Corrective Action Plans

Finding 525679 (2024-003)

Significant Deficiency 2024

Flat Rock - Haw Creek School Corporation

IN

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

Context: For one sponsor claim reimbursement in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Contact P...

Context: For one sponsor claim reimbursement in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: I have spoken to the Food Service Director to ensure that 2 individuals are signing off on all the claims. Anticipated Completion Date: 3/1/2025

View Audit 344796

Finding 525676 (2024-002)

Material Weakness 2024

Flat Rock - Haw Creek School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guid...

Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: I have spoken to the Food Service Director and she will begin printing the Skyward threshold guidelines and sign off on those/confirm they match the federal poverty guidelines. Anticipated Completion Date: August 2025

View Audit 344796

Finding 525652 (2024-001)

Material Weakness 2024

Lebanon Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

1. Corrective Action Step A. Strengthening Internal Controls Over Determination of Applications Demonstrating Questionable Eligibility The School Corporation will develop and implement a segregation of duties, ensuring that current individuals approve applications, perform Direct Certification check...

1. Corrective Action Step A. Strengthening Internal Controls Over Determination of Applications Demonstrating Questionable Eligibility The School Corporation will develop and implement a segregation of duties, ensuring that current individuals approve applications, perform Direct Certification checks, and conduct follow-up verifications of questionable applicatoins in a more directed manor. If an applicant provides a case number that does not appear on the Direct Certification list the School Corporation will: 1. Review the application based on standard income eligibility requirements, while confirming the application will remain subject to verification. 2. If $0 income is provided or the application is otherwise 'questionable' then the reviewing individual will add the following to the application comments field: reviewing individual name, reason for review request, to whom the application will be escalated. 3. Apply benefits to siblings, if appropriate. 4. Not complete the final step of marking the application as processed, rather leave it 'pending' and notify Director of School Nutrition of the need for this application to be reviewed. 5. Director of School Nutrition or designee will review and either confirm the DC status by downloading the certification or conduct follow-up verification. In either case, approved or verification for cause, the Director of School Nutrition or Designee will mark the application as processed. 6. If the verification for cause is not responded to in a timely manner, the status will revert to 'Paid' status as per 'verification for cause' guidelines. 2. Corrective Follow-Up and Reporting The School Corporation will review all applications from current year (FY 24-25) to identify any applications not subject to verification process. Management will report progress on implementing these corrective actions to the School Board and maintain records for review by auditors and state officials. 3. Anticipated Completion Date The review of current year (FY 24-25) applications will be completed March 21, 2025. The school board report will be completed April 11, 2025.

View Audit 344763

Finding 525650 (2024-002)

Material Weakness 2024

Yancey County, North Carolina

NC

Eligibility Material Weakness Matching / Level of Effort / Earmarking § 200.303

The County will develop a 2nd Party Review from that will be used to check completed applications for accuracy in applying policy and to assure all verifications have been uploaded to the NCFAST system.

View Audit 344762

Finding 525631 (2024-001)

Material Weakness 2024

Essex North Supervisory Union

VT

Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.303

CORRECTIVE ACTION PLAN (Concerning Finding 2024-001) Contact person responsible for corrective action: Jennifer Lawcewicz, Superintendent Corrective Action: The Essex North Supervisory Union will take the following actions to address finding 2024-001- Activities Allowed and Allowable Costs: 1. Essex...

CORRECTIVE ACTION PLAN (Concerning Finding 2024-001) Contact person responsible for corrective action: Jennifer Lawcewicz, Superintendent Corrective Action: The Essex North Supervisory Union will take the following actions to address finding 2024-001- Activities Allowed and Allowable Costs: 1. Essex North Supervisory Union has created a purchasing and procurement procedure manual with detailed procedures. 2. The business manager and superintendent have shared this document with all employees that are involved in purchasing. 3. The business manager and the superintendent will have regular mee􀆟ngs with the principal and grants manager to ensure that all procedures are being followed. 4. All invoices will con􀆟nue to be reviewed by the business manager or the superintendent. 5. Contracts will be issued for all work to be performed prior to the ini􀆟a􀆟on of the work. 6. Time sheets will con􀆟nue to be filled out for all hourly employees.

View Audit 344752

Finding 525551 (2024-003)

Material Weakness 2024

Jay County School Corporation

IN

Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.320

Context: For the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The total amount disbursed for the sample items was $146,895 in FY23 and $69,793 in FY24 for contracted occupational ...

