program participants who are FWS-eligible and who are working in Community Service activities and plan to expand on-campus FWS Community Service opportunities to meet the minimum 7% community service requirement. Name(s) of the contact person(s) responsible for corrective action: James Martin, Director of Financial Aid and Katheryn Wareing, Senior Accountant for Financial Aid/FWS Administrator Planned completion date for corrective action plan: 08/24/2026

View Audit 393093

Finding 1181828 (2025-002)

Material Weakness 2025

Idaho State University

ID

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.033, 84.268, 84.063 & 84.007 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement wit...

Student Financial Assistance Cluster – Assistance Listing No. 84.033, 84.268, 84.063 & 84.007 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for 2024-004 Finding’s Recurrence: Related to case identified where a corrected Last Date of Attendance (Effective Date in Banner System on SFAWDRL input by the Financial Aid Office for a fully online student during the Unofficial Withdrawal [post term] Return of Title IV processing) was not carried over to Status Date in Banner maintained by the Registrar’s Office and to NSC/NSLDS so that all are reporting the accurate Last Date of Attendance, the University found that corrected dates during the semester aligned and were being reported to NSC/NSLDS in a timely manner, but that corrected dates after end of term were not being transmitted to NSC and NSLDS. Related to case identified of not reporting Graduated status to NSLDS in a timely manner: Typically, it takes approximately 2–3 weeks after commencement to clear degree audits and begin awarding degrees, as commencement occurs before final grades are released. The Graduate-only upload to NSC was completed on May 21, 2025.However, due to limitations with the National Student Clearinghouse (NSC) system, which does not accept multiple awards being posted simultaneously, we received an error report affecting approximately 60% of our graduates. Records included in this report must be corrected manually, which is a time-consuming process. We actively work to correct these records as quickly as possible within our current human resource limitations. The corrected error file related to the 2025-002 finding was uploaded to NSC on July 11, 2025, and sent to NSLDS on 7/12/2025. Action taken in response to finding: The University reviewed its procedures and implemented steps in our Unofficial Withdrawal [post term] Return of Title IV business process to include an email communication plan between the Financial Aid staff and the Office of the Registrar along with documentation sharing and added review steps to ensure the post-term corrected Last Date of Attendance is updated in all affected institutional and federal systems in a timely manner. The Office of the Registrar will correct errors returned from NSC within four weeks of receiving the file. To ensure this task is completed in a timely manner, we will allocate additional human resources as needed. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar, and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 08/06/2025

View Audit 393093

Finding 1181812 (2025-001)

Material Weakness 2025

Idaho State University

ID

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University reviewed its procedures and reporting processes and added calendar reminders to run queries around our census day each term (since the case identified in the audit was due to a timing issue of a student’s aid period revision and when our automated Exit counseling processes are turned on) to find students who were missed by our automated processes for the adding of EXIT tracking requirement and ensuring timely notifications to the students. Name(s) of the contact person(s) responsible for corrective action James Martin, Director of Financial Aid and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 8/12/2025

View Audit 393093

Finding 1181772 (2025-003)

Material Weakness 2025

Manor College

PA

Reporting Student Financial Aid Significant Deficiency § 200.303

Management is formalizing written enrollment reporting procedures to ensure timely and accurate reporting to NSLDS. Until implementation of a new student information system, enrollment reporting will continue to be performed manually, with monthly supervisory review and documentation of submissions....

Management is formalizing written enrollment reporting procedures to ensure timely and accurate reporting to NSLDS. Until implementation of a new student information system, enrollment reporting will continue to be performed manually, with monthly supervisory review and documentation of submissions. Automation of enrollment reporting is expected upon implementation of the new SIS.

View Audit 393057

Finding 1181741 (2025-002)

Material Weakness 2025

The Hektoen Institute of Medicine, LLC

IL

Questioned Costs Subrecipient Monitoring Cash Management § 200.303 § 200.305

Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: Management acknowledges the finding. Delays in approvals may occur due to multiple internal and external parties involved. To prev...

Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: Management acknowledges the finding. Delays in approvals may occur due to multiple internal and external parties involved. To prevent recurrence, management will monitor all parties, issue email reminders with clear deadlines, and enforce timely processing to ensure compliance with the 30-day requirement. Contact person responsible for corrective action: Teresa Martinez, Lorena Soto, Alvaro Espino and Mariela Romo Anticipated Completion Date: 8/31/2026

View Audit 392991

Finding 1181740 (2025-001)

Material Weakness 2025

The Hektoen Institute of Medicine, LLC

IL

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.317 § 200.318 § 200.327

Condition: Controls were not sufficient to ensure that the history of procurement decisions was documented, as required by 2 CFR 200. Additionally, controls were not sufficient to ensure checks for suspension and debarment were documented before entering into covered transactions with third-parties....

Condition: Controls were not sufficient to ensure that the history of procurement decisions was documented, as required by 2 CFR 200. Additionally, controls were not sufficient to ensure checks for suspension and debarment were documented before entering into covered transactions with third-parties. Planned Corrective Action: Management will continue to strengthen internal controls through the revised Procurement Policy, enhanced documentation requirements, and clarified approval procedures. A centralized tracking database has been implemented to document sanctions, suspension, and debarment checks, as well as other required verifications based on the nature of each purchase or service. These procedures are required prior to entering into covered transactions and are monitored through dual staff reviews. Management believes that ongoing monitoring and consistent enforcement of these procedures will ensure compliance and prevent recurrence. Contact person responsible for corrective action: Teresa Martinez, Lorena Soto, Alvaro Espino and Mariela Romo Anticipated Completion Date: 8/31/2026

View Audit 392991

Finding 1181729 (2025-004)

Material Weakness 2025

Workforce Development Board Work4wv Region 1, Inc.

WV

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

2025-004 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Take...

2025-004 Activities Allowed or Unallowed U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all charges to federal programs are adequately reviewed and approved prior to payment. Action Taken: The Board will evaluate existing review and approval processes for federal program charges and implement appropriate controls to ensure all expenditures are thoroughly reviewed, properly authorized, and fully supported before payment is made. As part of the review of charges, a daily review of invoices will be implemented to ensure that all invoices coded to WIOA are allowable costs. The Board’s allowable costs are reviewed by three members: Fiscal Coordinator, Fiscal Manager and Executive Director. These are reviewed and approved by each before the costs are paid. Evidence of these allowable costs will have reviewer’s initials and date reviewed on the bills/invoices themselves and a checklist with signatures that they have reviewed these.

View Audit 392981

Finding 1181728 (2025-003)

Material Weakness 2025

Workforce Development Board Work4wv Region 1, Inc.

WV

Questioned Costs Reporting Matching / Level of Effort / Earmarking § 200.303

2025-003 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board will design and implemen...

2025-003 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board will design and implement enhanced controls to ensure compliance with all reporting requirements by evaluating the existing reporting procedures and work to strengthen controls around preparation, review, and submission. These measures will help ensure that all reports are prepared accurately, reviewed appropriately, and submitted in a timely manner. We will proceed in this manner by training personnel in preparation and review. We will create a checklist so the breakdown in this report can be verified as correct and complete. Reports will not be submitted until these procedures have been completed.

View Audit 392981

Finding 1181727 (2025-002)

Material Weakness 2025

Workforce Development Board Work4wv Region 1, Inc.

WV

Matching / Level of Effort / Earmarking Questioned Costs § 200.303

2025-002 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: We recognize that ...

2025-002 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: We recognize that full compliance with the Uniform Guidance earmarking requirements is essential. The Board will implement additional controls and procedures to ensure adherence to these standards. We will strengthen these controls by training personnel on the specific steps required and ensuring they fully understand the compliance requirements. Additionally, we will enhance our monitoring processes to verify that all obligations are properly documented and followed. In addition, we will implement additional controls by including checklists to confirm actions and approvals for accounts payable, account reconciliations, review of the general ledger, review of deposits and journal entries. The referred to actions will be presented monthly via email to the executive committee of the Board.

