Corrective Action Plans

Finding 1229292 (2025-001)

Material Weakness 2025

IA

Reporting Internal Control / Segregation of Duties

The Organization will review and implement processes and controls to ensure they record expenditures in the appropriate period and provide accurate year–end account balances

View Audit 410772

Finding 1229290 (2025-001)

Material Weakness 2025

Cong MacHzikei Hadas of Belz

NY

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.512

The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before t...

The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end, and the auditors should put this engagement on their calendar well in advance of the due date. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. The Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight. Anticipated Completion Date: 03/31/2027. Actions Taken: The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit firm has put it on its calendar to begin the audit process well in advance. The Organization’s board of directors has agreed to oversee the auditing and reporting processes to a greater extent. With these actions, the Organization expects to comply with the Uniform Guidance for single audits deadline for the fiscal year end 06/30/2026. Mr. Moshe Weiss, Food Program director, has been designated to monitor the plan of corrective action for this finding. He can be reached at 845-425-0909. Contact Person Responsible for Corrective Action: Moshe Weiss, Food Program Director

View Audit 410768

Finding 1229283 (2025-002)

Material Weakness 2025

New York Association on Independent Living, Inc.

NY

Management acknowledges that the SF-SAC for the fiscal year ended September 30, 2025 was not submitted by the required deadline of June 30, 2026. The delay occurred during a period when the finance department lacked sufficient capacity, experience, and oversight to effectively manage all financial r...

Management acknowledges that the SF-SAC for the fiscal year ended September 30, 2025 was not submitted by the required deadline of June 30, 2026. The delay occurred during a period when the finance department lacked sufficient capacity, experience, and oversight to effectively manage all financial reporting and federal complaince responsibilities. As a result, the filing requirement was not completed within the perscribed timeframe. To address the issues, management has restructured the finance department, clarified roles and responsibilities, and stregthened supervisory review procedures over financiall reporting and compliance activities. In addition, management has established a formal year-end closing procedures and audit preparation timeline that requires the organization to be audit-ready and provide all requested schedules, supporting documentation, and audit workpapers to the external auditors no later than MArch 31 each year. MAnamegement believes these corrective actions have significantly enhanced oversight, accountability, and compliance monitoring and will help ensure that all future Uniform Guidance reporting requireement are met on a timely basis.

View Audit 410760

Finding 1229282 (2025-001)

Material Weakness 2025

New York Association on Independent Living, Inc.

NY

Reporting

2025-001: Supervisory Review of Accounting function Management Response and Corrective Actions Taken: Management acknowledges that certain subcontractor invoices incurred prior to September 30 were not accrued, resulting in an audit adjustment. While the adjustment was necessary, management does not...

2025-001: Supervisory Review of Accounting function Management Response and Corrective Actions Taken: Management acknowledges that certain subcontractor invoices incurred prior to September 30 were not accrued, resulting in an audit adjustment. While the adjustment was necessary, management does not believe the issue resulted from a lack of oversight. During the fiscal year, management and the board identified concerns within the finance department to stregthen financials management and internal controls. Action taken included revising the organization's fiscal policies, engaging an independent firm to asses the finance department, obtaining Board oversight and approval throughout the process, documenting critical accounting procedures, and implementing additional financial oversight during the transition. Management also strengthened year end closing procedures by establishing documented account reconciliation, review, and accrual processes to ensure liabilities are recorded in the proper reporting period regardless of invoice receipt date. Manamgement believes these actions demonstrate proactive oversight, transparency with the board, and committement to stregthening the oprganization's internal control enviroment while reducing financial and operational risk. Anticipated completion date: Implemented March 2026

View Audit 410760

Finding 1229281 (2025-001)

Material Weakness 2025

Bais Yaakov Elementary of Rockland County

NY

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.512

The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before t...