Context: For the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The total amount disbursed for the sample items was $146,895 in FY23 and $69,793 in FY24 for contracted occupational therapy and physical therapy services. The School Corporation did properly confirm the sample vendors were not debarred or suspended. Contact Person Responsible for Corrective Action: Shannon Current Contact Phone Number: 260-726-9341 Views of Responsible Official: We concur with the finding now that we are aware this must be done for contracted services. Prior to the audit, for at least 12 years, we were not aware this was to be done for contracted services. During prior audits, this was never brought to our attention. Description of Corrective Action Plan: Moving forward, we will make sure to solicit three quotes for contracted services that will be more than $50,000. Anticipated Completion Date: As soon as our next contracted service contract is to be entered into which will most likely be in May 2025 prior to the next school year.

View Audit 344628

Finding 525547 (2024-002)

Material Weakness 2024

Jay County School Corporation

IN

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

Context: During testing of activities allowed and unallowed/allowable costs, it was noted the School Corporation transferred $48,693 from the School Lunch Fund to the JCHS Prepaid Food/Trust Acct to settle negative student balances deemed uncollectible. Outstanding student debt resulting from nonpa...

Context: During testing of activities allowed and unallowed/allowable costs, it was noted the School Corporation transferred $48,693 from the School Lunch Fund to the JCHS Prepaid Food/Trust Acct to settle negative student balances deemed uncollectible. Outstanding student debt resulting from nonpayment of school meals or milk is an unallowable expenditure to the nonprofit school food service account and cannot be absorbed by the food service program at the end of the school year. It must be paid for with other non-federal sources. Contact Person Responsible for Corrective Action: Shannon Current Contact Phone Number: 260-726-9341 Views of Responsible Official: We concur with the finding now that we have more clarifying information. Prior to this audit, we were told we had to use non-federal funds to write off the debt. The published documentation we had was vague as it only stated non-federal funds. With the assistance of our food service company, we were told that catering, adult meals, and al a carte were all non-federal funds. They also had a calculation for figuring out the amount of non-federal funds that we had to make sure it was enough to cover the negative debt. Description of Corrective Action Plan: Moving forward, I will make sure that any negative debt is written off using the operations fund, rainy day, or other approved fund. Anticipated Completion Date: The next time we are required to write off debt. Possibly June 30, 2025.

View Audit 344628 Questioned Costs: $1

Finding 525546 (2024-001)

Material Weakness 2024

University of Wisconsin Hospitals & Clinics Authority

WI

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.317 § 200.318 § 200.319 § 200.320

Finding: While testing the procurement requirement, we noted that internal controls were not properly designed over the procurement requirement. Prior to receiving federal funding beginning in August 2022, the program conducted a request for proposal (RFP) process and began contracting with a vendor...

Finding: While testing the procurement requirement, we noted that internal controls were not properly designed over the procurement requirement. Prior to receiving federal funding beginning in August 2022, the program conducted a request for proposal (RFP) process and began contracting with a vendor. When federal funding was obtained, the vendor was not reevaluated in accordance with the Uniform Guidance to ensure the procurement requirements were being met. In addition, we noted UW Health – Madison’s procurement policy documents do not include all of the information that is required by the Uniform Guidance. Correction actions taken or planned: Management became aware of the need to perform additional procedures to comply with Uniform Guidance part way through the year ended June 30, 2024 and completed the evaluation once it became known. However, by that time, the vendor was already charged to the grant prior to the completion of the vendor evaluation. UW Health has developed processes and procedures to ensure compliance with the Uniform Guidance and that evaluations are taking place prior to any vendors being charged to the grant. UW Health is also in the process of updating policy to comply with Uniform Guidance. Anticipated completion Date: June 2025 UW Health employees responsible for Corrective Action Plan: James Hood, Director of Procurement Services and Jamie Soyk, Program Director – Financial Reporting

View Audit 344625

Finding 525502 (2024-007)

Significant Deficiency 2024

Maywood-Melrose Park-Broadview School District 89

IL

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2024 Corrective Action Plan Finding No.: 2024- 007 Condition: During our audit of Education Stabilization Fund, we noted the District paid...

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2024 Corrective Action Plan Finding No.: 2024- 007 Condition: During our audit of Education Stabilization Fund, we noted the District paid the vendor for duplicate invoices. The erroneous invoice passed through all necessary controls, including purchase order/invoice review and approval to payment approval, resulting in the invoice being paid twice to the vendor for a single service. BT noted the total suspected duplicated invoices to be $2,955.67. Plan: Moving forward, our accounts payable coordinator will not adjust invoice numbers in IVEE and instead check the general ledger to ensure payment for that invoice has not already been made. Business Manager will perform a review of the list of bills to ensure there are no duplicate payments. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Scott Wold, Business Manager

View Audit 344578

Finding 525303 (2024-004)

Significant Deficiency 2024

Shelby Eastern Schools

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.430

Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support ...

Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the School Lunch fund. Contact Person Responsible for Corrective Action: Chris Scott Contact Phone Number: 765-544-2246 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a formal time and effort reporting system for all employees whose salaries are partially funded by federal grants. Our Café department has since revised our process and no longer charge any SES employee payroll to the Café Account for cleaning. As a result, this issue has been fully addressed and should not recure in future reporting periods Anticipated Completion Date: July 2024

View Audit 344529 Questioned Costs: $1

Finding 525299 (2024-003)

Material Weakness 2024

Shelby Eastern Schools

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guid...

Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Contact Person Responsible for Corrective Action: Chris Scott Contact Phone Number: 765-544-2246 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A new Food Service Director has been hired and will take responsibility for ensuring compliance with eligibility requirements. Additionally, the Business Manager will oversee the corrective actions and implement a formal secondary review process. The Business Manager will conduct and document secondary reviews for all applications entered into the food service software to verify eligibility determinations. This ensures compliance with regulatory standards and addresses the deficiencies noted in the audit findings. Anticipated Completion Date: June 2025

View Audit 344529

Finding 525297 (2024-001)

Significant Deficiency 2024

Gilbert Unified School District No. 41

AZ

Questioned Costs Allowable Costs / Cost Principles Reporting § 200.303 § 200.510

Finding Number: 2024‐001 Program Name/Assistance Listing Titles: Emergency Connectivity Fund; Education Stabilization Fund Assistance Listing Numbers: 32.009; 84.425 Contact Person: Jackie Mattinen, Director of Finance Anticipated Completion Date: February 28, 2025 Planned Corrective Action: The Gil...

Finding Number: 2024‐001 Program Name/Assistance Listing Titles: Emergency Connectivity Fund; Education Stabilization Fund Assistance Listing Numbers: 32.009; 84.425 Contact Person: Jackie Mattinen, Director of Finance Anticipated Completion Date: February 28, 2025 Planned Corrective Action: The Gilbert Public Schools Finance Department will provide financial oversight of all State and Federal fund applications and will require finance approval prior to submittal of all State and Federal fund applications initiated by all District departments and schools.

View Audit 344525 Questioned Costs: $1

Finding 525236 (2024-001)

Material Weakness 2024

YWCA Metropolitan Chicago

IL

Subrecipient Monitoring Internal Control / Segregation of Duties Eligibility § 200.303

Condition: There was a lack of documented controls as evidence of supervisory review and segregation of duties to ensure compliance with federal program requirements, specifically over the following: a)Tier (day care home eligibility) determinations b)Subrecipient monitoring Noncompliance was ident...

Condition: There was a lack of documented controls as evidence of supervisory review and segregation of duties to ensure compliance with federal program requirements, specifically over the following: a)Tier (day care home eligibility) determinations b)Subrecipient monitoring Noncompliance was identified for subrecipient monitoring as noted in the context below. Planned Corrective Action: (a)Management is working with the Software company staff to develop software-based evidence of second review. If this is not possible, a tracking mechanism external to the software will be developed by March 2025. (b)Under management’s supervision, monitoring visits are being brought current on the contract currently in place and will be completed as required by end of contract. A tracking mechanism has been put in place to ensure compliance with the required number of monitoring visits and timeliness. Contact person responsible for corrective action: Loukisha Pennex, Chief of Youth and Family Potential and Anjanette Brown, CFO. Anticipated Completion Date: June 2025

View Audit 344452

Finding 525195 (2024-001)

Material Weakness 2024

Eastbrook Community School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Context: For testing of activities allowed and unallowed, a sample of 21 vendor vouchers were selected for testing. Two vouchers totaling $61,841 were related to disbursements for floor replacement costs incurred and charged to the ESSER III grant award. The School Corporation received approval fr...

