Corrective Action Plans

Finding 1174099 (2025-002)

Material Weakness 2025

The Harry and Jeanette Weinberg House, Inc.

MD

HUD Housing Programs Cash Management

Management agrees with the findings and recommendations, however due to insufficient funds at the property, we will collaborate with HUD to secure appropriate funding.

View Audit 387762

Finding 1174097 (2025-001)

Material Weakness 2025

The Harry and Jeanette Weinberg House, Inc.

MD

Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.

View Audit 387762

Finding 1174092 (2025-005)

Material Weakness 2025

City of Red Lodge

MT

Procurement, Suspension & Debarment

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING FUNDS ASSISTANCE LISTING No. 66.458 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certific...

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING FUNDS ASSISTANCE LISTING No. 66.458 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2026.

View Audit 387749

Finding 1174091 (2025-004)

Material Weakness 2025

City of Red Lodge

MT

Procurement, Suspension & Debarment

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, HAZARD MITIGATION GRANT PROGRAM, ASSISTANCE LISTING No. 97.039 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required ent...

NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, HAZARD MITIGATION GRANT PROGRAM, ASSISTANCE LISTING No. 97.039 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2026.

View Audit 387749

Finding 1174090 (2025-004)

Material Weakness 2025

Mid-South Food Bank

TN

Special Tests & Provisions Reporting Significant Deficiency

Management concurs with Audit Finding 2025-004 and will strengthen controls over USDA commodity receiving documentation and related reporting to ensure compliance with Food Distribution Cluster special tests and provisions and reporting requirements. Management will implement the following correctiv...

Management concurs with Audit Finding 2025-004 and will strengthen controls over USDA commodity receiving documentation and related reporting to ensure compliance with Food Distribution Cluster special tests and provisions and reporting requirements. Management will implement the following corrective actions: 1. Required Receiving Worksheets for USDA Commodity Receipts Management will reinforce the requirement that a completed receiving worksheet be prepared for all TDA USDA commodity receipts. Each receiving worksheet will be signed or initialed by the receiving employee at the time of receipt to evidence verification of quantities received. 2. Reconciliation of Receiving Documentation to CERES Management will implement a formal reconciliation process to ensure all USDA receiving documentation is reconciled to CERES inventory entries prior to submission of monthly TEFAP reports. Any discrepancies will be promptly investigated, resolved, and documented. 3. Supervisory Review and Approval Supervisory personnel will perform periodic documented reviews to verify that: o All USDA commodity receipts are supported by completed and signed receiving worksheets; and o Receiving activity is accurately and completely recorded in CERES. Evidence of supervisory review will be retained. 4. Documentation Retention and Standardization All receiving worksheets and supporting documentation will be retained in accordance with Food Distribution Cluster record retention requirements. Management will standardize receiving forms and procedures to promote consistency and completeness. 5. Training and Ongoing Monitoring Management will provide refresher training to warehouse and inventory staff on USDA receiving requirements and the importance of timely, accurate documentation. Management will periodically monitor compliance with these procedures to ensure controls are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

View Audit 387744

Finding 1174089 (2025-003)

Material Weakness 2025

Mid-South Food Bank

TN

Reporting School Nutrition Programs Significant Deficiency

Management concurs with Audit Finding 2025-003 and will strengthen controls over USDA Food Distribution Cluster reporting to ensure accuracy, completeness, and compliance with federal and State requirements. Management will implement the following corrective actions: 1. Monthly USDA Reporting Reconc...

Management concurs with Audit Finding 2025-003 and will strengthen controls over USDA Food Distribution Cluster reporting to ensure accuracy, completeness, and compliance with federal and State requirements. Management will implement the following corrective actions: 1. Monthly USDA Reporting Reconciliation Process Management will implement a formal monthly reconciliation process that includes: o Reviewing confirmed USDA receipts and reconciling them to internal inventory records in CERES; and o Reconciling all TEFAP distribution reports submitted to the States to CERES data prior to submission. All reconciliations will be documented, reviewed, and retained. 2. Documentation of Shortages and Inventory Adjustments Shortages noted on signed agency invoices will be promptly documented and resolved through credit memos or inventory adjustments in CERES. Supporting documentation will be retained to substantiate all adjustments. 3. 48-Hour Receipt Confirmation Tracking Management will establish a tracking mechanism (e.g., log or checklist) to monitor submission of all required 48-hour receipt confirmations. The tracking tool will document submission dates and ensure confirmations are submitted timely and retained in accordance with record retention requirements. 4. Assignment of Reporting Responsibility Management will formally assign primary responsibility for preparation and submission of Food Distribution Cluster reports to a designated individual. Roles and responsibilities will be clearly documented. 5. Supervisory Review and Oversight A supervisory reviewer will perform documented reviews of reconciliations, supporting documentation, and reports prior to submission. Supervisory review will confirm that: o Reconciliations are completed. o Differences are investigated and resolved; and o Reports comply with applicable federal and State requirements. 6. Monitoring and Training Management will periodically monitor compliance with these procedures and provide refresher training to staff involved in inventory, distribution, and reporting to ensure consistent application of controls. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

