Corrective Action Plans

Finding 1191467 (2025-003)

Material Weakness 2025

MI

Student Financial Aid Reporting Significant Deficiency

Fiscal Operations Report and Application to Participate (FISAP) Reporting Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items (information on eligible aid applicants) identified in the com...

Fiscal Operations Report and Application to Participate (FISAP) Reporting Auditor Description of Condition and Effect. It was noted during our testing of the FISAP that the College did not have support for one of the eight key line items (information on eligible aid applicants) identified in the compliance supplement as critical information. As a result, the College is not in compliance with the Department of Education requirements that state the FISAP must be accurately reporting information. Auditor Recommendation. We recommend the College review their policies and procedures surrounding FISAP reporting. Corrective Action. The College is improving its documentation and retention processes to ensure all information used in preparing the annual FISAP report is fully supported and available for review. Moving forward, all data underlying the eight key line items identified in the compliance supplement will be saved, documented, and stored in a consistent and accessible manner. Information obtained from other departments will be retained in its original format, and any data extracted from PowerFAIDS or related systems will be saved at the time of report preparation. By implementing these documentation and retention procedures as standard operating practice, the College ensures FISAP submissions are accurate, verifiable, and compliant with federal audit requirements. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026

View Audit 395393

Finding 1191462 (2025-002)

Material Weakness 2025

Montcalm Community College

MI

Eligibility Student Financial Aid Reporting

Ineligible Student Received Title IV Funding Auditor Description of Condition and Effect. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed...

Ineligible Student Received Title IV Funding Auditor Description of Condition and Effect. During our testing, we noted that a student successfully appealed their academic dismissal in the Summer 2022–2023 semester. The student did not receive Title IV funding during that term and subsequently failed both attempted courses. Despite the lack of demonstrated academic improvement following the appeal, the student was awarded Title IV funding in the Spring 2024–2025 semester based on the appeal granted during the 2022–2023 academic year. As a result of this condition, one student received Title IV funding that who was not eligible based on the criteria outlined in the College's satisfactory academic policy (SAP). Auditor Recommendation. We recommend the College implement a formal review process to verify that students who were previously dismissed and granted an appeal in a prior academic year have demonstrated the required academic improvement before receiving subsequent Title IV funding, or alternatively, obtain a new appeal determination. Corrective Action. Management acknowledges this finding and is implementing strengthened Satisfactory Academic Progress (SAP) review procedures to ensure students who previously appealed an academic dismissal are properly evaluated before receiving Title IV funding. The Financial Aid Office is now working closely with the Registrar to ensure both Title‑IV and non‑Title‑IV students undergo appropriate SAP monitoring. Information Technology is developing a report that identifies students by financial‑aid track status, allowing Financial Aid to review aid‑receiving students while the Registrar evaluates all others. Students who require SAP follow‑up are contacted by the appropriate office, and SAP appeal forms are reviewed under updated criteria to ensure students demonstrate academic improvement before additional aid is awarded. These steps ensure the College remains compliant with federal SAP requirements and prevents ineligible students from receiving Title IV funds. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. June 30, 2026

View Audit 395393

Finding 1191457 (2025-003)

Material Weakness 2025

Metro Technology Center

OK

Student Financial Aid Reporting

Finding 2025-003 Finding Summary: Some discrepancies were noted between the District and NSLDS. One student's data was not updated within the allowable time period. Responsible Individuals: Melissa Thornton, Financial Aid Manager Corrective Action Plan: We have worked within the department to ensure...

Finding 2025-003 Finding Summary: Some discrepancies were noted between the District and NSLDS. One student's data was not updated within the allowable time period. Responsible Individuals: Melissa Thornton, Financial Aid Manager Corrective Action Plan: We have worked within the department to ensure proper reporting on the financial aid systems. Anticipated Completion Date: July 1, 2026

View Audit 395391

Finding 1191452 (2025-001)

Material Weakness 2025

Bluffton Unversity

OH

Student Financial Aid Special Tests & Provisions

The Registrar and Student Financial Aid Director will both ensure that any students that have updated their status are updated on a weekly basis. Registrar’s office will log into NSLDS to upload the file, and the CFO, Registrar, and Student Financial Aid Director will monitor updates monthly.

View Audit 395390

Finding 1191450 (2025-002)

Material Weakness 2025

Langston University

OK

Equipment & Real Property Management § 200.303 § 200.313

Research and Development – Assistance Listing No. Various Agriculture Extension at 1890 Land-grant Institutions – Assistance Listing No. Various Higher Education Institutional Aid – Assistance Listing No. Various Recommendation: We recommend the University ensure that a physical inventory over equip...