Context: For testing of activities allowed and unallowed, a sample of 21 vendor vouchers were selected for testing. Two vouchers totaling $61,841 were related to disbursements for floor replacement costs incurred and charged to the ESSER III grant award. The School Corporation received approval from the Indiana Department of Education (IDOE) through the grant application to utilize a portion of the ESSER II grant award for floor replacement throughout the School Corporation. During the audit period, the School Corporation had $88,600 that was disbursed and reported on the SEFA for ESSER II and $142,400 that was disbursed and reported on the SEFA for ESSER III for floor replacement. The School Corporation did not receive approval from the Indiana Department of Education (IDOE) to use ESSER III funding for the flooring project as required for construction or remodeling related projects. The total amount of the flooring project funded by the ESSER III grant, including amounts paid prior to the audit, was $219,992. The portion of the flooring project paid by the ESSER II grant was $163,000 which was properly approved by IDOE. Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager Contact Phone Number: 765-664-0624 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will put a system in place to ensure that each grant application is printed in its entirety, including the narratives, and file them in the appropriate grant files maintained by the business manager. The business manager will verify that the agreed upon expenditures are included in the grant application before any orders are placed or purchases are approved. Additionally, accounting descriptions set up in the financial software will better reflect IDOE-approved expenditures. Anticipated Completion Date: February 25, 2025

View Audit 344409 Questioned Costs: $1

Finding 525191 (2024-002)

Material Weakness 2024

Eastbrook Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Context: For the one project sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the fede...

Context: For the one project sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the company that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. Additionally, the School Corporation did not have a contract with the company that included the clause for the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $231,000. Audit adjustments were proposed, accepted by the School Corporation, and made to the SEFA to correct the issues noted above. We also noted there was no documented, secondary review of the information in the SEFA by someone other than the preparer. Contact Person Responsible for Corrective Action: Lisa Baker, Business Manager/Treasurer Contact Phone Number: 765-664-0624 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Davis-Bacon requirements is a repeat finding due to the timing of the prior audit and a lag for new controls to take effect. When the School Corporation is awarded federal funds that will be used for construction, alteration, or repair projects in excess of $2,000, the superintendent and/or business manager will notify the contractors that the project is being funded by federal funds and the requirements as outlined by the Davis-Bacon Act. In addition, the superintendent and/or the business manager will ensure that the contractors provide weekly payroll report certifications and will review the documents to ensure compliance with the wage rate requirements. The SEFA, which is included with the Annual Financial Report, is reviewed by the deputy treasurer upon its completion. Going forward, any corrections or adjustments made to the SEFA will be reviewed by the deputy treasurer or other district office employee. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

View Audit 344409

Finding 525080 (2024-001)

Significant Deficiency 2024

Bothwell Regional Health Center

MO

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

February 27, 2025 Finding 2024-001 U.S. Department of Health and Human Services, passed through the Curators of the University of Missouri ALN 93.680 - Medical Student Education PTE Federal Award No: T9952110 Management's Response: Bothwell Regional Health Center will begin performing suspens...

February 27, 2025 Finding 2024-001 U.S. Department of Health and Human Services, passed through the Curators of the University of Missouri ALN 93.680 - Medical Student Education PTE Federal Award No: T9952110 Management's Response: Bothwell Regional Health Center will begin performing suspension and debarment checks on all vendors/contracts funded with grants in 2025. This process will be implemented in 2025 pending policy review processes. Bothwell Regional Health Center will start documenting reviews of suspension and debarment checks of vendors receiving Federal funds while onboarding new vendors and monitoring periodically throughout the year. Views of Responsible Officials and Corrective Action: Management agrees with the finding and management will implement a control process to ensure that suspension and debarment checks are performed on vendors/contracts funded with grants in 2025. Responsible Official: Steven Davis Chief Financial Officer Bothwell Regional Health

View Audit 344357

Finding 524978 (2024-003)

Significant Deficiency 2024

Minneapolis College of Art and Design

MN

Matching / Level of Effort / Earmarking Student Financial Aid Significant Deficiency § 200.303

Documentation of Review Recommendation: We recommend the College reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: MCAD Financial Aid already has sound procedures in place that outlines the process for ou...

Documentation of Review Recommendation: We recommend the College reevaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: MCAD Financial Aid already has sound procedures in place that outlines the process for our internal review and audit processes in all areas (ex. Awarding, Reconciliation, and R2T4). Action taken in response to finding: ● The Director of Financial Aid will ensure regular internal review audits will take place throughout the fiscal year. ● Review results will be documented for recordkeeping and to track whether processes and procedures are followed. ● The Financial Aid Operations Calendar will include dates of when internal reviews will take place over the different areas of the department ● The Business Office will be involved for all reconciliation related internal review processes as a third party reviewer to ensure the disbursed amounts on Powerfaids, COD, and G5 are synchronized. Name(s) of the contact person(s) responsible for corrective action: Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: May 1, 2025

View Audit 344312

Finding 524953 (2024-002)

Material Weakness 2024

Queen Anne's County, Maryland

MD

Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.327

Recommendation: We recommend the County follow procurement policies in place at the County or outlined in the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Plan: Going forward, the county is committed to enhanci...