The Organization should develop a compliance calendar that includes financial reporting deadlines and set automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end, and the auditors should put this engagement on their calendar well in advance of the due date. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. The Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight. Anticipated Completion Date: 05/31/2027. Actions Taken: The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit firm has put it on its calendar to begin the audit process well in advance. The Organization’s board of directors has agreed to oversee the auditing and reporting processes to a greater extent. With these actions, the Organization expects to comply with the Uniform Guidance for single audits deadline for the fiscal year end 08/31/2026. Nisson Portnoy, Food Program director, has been designated to monitor the plan of corrective action for this finding. He can be reached at 845-368-2247. Contact Person Responsible for Corrective Action: Nisson Portnoy, Food Program Director

View Audit 410757

Finding 1229279 (2025-005)

Material Weakness 2025

Idaho Coalition Against Sexual & Domestic Violence, Inc.

ID

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance § 200.308 § 200.309 § 200.403 § 200.514 § 200.514(C)

THE COALITION WILL MAINTAIN A CENTRALIZED GRANT REGISTER IDENTIFYING EACH AWARD NUMBER, PROJECT CODE, BEGINNING DATE, ENDING DATE, AND APPROVED PERIOD OF PERFORMANCE. FINANCE WILL USE THE REGISTER DURING MONTHLY CLOSE AND GRANT REVIEW TO VERIFY THAT PAYROLL AND NON-PAYROLL EXPENDITURES ARE CHARGED T...

THE COALITION WILL MAINTAIN A CENTRALIZED GRANT REGISTER IDENTIFYING EACH AWARD NUMBER, PROJECT CODE, BEGINNING DATE, ENDING DATE, AND APPROVED PERIOD OF PERFORMANCE. FINANCE WILL USE THE REGISTER DURING MONTHLY CLOSE AND GRANT REVIEW TO VERIFY THAT PAYROLL AND NON-PAYROLL EXPENDITURES ARE CHARGED TO THE CORRECT ACTIVE GRANT/PROJECT. BEFORE AND AFTER AN AWARD END DATE, FINANCE WILL REVIEW PROJECT ACTIVITY FOR COSTS POSTED OUTSIDE THE APPROVED PERIOD, CONFIRM WHETHER ANY PRE-AWARD OR CLOSEOUT COST IS AUTHORIZED, AND RECLASSIFY MISCODED TRANSACTIONS BEFORE GRANT REPORTING IS FINALIZED. NEW AWARD/PROJECT CODES WILL BE ESTABLISHED AND COMMUNICATED BEFORE COSTS ARE CHARGED TO A SUCCESSOR AWARD. IN ADDITION, AFTER THE MONTHLY CLOSE PROCESS IS COMPLETE, FINANCE WILL DISTRIBUTE GRANT STATEMENTS TO ADMINISTRATION TO REVIEW EXPENDITURES AND REMAINING GRANT BALANCES FOR REASONABLENESS. THIS PROVIDES AN ADDITIONAL LAYER OF OVERSIGHT TO VERIFY THAT GRANT-RELATED EXPENSES HAVE BEEN RECORDED ACCURATELY.

View Audit 410756

Finding 1229278 (2025-004)

Material Weakness 2025

Idaho Coalition Against Sexual & Domestic Violence, Inc.

ID

Internal Control / Segregation of Duties Reporting § 200.514 § 200.514(C)

THE COALITION WILL REQUIRE DOCUMENTED REVIEW AND APPROVAL OF EMPLOYEE TIME FOR EVERY PAYROLL PERIOD AND WILL RETAIN PAYROLL AND TIMEKEEPING RECORDS IN AN AUDIT-ACCESSIBLE LOCATION. BEFORE PAYROLL IS PROCESSED, DESIGNATED MANAGEMENT WILL REVIEW TIME ENTRIES FOR COMPLETENESS, FUNDING ALLOCATION, LEAVE...