View Audit 387744

Finding 1174088 (2025-002)

Material Weakness 2025

Mid-South Food Bank

TN

Internal Control / Segregation of Duties Special Tests & Provisions Reporting

Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following co...

Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following corrective actions: 1. Required Agency Acknowledgment at Delivery Management will reinforce procedures requiring recipient agency signatures or equivalent acknowledgment on all USDA food distribution invoices at the time of delivery. Distribution staff and drivers will be reminded that unsigned delivery documentation is considered incomplete. 2. Post-Delivery Follow-Up Control Management will implement a follow-up control, such as a delivery log or checklist, to track all USDA distributions recorded at the time of delivery. The log will include verification that a signed receipt has been obtained and returned for each transaction. 3. Reconciliation of Distributions to Signed Documentation On a periodic basis, management will reconcile USDA distribution activity to signed agency invoices to identify any missing acknowledgments. Missing signatures will be promptly investigated and resolved, with documentation of follow-up retained. 4. Supervisory Review and Oversight Supervisory personnel will perform periodic documented reviews of distribution documentation to verify that signed agency receipts are obtained, complete, and retained. Evidence of review will be maintained. 5. Training and Awareness Management will provide refresher training to distribution staff and drivers on USDA documentation requirements and the importance of obtaining signed acknowledgment to support program accountability and reporting accuracy. Expected Completion Date: Within 60-90 days Responsible Parties: Andrelle Bowen, Transportation Manager, (901-373-0402)

View Audit 387744

Finding 1174087 (2025-001)

Material Weakness 2025

Mid-South Food Bank

TN

Equipment & Real Property Management Reporting School Nutrition Programs

Management concurs with Audit Finding 2025-001 and will implement enhanced internal controls over inventory adjustments to ensure accurate accounting for the receipt, distribution, and disposition of all USDA commodities in compliance with Special Tests and Provisions requirements. Management will i...

Management concurs with Audit Finding 2025-001 and will implement enhanced internal controls over inventory adjustments to ensure accurate accounting for the receipt, distribution, and disposition of all USDA commodities in compliance with Special Tests and Provisions requirements. Management will implement the following corrective actions: 1. Formal Approval and Authorization of Inventory Adjustments Management will establish a formal policy requiring documented supervisory review and approval for all manual positive and negative inventory adjustments recorded in the general ledger and the CERES inventory system. Approval will be obtained prior to posting adjustments, and access to record adjustments will be restricted to authorized personnel. 2. Standardized Documentation for Adjustments Each inventory adjustment will be supported by standardized documentation clearly explaining the nature, reason, and calculation of the adjustment, along with applicable supporting records (e.g., receiving documents, distribution records, shortage documentation). All documentation will be retained in accordance with USDA record retention requirements. 3. Reconciliation of Inventory Activity Management will implement a periodic (at least monthly) reconciliation of inventory receipts, distributions, and adjustments to CERES and the general ledger. Reconciling items will be investigated, resolved, and documented timely. 4. Monitoring of USDA Program Inventory Management will perform periodic reviews of inventory activity related to donated inventory and Tennessee and Mississippi USDA programs to ensure that adjustments are appropriate, approved, and accurately recorded. 5. Training and Ongoing Oversight Management will provide targeted training to staff involved in inventory and accounting processes regarding USDA Special Tests and Provisions requirements and the new approval and documentation procedures. Management will monitor compliance with these controls to ensure they are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

View Audit 387744

Finding 1174066 (2025-004)

Material Weakness 2025

Yellowstone-West Carbon County Special Services Cooperative

MT

Internal Control / Segregation of Duties

2025-004. SEGREGATION OF DUTIES Name of Contact Person: Roger Heimbigner Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to be involved in providing some of these control...