Recommendation: We recommend the County follow procurement policies in place at the County or outlined in the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Plan: Going forward, the county is committed to enhancing the efficiency and transparency of its procurement process for awarding contracts. We will ensure that all departments strictly adhere to the established procurement policy, fostering an environment of full and open competition. Additionally, we will implement annual training sessions for all departments to reinforce their understanding of the procurement policy and ensure ongoing compliance. Name of contact person responsible for corrective action: Jeffrey Rank, Director, Office of Budget & Finance Planned completion date for corrective action plan: February 28, 2025

View Audit 344295

Finding 524952 (2024-001)

Material Weakness 2024

Queen Anne's County, Maryland

MD

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.303

Recommendation: We recommend all reimbursements and payments be reviewed in detail to ensure no payments are funding unallowable costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Going forward, the county w...

Recommendation: We recommend all reimbursements and payments be reviewed in detail to ensure no payments are funding unallowable costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Going forward, the county will implement a more thorough review process for expenditures that were initially paid by a separate entity and subsequently reimbursed by us, ensuring all such transactions are properly documented and compliant with grant guidelines. Name of contact person responsible for corrective action: Jeffrey Rank, Director, Office of Budget & Finance Planned completion date for corrective action plan: February 28, 2025

View Audit 344295

Finding 524920 (2024-002)

Significant Deficiency 2024

Howard Community College

MD

Special Tests & Provisions Student Financial Aid Reporting § 200.303

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommenda...

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with Records, Registration and Veterans Affairs (RRVA) to conduct a thorough review of the current policies and procedures for reporting student enrollment status changes and effective dates to NSLDS and then subsequently implement process improvements to ensure that our process aligns with federal regulations. Name(s) of the contact person(s) responsible for corrective action: Jessica Peterson, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 344285

Finding 524916 (2024-005)

Significant Deficiency 2024

Howard Community College

MD

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation:...

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation: It is recommended that the College strengthens its internal controls and improves coordination among departments to ensure timely submission of required data for the Return of Funds. This may include implementing a more robust tracking system, providing additional training to staff, and establishing clear deadlines and responsibilities for data submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services will work with the Administration Information Systems department along with other stakeholders to strengthen its internal controls and improve communication. Additionally, Howard Community College will work with AIS to develop and implement a more robust system to track and review the data required to complete the Return of Funds process. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Education has questions regarding this plan, please call Detra Hooper, Financial Aid Services Director at 443‐518‐4776.

View Audit 344285

Finding 524915 (2024-004)

Significant Deficiency 2024

Howard Community College

MD

Student Financial Aid Reporting Significant Deficiency § 200.303

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recom...

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recommendation: It is recommended that the College strengthens its internal controls and verification processes to ensure the accuracy of data reported in the FISAP. This may include creating a formalized review process for the FISAP and ensuring all supporting schedules used to populate the form are centrally stored. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services has created a formalized review process for FISAP and created a central location to store data. This review process includes multiple staff members and internal controls for future review. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Director Planned completion date for corrective action plan: June 30, 2025

View Audit 344285

Finding 524914 (2024-003)

Significant Deficiency 2024

Howard Community College

MD

Subrecipient Monitoring Internal Control / Segregation of Duties Student Financial Aid § 200.303

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the ...

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with the Administrative Information Systems (AIS) department to conduct a thorough review of the written information security program to ensure the necessary elements are included and meeting the minimum requirements as outlined in 16 CFR 314.4. Name(s) of the contact person(s) responsible for corrective action: Tyria Stone, Executive Vice President, Finance & Administration

View Audit 344285

Finding 524791 (2024-003)

Significant Deficiency 2024

University of Dubuque

IA

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

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive securi...

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive security policy. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 10/01/2024

View Audit 344180

Finding 524790 (2024-002)

Significant Deficiency 2024

University of Dubuque

IA

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

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and process...

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and processes the R2T4 calculations. The Director will reassess R2T4 calculations and verify that only aid with signed promissory notes are being included in R2T4 calculations. Internal policies and procedures have been updated to ensure accurate calculations. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024

View Audit 344180 Questioned Costs: $1

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