THE COALITION WILL REQUIRE DOCUMENTED REVIEW AND APPROVAL OF EMPLOYEE TIME FOR EVERY PAYROLL PERIOD AND WILL RETAIN PAYROLL AND TIMEKEEPING RECORDS IN AN AUDIT-ACCESSIBLE LOCATION. BEFORE PAYROLL IS PROCESSED, DESIGNATED MANAGEMENT WILL REVIEW TIME ENTRIES FOR COMPLETENESS, FUNDING ALLOCATION, LEAVE, AND APPROVAL STATUS. THE PAYROLL FILE RETAINED FOR EACH PERIOD WILL INCLUDE THE APPROVED TIME RECORD, PAYROLL REGISTER, ALLOCATION DETAIL, AND EVIDENCE OF PREPARER/REVIEWER APPROVAL. WHEN TIMEKEEPING OR PAYROLL SYSTEMS CHANGE, THE COALITION WILL EXPORT AND PRESERVE HISTORICAL REPORTS AND APPROVAL RECORDS FOR THE APPLICABLE RECORD-RETENTION PERIOD BEFORE ACCESS TO THE PRIOR SYSTEM ENDS.

View Audit 410756

Finding 1229277 (2025-003)

Material Weakness 2025

Idaho Coalition Against Sexual & Domestic Violence, Inc.

ID

Allowable Costs / Cost Principles § 200.514 § 200.514(C)

THE COALITION WILL FORMALIZE AND RETAIN A DOCUMENTED ALLOCATION CONTROL PROCESS FOR EXPENSES CHARGED TO FEDERAL PROGRAMS. ON A MONTHLY BASIS, FINANCE WILL RECONCILE PAYROLL REPORTS FROM GUSTO TO THE GENERAL LEDGER TO ENSURE PAYROLL ENTRIES POSTED TO THE GL AGREE TO THE PAYROLL REGISTER FOR THE APPLI...

THE COALITION WILL FORMALIZE AND RETAIN A DOCUMENTED ALLOCATION CONTROL PROCESS FOR EXPENSES CHARGED TO FEDERAL PROGRAMS. ON A MONTHLY BASIS, FINANCE WILL RECONCILE PAYROLL REPORTS FROM GUSTO TO THE GENERAL LEDGER TO ENSURE PAYROLL ENTRIES POSTED TO THE GL AGREE TO THE PAYROLL REGISTER FOR THE APPLICABLE PAY PERIOD. THESE RECONCILED PAYROLL ENTRIES WILL SERVE AS THE BASIS FOR ALL PAYROLL ALLOCATIONS. FOR PAYROLL ALLOCATIONS, THE PAYROLL REGISTER WILL SERVE AS THE SOURCE DOCUMENT AND WILL BE RECONCILED TO THE ALLOCATION WORKSHEET AND THE CORRESPONDING JOURNAL ENTRY POSTED TO THE GENERAL LEDGER. THE RECONCILIATION WILL IDENTIFY THE PAYROLL PERIOD, EMPLOYEE, SOURCE PAYROLL AMOUNT, ALLOCATION METHODOLOGY, FUNDING SOURCE OR PROJECT, AND RESULTING JOURNAL ENTRY. A PREPARER AND AN INDEPENDENT REVIEWER WILL DOCUMENT COMPLETION AND APPROVAL, AND THE SUPPORTING DOCUMENTATION WILL BE RETAINED WITH THE JOURNAL ENTRY TO ENSURE ALLOCATED AMOUNTS CAN BE TRACED BACK TO THE ORIGINATING PAYROLL RECORDS. IN ADDITION, FINANCE WILL RECONCILE ON A MONTHLY BASIS, THE PAYROLL REPORTS FROM GUSTO TO THE GENERAL LEDGER, ENSURING THAT THE PAYROLL ENTRIES POSTED TO THE GL TIE DIRECTLY BACK TO THE PR REGISTER FOR THAT TIME PERIOD. THESE PAYROLL ENTRIES (FROM GUSTO) ARE THEN WHAT IS USED TO CREATE THE ALLOCATIONS. ANY UNEXPLAINED VARIANCE WILL BE RESOLVED BEFORE THE JOURNAL ENTRY IS FINALIZED

View Audit 410756

Finding 1229270 (2025-003)

Material Weakness 2025

Project Support Housing II

CO

HUD Housing Programs Subrecipient Monitoring Cash Management

Management has corrected this required deposit (on 4/21/2026). Management has assigned responsibility to a designated individual for monitoring residual receipts requirements and deadlines and banking restrictions. Required deposits to the Residual Account will be addressed and made whole within the...