2025-004. SEGREGATION OF DUTIES Name of Contact Person: Roger Heimbigner Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to be involved in providing some of these controls. Proposed Completion Date: The governing board will implement the above procedure immediately.

View Audit 387729

Finding 1174064 (2025-007)

Material Weakness 2025

Community Unit School District No. 196

IL

Reporting

Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports ...

Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports before submitting. Management response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.

View Audit 387723

Finding 1174063 (2025-006)

Material Weakness 2025

Community Unit School District No. 196

IL

Reporting

Condition: The amounts used to record expenditures on the quarterly expenditure reports should match the general ledger accounts where the expenditures are recorded. Recommendation: We recommend reviewing the general ledger to the expenditure reports before submittin for more accurate reporting. Man...

Condition: The amounts used to record expenditures on the quarterly expenditure reports should match the general ledger accounts where the expenditures are recorded. Recommendation: We recommend reviewing the general ledger to the expenditure reports before submittin for more accurate reporting. Management response: The District will review the general ledger to the expenditure reports before submitting.

View Audit 387723

Finding 1174062 (2025-004)

Material Weakness 2025

Community Unit School District No. 196

IL

Reporting

Condition: The District's general ledgers totals are inconsistent with the ISBE reports due to timing errors, resultig in certain expenses being claimed late on the IDEA Flow Through. Recommendation: We recommend reconciling the general ledger totals to the expenditure reports before sumbitting. Man...

Condition: The District's general ledgers totals are inconsistent with the ISBE reports due to timing errors, resultig in certain expenses being claimed late on the IDEA Flow Through. Recommendation: We recommend reconciling the general ledger totals to the expenditure reports before sumbitting. Management Response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.

View Audit 387723

Finding 1174061 (2025-005)

Material Weakness 2025

Community Unit School District No. 196

IL

Reporting

Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports ...

Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports before submitting. Management response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.

View Audit 387723

Finding 1174060 (2025-001)

Material Weakness 2025

National Foundation for the Centers for Disease Control and Prevention

GA

Subrecipient Monitoring

Finding 2025-001: Subrecipient monitoring Name of contact person: Shavone Smith, Vice President of Finance, (404) 653-0790 Recommendation: The Foundation should ensure that established policies and procedures that are in place to ensure proper subrecipient monitoring activities are adhered to and if...

Finding 2025-001: Subrecipient monitoring Name of contact person: Shavone Smith, Vice President of Finance, (404) 653-0790 Recommendation: The Foundation should ensure that established policies and procedures that are in place to ensure proper subrecipient monitoring activities are adhered to and if there are delays in performing certain key tasks that a plan with a timeline be developed to address when missed tasks will be completed. Corrective action: The Foundation acknowledges that it did not obtain internal control surveys and audit certification forms for a portion of fiscal year 2025 due to reductions in force and other organizational changes which temporarily limited staff capacity to complete all monitoring activities. Internal control surveys and audit certification fully resumed in October 2025. At that time, we also went back to the period May-October 2025 to perform the procedures that were paused and completed monitoring for all subrecipient agreements that were still active. The procedures we performed retroactively did not indicate any heightened risks for the applicable subrecipients. Additionally, all current subrecipient agreements with end dates beyond October of 2025 have had monitoring completed or are scheduled to be completed (due to more recent start dates). To prevent recurrence, the Foundation has implemented procedural safeguards to ensure continuity of compliance monitoring (specifically internal control survey administration, audit certification and an audit review and follow-up) during periods of staffing or operational disruption. These safeguards include (1) reaffirming formal assignment of responsibility for internal control survey administration and audit certification/foll-up to designated roles rather than individual staff, (2) cross-training of additional personnel to perform these functions as needed, and (3) increased management review to confirm completion and timeliness of monitoring. The Foundation will proactively assess the potential impact of anticipated and unanticipated staffing changes on subrecipient monitoring and compliance activities. Management will identify critical functions (including internal controls surveys and audit certification collection) and will ensure appropriate coverage, cross-training, or alternative resources are in place to maintain compliance with federal requirements. These controls were designed to ensure continuity of compliance activities during periods of staffing transition or operational disruption. Management will monitor compliance with this process on an ongoing basis to ensure monitoring is consistently performed in accordance with policy. Proposed completion date: October 2025

View Audit 387721

Finding 1174055 (2025-001)

Material Weakness 2025

Elkhart and St. Joseph Counties Head Start Consortium

IN

Equipment & Real Property Management Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.313

Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the U...

Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the Unit did not perform any of the required federal compliance steps related to the flooring purchase (getting approval before making the purchase, adding the flooring purchase to the capital asset listing, and performing an inventory of the flooring). The Unit believed the flooring purchase did not require approval because it does not meet the criteria of a major renovation under Head Start guidelines. However, as noted in the criteria above, the flooring still qualifies as an equipment and real property purchase. Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: The Consortium management disagrees with the finding. Description of Corrective Action Plan: The Consortium plans to discuss this matter with ACF/HHS to determine if the finding is out of compliance. Anticipated Completion Date: June 30, 2026

View Audit 387707

Finding 1174004 (2025-001)

Material Weakness 2025

City of Woodburn

OR

Allowable Costs / Cost Principles § 200.302

Finding Description: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. The City has not developed written procedures for determining the allowability of costs for departments outside of transit. Corrective Actio...

Finding Description: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. The City has not developed written procedures for determining the allowability of costs for departments outside of transit. Corrective Action: Management will incorporate written procedures for determining the allowability of costs into the City's Financial Plan document, which already includes a section for City-wide policies related to grant administration. The Finance Director and City Manager are responsible for updating the Financial Plan, and the policy updates will be incorporated along with the adoption of the City's fiscal year 2026-2027 budget prior to June 30, 2026.

View Audit 387665

Finding 1174001 (2025-002)

Material Weakness 2025

Town of Seymour, Connecticut

CT

Reporting § 200.512

Recommendation: We recommend the Town evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the data collection form. Management’s Response:: The Town will implement internal ...

Recommendation: We recommend the Town evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the data collection form. Management’s Response:: The Town will implement internal controls to ensure the filing deadline is met. Jason Vieira of the Towns Finance Department is responsible for the corrective action plan.

View Audit 387663

Finding 1173999 (2025-001)

Material Weakness 2025

Pathways in Education - Illinois, Inc.

CA

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management § 200.303 § 200.508

Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and...

Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and Neglected Audit Finding Reference: 2025-001 ________________________________________ 1. Finding Summary The Single Audit identified a deficiency in the documentation and communication of federally funded position percentages and the alignment of Time & Effort attestations with the actual period of work performed. Specifically, the current CPS Federal Funds platform (Oracle) generates Time & Effort Attestation reports based on the month reimbursement claims are submitted, rather than the period during which the work was performed, creating a compliance gap. ________________________________________ 2. Root Cause ● Staff were not consistently informed of the exact percentage of their position funded by federal sources at the start of each semester. ● Time & Effort attestations were generated from the CPS Oracle system based on claim submission timing, not the actual work period. ● There was no formal internal SOP layer to supplement Oracle-generated reports with staff attestation aligned to Semester 1 and Semester 2 work periods. ________________________________________ 3. Corrective Actions Action 1: Internal Funding Percentage Notification System Description: PIE-IL will implement an internal tracking and notification system to ensure all staff funded in whole or in part with federal funds are formally notified of the exact percentage of their position supported by federal funding. Implementation Steps: ● Develop a standardized Federal Funding Allocation Notice template. ● Distribute notices to all applicable staff at the start of Semester 1 and Semester 2. ● Require staff acknowledgment (electronic or signed) confirming receipt and understanding. ● Maintain records centrally in the federal compliance folder. Responsible Party: Manager of Instructional Compliance Timeline: Implemented by the first day of each semester Monitoring: Semester-based review of acknowledgment logs ________________________________________ Action 2: Semester-Based Time & Effort Attestation Description: All federally funded staff will complete and sign a Time & Effort Attestation for both Semester 1 and Semester 2, certifying that time worked aligns with the funding source and percentage assigned. Implementation Steps: ● Issue Time & Effort forms at the end of each semester. ● Require staff to certify actual work performed during the semester. ● Collect supervisor verification signatures. ● Store completed attestations in the federal compliance repository. Responsible Party: Site Administrators / Federal Compliance Officer Timeline: Within 10 business days of semester end Monitoring: Quarterly internal compliance audits ________________________________________ Action 3: Internal SOP as Supplemental Documentation Layer Description: PIE-IL will implement a formal Standard Operating Procedure (SOP) for Time & Effort as a self-managed, internal documentation layer that supplements CPS Oracle-generated attestation reports. This SOP will ensure that Time & Effort documentation reflects the actual period of work performed, rather than the month in which reimbursement claims are submitted. Implementation Steps: ● Draft and approve a written SOP outlining: ○ Semester-based attestation requirements ○ Alignment between funding percentages and staff assignments ○ Reconciliation process between internal records and Oracle reports ● Train administrators and federally funded staff on SOP procedures. ● Maintain SOP as a controlled document with annual review and updates. Responsible Party: Federal Programs Director / Compliance Manager Timeline: SOP finalized within 30 days of audit response submission Monitoring: Annual SOP review and internal compliance testing ________________________________________ 4. Reconciliation Process with CPS Oracle System PIE-IL will perform a monthly reconciliation between: ● Oracle-generated Time & Effort Attestation reports (claim-based), and ● Internal Semester-Based Time & Effort attestations (work-period-based). Any discrepancies will be documented, corrected, and reviewed by the Federal Compliance Officer prior to reimbursement submission. ________________________________________ 5. Evidence of Implementation The following documentation will be maintained for audit and monitoring purposes: ● Federal Funding Allocation Notices with staff acknowledgments ● Signed Semester 1 and Semester 2 Time & Effort Attestation forms ● Approved Time & Effort SOP document ● Training sign-in sheets and materials ● Monthly reconciliation logs between Oracle and internal records ________________________________________ 6. Completion Dates Corrective Action Target Completion Date Funding Percentage Notification System [9/30/2026] Semester-Based Time & Effort Attestation Process [02/06/2026] SOP Finalization and Staff Training [02/28/2026] Monthly Reconciliation Process Ongoing ________________________________________