View Audit 392981

Finding 1181719 (2025-003)

Material Weakness 2025

Fayette County School Corporation

IN

Equipment & Real Property Management § 200.303 § 200.313

FINDING 2025-003 Finding Subject: Head Start Cluster – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Tina Smith Contact Phone Number and Email Address: (765) 825-2178 tlsmith@fayette.k12.in.us Views of Responsible Officials: We concur with this finding. Des...

FINDING 2025-003 Finding Subject: Head Start Cluster – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Tina Smith Contact Phone Number and Email Address: (765) 825-2178 tlsmith@fayette.k12.in.us Views of Responsible Officials: We concur with this finding. Description of Corrective Action Plan: The Treasurer will work closely with Ad-Tech to ensure that all required information is reported accurately. Anticipated Completion Date: The capital assets inventory list will be updated to include the above required information beginning with the 2025-2026 Inventory Report.

View Audit 392978

Finding 1181718 (2025-002)

Material Weakness 2025

Fayette County School Corporation

IN

Matching / Level of Effort / Earmarking § 200.303

FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) -- Earmarking Contact Person Responsible for Corrective Action: Tina Smith Contact Phone Number and Email Address: (765) 825-2178 tlsmith@fayette.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 26 2 Views of Responsible Officials: We concu...

FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA) -- Earmarking Contact Person Responsible for Corrective Action: Tina Smith Contact Phone Number and Email Address: (765) 825-2178 tlsmith@fayette.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 26 2 Views of Responsible Officials: We concur with this finding. Description of Corrective Action Plan: It is increasingly difficult to get our non-public schools to spend their grant money. However, to address the internal control finding, we will strengthen subrecipient monitoring by implementing clearer expenditure timelines for subrecipient entities associated with the grant to ensure awarded funds are expended properly and in a timely manner in accordance with grant requirements. We will also provide additional technical assistance and guidance regarding allowable costs and conduct more frequent financial reviews throughout the grant cycle. These measures will promote timely use of funds, improve compliance with grant requirements, and reduce the risk of unspent or improperly managed grant resources in future periods. Anticipated Completion Date: A new procedure is in place effective February 2026.

View Audit 392978

Finding 1181652 (2025-001)

Material Weakness 2025

The Johns Hopkins University

MD

Allowable Costs / Cost Principles § 200.303 § 200.309 § 200.403

Corrective Action Plan: The University accepts this finding and has removed the questioned costs from the award. Management will reinforce and reiterate the internal controls process to the staff responsible for the review of the grant expenditures during the financial reporting process. Management ...

Corrective Action Plan: The University accepts this finding and has removed the questioned costs from the award. Management will reinforce and reiterate the internal controls process to the staff responsible for the review of the grant expenditures during the financial reporting process. Management will also communicate via our Financial Administrative Bulletin to the grants administration community our internal controls around 2 CFR 200. Management will conduct 2 CFR 200 training with the impacted departmental grant administration by March 5, 2026 Completion Date: March 31, 2026 Contact Person: Paul Gasior 443-997-8141

View Audit 392931

Finding 1181627 (2025-001)

Material Weakness 2025

Brenau University

GA

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2025-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, one (1) student graduation was reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review an...

Finding 2025-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, one (1) student graduation was reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal requirements. Persons Responsible for Corrective Action: Registrar Liz Force Planned Corrective Action: The Registrar will update NSLDS reporting processes and controls to include detection controls to ensure all student graduations, including those occurring outside the traditional reporting window, are accurately and timely reported to the NSLDS within the maximum 60-day window. Anticipated Completion Date: December 31, 2025

View Audit 392908

Corrective Action Plans

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