Management has corrected this required deposit (on 4/21/2026). Management has assigned responsibility to a designated individual for monitoring residual receipts requirements and deadlines and banking restrictions. Required deposits to the Residual Account will be addressed and made whole within the full picture of the need to stabilize the project’s financial issues. Provide staff training on HUD regulatory requirements related to restricted accounts.

View Audit 410749

Finding 1229269 (2025-002)

Material Weakness 2025

Project Support Housing II

CO

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Management concurs with the auditor’s recommendations. The Organization experienced an extreme legal issue with one tenant that drained the checking account above the usual expenses in 2024 and 2025 plus lowered the revenue for the unit until the Organization could successfully evict the tenant from...

Management concurs with the auditor’s recommendations. The Organization experienced an extreme legal issue with one tenant that drained the checking account above the usual expenses in 2024 and 2025 plus lowered the revenue for the unit until the Organization could successfully evict the tenant from the property. This was an unusually aggressive and unethical tenant that used the system to inflict continuous financial hardships on the Organization. To remedy this situation, management noted there are no pending legal issues at this time or outstanding attorney charges and will: Submit proper documentation to HUD to request retroactive approval of transfer with HUD Funds Authorization. Management will be in contact with HUD on how to resolve the unauthorized transfer covering the extreme legal issue. This action will be addressed within the full picture of the need to stabilize the project’s physical and financial issues to ensure that the organization continues to function effectively. Implement internal controls to ensure that all future withdrawals from restricted account receive required HUD authorization prior to disbursement and banking restrictions. Provide staff training on HUD regulatory requirements related to restricted accounts.

View Audit 410749

Finding 1229268 (2025-002)

Material Weakness 2025

Housing Authority of the City of Athens, Alabama

AL

Significant Deficiency Internal Control / Segregation of Duties

Corrective Action Plan: The Housing Authority concurs with the recommendation. The Authority recognizes that limited accounting staff and competing operational demands contributed to delays in completing accurate unaudited multifamily submissions and timely identifying necessary adjusting entries. M...

Corrective Action Plan: The Housing Authority concurs with the recommendation. The Authority recognizes that limited accounting staff and competing operational demands contributed to delays in completing accurate unaudited multifamily submissions and timely identifying necessary adjusting entries. Management is implementing a sustainable solution that combines specialized technical assistance, documented procedures, staff training, and executive review. The Authority has begun reviewing the calendar year 2021 submission and compiling the financial records required for the outstanding 2022 through 2025 submissions. The Authority is seeking to retain an expert in HUD Multifamily and REAC financial reporting to assist staff in correcting prior submissions and preparing, validating, and submitting all required filings. The Authority will complete the following corrective actions: 1. Reconcile and validate the general ledger balances, trial balances, and supporting schedules for each affected reporting year. 2. Correct and resubmit the calendar year 2021 unaudited multifamily submission and prepare and submit the required unaudited multifamily submissions for calendar years 2022 through 2025. 3. Establish a written year-end closing and REAC submission calendar and checklist identifying responsible staff, required supporting schedules, due dates, and supervisory review before submission. 4. Provide appropriate staff training and require quarterly management review of balance-sheet reconciliations, audit-adjustment status, and HUD submission deadlines until the backlog is eliminated and the revised controls are operating effectively. hese measures are designed to address the Authority's limited staffing capacity while creating a practical and sustainable process for accurate financial reporting and timely HUD submissions.