View Audit 387658

Finding 1173998 (2025-001)

Material Weakness 2025

Voices College Bound Language Academies

CA

School Nutrition Programs Subrecipient Monitoring Cash Management

The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.

View Audit 387654

Finding 1173997 (2025-005)

Material Weakness 2025

College of Southern Idaho

ID

Student Financial Aid

Finding 2025-005 Finding Summary: Under 34 CFR 690.63 and 685.200, institutions must calculate Pell grant and federal direct loan awards based on the student’s eligible enrollment status, cost of attendance, expected family contribution (EFC) or student aid index (SAI), satisfactory academic progres...

Finding 2025-005 Finding Summary: Under 34 CFR 690.63 and 685.200, institutions must calculate Pell grant and federal direct loan awards based on the student’s eligible enrollment status, cost of attendance, expected family contribution (EFC) or student aid index (SAI), satisfactory academic progress, and other Title IV eligibility requirements. Institutions are required to ensure award amounts are accurate and supported by the documentation in the student’s file. During our testing of 60 students, we found one student who received a subsidized direct loan; however, did not meet the requirements to receive the need-based aid. Corrective Action Plan: The institution is actively working to address this system limitation to prevent future occurrences. Corrective actions include: 1. Collaborating with internal teams and system support to update the configuration so that Cost of Attendance and other adjustments can be made for students receiving student loans only. 2. Implementing additional review procedures to identify and document any instances where system limitations may impact COA calculations. 3. Training relevant staff on the updated process once system changes are in place to ensure consistent and accurate awarding moving forward. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Jennifer Service – Director of Financial Aid Anticipated Completion Date: 12/31/202525

View Audit 387647

Finding 1173996 (2025-004)

Material Weakness 2025

College of Southern Idaho

ID

Special Tests & Provisions Student Financial Aid Reporting

Finding 2025-004 Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Instituti...

Finding 2025-004 Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. During testing of compliance for Enrollment Reporting, there were 3 instances out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time limit of 60 days from the effective date of the student’s change in enrollment status. Corrective Action Plan: Enrollment reporting has been centralized under a single point of contact, thereby mitigating risk, ensuring consistency, accountability, and regulatory compliance. This structure was formally implemented last summer with the hiring of an Academic Records Compliance Specialist, significantly strengthening oversight and operational controls. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Noah Briscoe – Assistant Registrar Anticipated Completion Date: 12/31/2025

View Audit 387647

Finding 1173995 (2025-003)

Material Weakness 2025

College of Southern Idaho

ID

Student Financial Aid Material Weakness Reporting

Finding 2025-003 Finding Summary: 34 CFR 690.83 and the FSA Handbook states that an Institution must report accurate and timely data. During testing of compliance for COD Reporting, there were 6 instances out of 60 where the College did not report a student’s disbursement information to COD accurate...