View Audit 410746

Finding 1229267 (2025-001)

Material Weakness 2025

Housing Authority of the City of Athens, Alabama

AL

Cash Management HUD Housing Programs Material Weakness

Corrective Action Plan: The Housing Authority concurs with the auditor's recommendation. The outstanding inter-entity balance has been identified as a legacy balance associated with the RAD conversion and the transfer of assets and liabilities to Athens Housing Management, LLC. Management's review a...

Corrective Action Plan: The Housing Authority concurs with the auditor's recommendation. The outstanding inter-entity balance has been identified as a legacy balance associated with the RAD conversion and the transfer of assets and liabilities to Athens Housing Management, LLC. Management's review and reconciliation of the balance are in progress. Before recording any final disposition, the Authority will determine the balance's origin, funding source, supporting documentation, legal obligation, and collectability, including whether federally restricted or RAD/PBRA project funds are involved. The Board of Commissioners may authorize the accounting disposition of the balance, subject to the Authority's governing documents and applicable law; however, a Board vote alone will not be treated as authority to forgive or extinguish a federally restricted or project-level receivable. The Authority will complete the following process: 1. Complete and document the reconciliation and proposed accounting treatment in both entities' records, with management and legal review, and provide the supporting documentation to the Authority's auditor. 2. Determine whether the balance is subject to the RAD closing documents, HAP Contract, RAD Use Agreement, Surplus Cash requirements, or other Federal restrictions. If so, submit the reconciliation, proposed entries, supporting documentation, and draft resolutions to the appropriate HUD Field Office or Multifamily Account Executive and obtain written direction or concurrence, as applicable. 3.Present conditional resolutions to the governing boards of the Housing Authority and Athens Housing Management, LLC, as applicable, authorizing the Chief Executive Officer to record the disposition only after all required HUD approvals or concurrences have been received. 4. Record corresponding entries in both entities, retain the complete reconciliation and approval package, and disclose the final resolution to the auditor. This process is consistent with 2 CFR §§ 200.302 and 200.303, which require accurate, supported financial records, accountability for Federal funds and assets, and documented internal controls. It also recognizes the RAD Notice requirements governing Surplus Cash and related-party advances. Going forward, inter-entity balances will be reconciled monthly, reviewed by management, and any unresolved items will be reported to the Chief Executive Officer as part of the monthly financial review.

View Audit 410746

Finding 1229266 (2025-001)

Material Weakness 2025

Escambia Community Clinics, Inc. Dba Community Health Nw Florida

FL

Special Tests & Provisions Eligibility

Management concurs with the noted deficiencies and has implemented, or is in the process of implementing, corrective actions to strengthen compliance with HRSA Sliding Fee Discount Program requirements. Actions include the immediate use of standardized eligibility checklists, enhanced documentation ...

Management concurs with the noted deficiencies and has implemented, or is in the process of implementing, corrective actions to strengthen compliance with HRSA Sliding Fee Discount Program requirements. Actions include the immediate use of standardized eligibility checklists, enhanced documentation requirements, and monthly compliance reviews of approved applications. A secondary review process for eligibility determinations will be implemented, along with formalized staff training programs to be completed within established timelines. Additionally, management will establish a quarterly internal audit process to monitor ongoing compliance, with results reported to appropriate oversight personnel. These measures are designed to improve accuracy, consistency, and oversight, and management will continue to monitor compliance through recurring reviews and annual policy assessments.

View Audit 410744

Finding 1229263 (2025-007)

Material Weakness 2025

Mercer County

NJ

Reporting

Implement procedures to ensure the reports filed are in agreement with the County's financial accounting records and be clerically accurate.

View Audit 410743

Finding 1229255 (2025-006)

Material Weakness 2025

Galveston County Health District

TX

Reporting

Corrective Action: The District will establish a formal Federal Grant Compliance Reporting Calendar and Review Process. The corrective action will include: 1. Development and maintenance of a comprehensive federal reporting calendar identifying: o Grant/program; o Required report; o Reporting freque...

Corrective Action: The District will establish a formal Federal Grant Compliance Reporting Calendar and Review Process. The corrective action will include: 1. Development and maintenance of a comprehensive federal reporting calendar identifying: o Grant/program; o Required report; o Reporting frequency; o Federal or grantor due date; o Responsible preparer; o Supervisory reviewer; o Backup personnel; o Date prepared; o Date reviewed; and o Date submitted. 2. Establishment of internal deadlines sufficiently in advance of federal reporting deadlines to allow for supervisory review and correction. 3. Documented supervisory review before submission of federal reports. 4. Assignment of backup personnel for critical federal reporting responsibilities. 5. Periodic management review of upcoming reporting deadlines. 6. An escalation procedure for reports approaching their deadline without completion. 7. Retention of evidence demonstrating report preparation, review, submission, and acceptance when available. 8. Quarterly review of the federal reporting calendar to identify changes in grant requirements, personnel responsibilities, or reporting deadlines. 9. Coordination of the federal reporting calendar with the year-end close and Single Audit timetable. 10. Upon execution and implementation of the ICA, applicable grant accounting and financial reporting procedures will be coordinated with the County Auditor's Office to the extent those functions are included within the shared services established under the Agreement. Measure of Completion: The District will have the formal federal reporting calendar, assigned responsibilities, backup assignments, supervisory review procedures, and escalation procedures implemented by October 31, 2026. All federal reports will thereafter be submitted by their applicable deadlines. Management will retain documentation demonstrating timely preparation, supervisory review, and submission. Any missed deadline will be documented, investigated, and addressed through appropriate corrective action. Target Completion Date: October 31, 2026, for development and implementation; ongoing thereafter. District Management Contact: Tomiko Fisher, Chief Operating Officer

View Audit 410741

Finding 1229254 (2025-005)

Material Weakness 2025

Galveston County Health District

TX

Reporting

Corrective Action: The District will establish a formal Federal Award Period-of-Performance and Payroll Cutoff Procedure as a component of its year-end closing and grant reporting processes. The corrective action will include: 1. Identification of all payroll periods crossing the September 30 fiscal...

Corrective Action: The District will establish a formal Federal Award Period-of-Performance and Payroll Cutoff Procedure as a component of its year-end closing and grant reporting processes. The corrective action will include: 1. Identification of all payroll periods crossing the September 30 fiscal year-end. 2. Calculation and documentation of payroll and related benefits attributable to each fiscal year. 3. Procedures to ensure federal award expenditures reported on the SEFA are recorded in the appropriate fiscal period. 4. Documented spot checks of payroll and nonpayroll federal expenditures around fiscal year-end. 5. Coordination between Payroll, Accounting, and Grant Accounting regarding fiscal-year cutoff. 6. Supervisory review of year-end federal award cutoff calculations before preparation of the SEFA. 7. Training for accounting, payroll, and grant personnel regarding period-of-performance and fiscal-year cutoff requirements. 8. Upon execution and implementation of the ICA, applicable grant accounting, payroll cutoff, and financial reporting procedures will be coordinated with the County Auditor's Office to the extent those functions are included within the shared services established under the Agreement. Measure of Completion: The District will have the formal federal award period-of-performance and payroll cutoff procedures implemented by October 31, 2026. The procedures will thereafter be incorporated into the annual year-end close process. All federal award payroll and applicable nonpayroll expenditures crossing fiscal year-end will be reviewed and documented. The FY2026 SEFA will receive a specific period-of-performance and cutoff review before submission to the independent auditors. Target Completion Date: October 31, 2026, for development and implementation; ongoing thereafter. District Management Contact: Tomiko Fisher, Chief Operating Officer

View Audit 410741

Finding 1229249 (2025-009)

Material Weakness 2025

Urshan College

MO

Eligibility Reporting Significant Deficiency § 200.303

2025-009 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation ...