Finding 2025-003 Finding Summary: 34 CFR 690.83 and the FSA Handbook states that an Institution must report accurate and timely data. During testing of compliance for COD Reporting, there were 6 instances out of 60 where the College did not report a student’s disbursement information to COD accurately. Corrective Action Plan: The institution has taken and has fixed this issue by: • The system is now functioning correctly after addressing the issue with the vendor. • To prevent future issues, a more robust tool has been developed to identify discrepancies promptly should they arise. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Jennifer Service – Director of Financial Aid Anticipated Completion Date: 12/31/2025

View Audit 387647

Finding 1173994 (2025-002)

Material Weakness 2025

College of Southern Idaho

ID

Special Tests & Provisions Student Financial Aid Material Weakness

Finding 2025-002 Finding Summary: 34 CFR 668.164(h)(2)(i,ii) states that A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than—Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a...

Finding 2025-002 Finding Summary: 34 CFR 668.164(h)(2)(i,ii) states that A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than—Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. During our testing of compliance for HEA Credit balances, there were 5 instances out of 60 where the College did not refund a student’s within the required time frame of 14 days from the first day of class or 14 days after the credit balance was created. Corrective Action Plan: The institution has taken and has fixed this issue by: • Dedicated Staffing: A full-time position has been approved and filled to manage stipend processing, ensuring consistent oversight and timely disbursement. • Process Documentation: Stipend processing procedures have been documented to ensure continuity, accountability, and clarity of responsibilities. • System Review and Planning: The system is up and running as it should have been. • Ongoing Monitoring: Leadership will continue to monitor stipend processing timelines and staffing capacity to ensure compliance and timely student support. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Bethany Parmer – Assistant Dean of Enrollment Services Anticipated Completion Date: 12/31/2025

View Audit 387647

Finding 1173976 (2025-002)

Material Weakness 2025

Vermont Land Trust, Inc.

VT

Reporting

Management acknowledges this finding. As a result of limitations in the SEFA preparation and reconciliation process during the prior fiscal year, certain FY2024 fourth-quarter expenditures were not properly accrued and were instead recorded in FY2025. In connection with the transition of key finance...

Management acknowledges this finding. As a result of limitations in the SEFA preparation and reconciliation process during the prior fiscal year, certain FY2024 fourth-quarter expenditures were not properly accrued and were instead recorded in FY2025. In connection with the transition of key finance staff, these expenditures were inadvertently included on the first draft of the Schedule of Expenditures of Federal Awards as a part of a federal award that had been fully expended and closed out the in the prior fiscal year. The error was identified and corrected during the audit. Vermont Land Trust has taken targeted steps to address the specific circumstances that resulted in this finding. Management performed a detailed review and reconciliation of active federal awards, including the award affected by fourth-quarter accrual activity, to confirm proper period recognition and award closeout status. As a result, the fully expended award was appropriately removed from the SEFA during the audit. To prevent similar issues during periods of staff transition or year-end close, management has implemented additional review procedures focused on fourth-quarter federal expenditures and accruals.These procedures include verification of award status prior to SEFA preparation and reconciliation of SEFA amounts to the general ledger and grant tracking records. Management believes these targeted actions appropriately address the conditions identified in the finding, and based on subsequent review, no similar issues have been identified. Planned Implementation Date of Corrective Action: Implemented during FY2025 Person Responsible for Corrective Action: Tracy Zschau, President & CEO

View Audit 387626

Finding 1173975 (2025-001)

Material Weakness 2025

Latino Network

OR

Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.328

Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as ...

Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as an attachment. The required Progress Report was filed timely and accepted by HUD, however the required Federal Financial Report was omitted from the submission. Recommendation: The entity should implement and document internal controls to ensure all required reports are prepared, reviewed, and submitted in accordance with federal award requirements. Action Taken: To address the root cause and ensure strict adherence to federal reporting standards moving forward, the Finance Department has implemented the following internal controls, effective immediately: 1. Implementation of a Pre-Submission Checklist: A mandatory "Federal Reporting Checklist" has been developed. This document requires the preparer to physically check off that all required attachments—including narrative progress reports and financial reports (SF-425)—are present and accurate prior to upload. 2. Staff Training: Relevant staff members involved in the grant reporting process have been retrained on the specific submission requirements for HUD awards to ensure clarity on all deliverable components. Responsible Official: Rambod Behnam, Director of Finance Planned Completion Date: June 30, 2026.

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