2025-009 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University reviewed its awarding and reconciliation processes following the identified discrepancy between COD and the institutional ledger, which resulted from packaging based on an earlier ISIR transaction without confirming the most recent ISIR data. To address this, the University has partnered with FA Solutions and implemented enhanced controls within Regent, including system checks to flag updated ISIR information and require confirmation of the most current transaction prior to packaging.Additionally, reconciliations and related reporting provided by FA Solutions will be reviewed for accuracy and completeness. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 3/31/2026

View Audit 410734

Finding 1229248 (2025-008)

Material Weakness 2025

Urshan College

MO

Cash Management Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

2025-008 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University should implement formal review procedures to document that the Cash Management reconciliation and drawdown reviews are bei...

2025-008 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University should implement formal review procedures to document that the Cash Management reconciliation and drawdown reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University performs cash management reconciliation and drawdown reviews; however, formal documentation of these reviews has not been consistently maintained. To address this, the University is implementing formal review procedures that include documented evidence of reconciliation and drawdown review activities. As part of this process, reconciliations and drawdowns prepared by FA Solutions will be reviewed by the Financial Aid Office for accuracy and completeness prior to submission and reporting. These procedures will be formalized within a standardized SOP, which will outline review timelines, responsibilities, and required documentation to ensure errors are identified and resolved in a timely manner and to reduce the risk of discrepancies going undetected. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 4/30/2026

View Audit 410734

Finding 1229247 (2025-007)

Material Weakness 2025

Urshan College

MO

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2025-007 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance over stale checks that need to be returne...

2025-007 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance over stale checks that need to be returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is implementing enhanced controls to ensure compliance with stale-dated Title IV credit balance checks. This includes establishing a monthly review process in coordination with Accounts Payable, Accounts Receivable, and the Financial Aid Office to identify any outstanding checks approaching or exceeding the 240-day threshold. As part of this process, a tracking mechanism will be maintained to monitor the status and issuance dates of all Title IV credit balance checks. The University will make reasonable efforts to contact students and reissue checks, as appropriate, to ensure funds are received. Any checks that remain uncashed and meet the stale-dated threshold will be voided and returned to the U.S. Department of Education in accordance with federal requirements. These procedures will be formalized within a standardized SOP to ensure consistent and timely compliance moving forward. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid, Accounts Receivable Clerk, and Accounts Payable Clerk Planned completion date for corrective action plan: 4/30/2026

View Audit 410734

Finding 1229246 (2025-006)

Material Weakness 2025

Urshan College

MO

Student Financial Aid Eligibility Significant Deficiency § 200.303

2025-006 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are award...

2025-006 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has conducted a review of its procedures for awarding Title IV funds, with particular attention to the awarding of Summer Pell. Through this review, we identified that Summer Pell was not awarded to eligible students during the applicable period, due in part to a misunderstanding of awarding requirements during a transition in third-party processing support. Urshan has since partnered with FA Solutions to strengthen oversight and ensure alignment with federal awarding requirements. Updated procedures have been implemented to ensure all eligible students are properly evaluated for Title IV aid, including Summer Pell, across all applicable terms. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 8/31/2026

View Audit 410734

Finding 1229245 (2025-005)

Material Weakness 2025

Urshan College

MO

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency § 200.303

2025-005 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review the GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit ...

2025-005 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review the GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has completed a comprehensive review and revision of its Written Information Security Program (WISP) to ensure alignment with all applicable requirements under the Gramm-Leach-Bliley Act (GLBA). While these updates were finalized after the end of FY25, the revised WISP now includes all required elements. The University has also received confirmation from the U.S. Department of Education’s Cybersecurity Compliance team that the updated program meets minimum GLBA compliance requirements. Moving forward, the University will maintain and periodically review its WISP to ensure ongoing compliance with federal standards. Name(s) of the contact person(s) responsible for corrective action: Dewayne Presson & Keith Braswell | Urshan IT Department Planned completion date for corrective action plan: 3/31/2026

View Audit 410734

Finding 1229244 (2025-004)

Material Weakness 2025

Urshan College

MO

Special Tests & Provisions Student Financial Aid Significant Deficiency § 200.303

2025-004 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation o...

2025-004 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Urshan has partnered with FA Solutions, an experienced third-party processor. Through this partnership, we have strengthened our processes and implemented additional checks and balances to ensure that R2T4 determinations are identified, calculated, and processed in a timely and compliant manner. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 3/31/2026

View Audit 410734

Finding 1229243 (2025-003)

Material Weakness 2025

Urshan College

MO

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

U.S. Department of Education 2025-003 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are...

U.S. Department of Education 2025-003 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Urshan is currently in the onboarding process to partner with the National Student Clearinghouse, which will improve the timeliness and accuracy of our enrollment reporting to NSLDS. In addition, we are developing and implementing a standardized SOP that establishes defined reporting schedules (at least every 60 days), clearly outlines roles and responsibilities, and includes reconciliation procedures to ensure data accuracy. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 7/31/2026

View Audit 410734

Finding 1229231 (2025-003)

Material Weakness 2025

City of South Bend

IN

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

Finding 2025-003 Information on the federal program: Subject: Home Investment Partnerships Program – Internal Controls Federal Agency: Department of Housing and Urban Development Federal Program: Home Investment Partnerships Program Assistance Listing Number: 14.239 Pass-Through Entity: N/A - Direct...

Finding 2025-003 Information on the federal program: Subject: Home Investment Partnerships Program – Internal Controls Federal Agency: Department of Housing and Urban Development Federal Program: Home Investment Partnerships Program Assistance Listing Number: 14.239 Pass-Through Entity: N/A - Direct Grant Compliance Requirement: Special Tests and Provisions - Underwriting Requirements Audit Findings: Significant Deficiency Condition: The Consortium did not have a documented review control in place to ensure the underwriting calculation was prepared and calculated accurately. There was no documented proof of segregation of duties. Context: In a sample of two, one selection was noted where the underwriting calculation did not have evidence of preparer or reviewer. The selected underwriting calculation was prepared in April 2025. The Consortium implemented a control process in September 2025. The second sample tested had proper review and was completed in September 2025. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will implement a system of internal controls to ensure the required underwriting calculations are prepared, reviewed, and maintained. Responsible Party and Timeline for Completion: The Consortium Director (or their designee) and the Federal Grant Administrator are responsible for implementation. The Consortium has implemented additional controls effective September 2025.

View Audit 410728

Finding 1229227 (2025-002)

Material Weakness 2025

City of South Bend

IN

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

Finding 2025-002 Information on the federal program: Subject: Home Investment Partnerships Program – Internal Controls Federal Agency: Department of Housing and Urban Development Federal Program: Home Investment Partnerships Program Assistance Listing Number: 14.239 Pass-Through Entity: N/A - Direct...

Finding 2025-002 Information on the federal program: Subject: Home Investment Partnerships Program – Internal Controls Federal Agency: Department of Housing and Urban Development Federal Program: Home Investment Partnerships Program Assistance Listing Number: 14.239 Pass-Through Entity: N/A - Direct Grant Compliance Requirement: Special Tests and Provisions – Maximum Per Unit Subsidy Audit Findings: Material Weakness Condition: The Consortium did not have a documented review control in place to ensure the per-unit subsidy calculation was prepared and calculated accurately. There was no documented proof of segregation of duties. Context: In a sample of two, the following instances were noted: • For the first selection, the per-unit subsidy information was entered into the HUD system (IDIS) during the project close out. There is no evidence of segregation of duties over the preparation and review of IDIS inputs. • For the second selection, the calculation was prepared by a former employee in 2025 and did not have sign off by the preparer or reviewer. A secondary review with evidence of sign off was performed subsequent to the audit period in 2026. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will implement a system of internal controls to ensure the required per unit subsidy calculations are prepared, reviewed, and maintained. Responsible Party and Timeline for Completion: The Consortium Director (or their designee) and the Federal Grant Administrator are responsible for implementation. The Consortium has implemented additional controls effective September 2026.

View Audit 410728

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