Research and Development – Assistance Listing No. Various Agriculture Extension at 1890 Land-grant Institutions – Assistance Listing No. Various Higher Education Institutional Aid – Assistance Listing No. Various Recommendation: We recommend the University ensure that a physical inventory over equipment is completed at least every two years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is committed to strengthening its physical inventory process for tracking fixed assets. We are actively recruiting a Capital Asset Accountant. This is a new position within the Controller’s area that will assume primary responsibility for equipment management. The position will assume the following equipment management responsibilities: • Coordinate the accounting of equipment acquisitions/dispositions/disposals daily. • Place physical tags on all new equipment purchases, creating a video log along the way. • Perform a physical inventory of equipment, department by department, throughout the year. At a minimum, every item should be verified at least once per fiscal year. • Maintain an accurate record of additions/dispositions/disposals in Banner, which supports the external audit and reflects the results of the above-mentioned physical inventories. • Coordinate the periodic disposal/sale/auction of unneeded physical assets. In addition, existing personnel are actively working to ensure a complete physical inventory has been conducted by fiscal year-end. Name(s) of the contact person(s) responsible for corrective action: Ms. Nykkia Harris, Controller for Fiscal and Administrative Affairs Planned completion date for corrective action plan: June 2026

View Audit 395389

Finding 1191428 (2025-003)

Material Weakness 2025

Langston University

OK

Procurement, Suspension & Debarment Significant Deficiency § 200.303 § 200.318

Research and Development – Assistance Listing No. 10.205 Agriculture Extension at 1890 Land-grant Institutions – Assistance Listing No. 10.512 Higher Education Institutional Aid – Assistance Listing No. 84.031 Recommendation: We recommend that the University review policies and procedures for procur...

Research and Development – Assistance Listing No. 10.205 Agriculture Extension at 1890 Land-grant Institutions – Assistance Listing No. 10.512 Higher Education Institutional Aid – Assistance Listing No. 84.031 Recommendation: We recommend that the University review policies and procedures for procurement to ensure that every applicable transaction is going through the proper procurement procedures Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is reviewing existing procurement policies and procedures and strengthening processes as necessary. Additionally, training is being provided to relevant personnel to ensure an understanding of proper procurement procedures. Name(s) of the contact person(s) responsible for corrective action: Ms. Andrea Sherwood, Assistant Director, Grants and Contracts Financial Administration at Oklahoma State University and Ms. Nykkia Harris, Controller for Fiscal and Administrative Affairs Planned completion date for corrective action plan: June 2026

View Audit 395389

Finding 1191374 (2025-005)

Material Weakness 2025

Langston University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness § 200.303

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal...

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal TEACH Grant Program – Assistance Listing No. 84.379 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement additional 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: This is a repeat finding that was first presented to the University in conjunction with the release of the 2022 audit report in November 2023. While procedures had previously been implemented to address this issue, additional measures are being taken to ensure full compliance. The University will implement additional udates to its NSLDS reporting processes to ensure needed submissions are reported timely and accurately. Respective staff will receive additional training to ensure proper reporting to NSLDS occurs. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid; Mr. Heath Burge, Assistant Vice President for Strategic Enrollment and Advising Services; and Mrs. Jeanese Outlaw-Gunter, University Registrar Planned completion date for corrective action plan: April 2026

View Audit 395389

Finding 1191373 (2025-006)

Material Weakness 2025

Langston University

OK

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

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds ar...

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is evaluating its current Title IV funds procedures and implementing additional procedures to ensure timely return of refunds. This includes assigning additional staff to manage this process. Also, relevant staff have been reminded of the need to notify Financial Aid of student withdrawals timely. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid Planned completion date for corrective action plan: March 2026

View Audit 395389

Finding 1191337 (2025-004)

Material Weakness 2025

Langston University

OK

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

Student Financial Aid Cluster: TEACH Grant – Assistance Listing No. 84.379 Recommendation: We recommend the University review and update current procedures to ensure that students meet eligibility requirements prior to receiving the TEACH Grant. Explanation of disagreement with audit finding: There ...

Student Financial Aid Cluster: TEACH Grant – Assistance Listing No. 84.379 Recommendation: We recommend the University review and update current procedures to ensure that students meet eligibility requirements prior to receiving the TEACH Grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated procedures to ensure verification of student GPA prior to disbursement of TEACH Grant funding. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid and Ms. Courtney Youngblood, Assistant Director of Financial Aid Planned completion date for corrective action plan: September 2025

View Audit 395389

Finding 1191322 (2025-001)

Material Weakness 2025

Langston University

OK

Subrecipient Monitoring Cash Management Significant Deficiency § 200.303 § 200.305

Research and Development – Assistance Listing No. 10.215 Research and Development – Assistance Listing No. 93.433 Recommendation: We recommend that the University review and update policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to per...

Research and Development – Assistance Listing No. 10.215 Research and Development – Assistance Listing No. 93.433 Recommendation: We recommend that the University review and update policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2023 audit report in May 2024. The 2023 audit was completed after substantially all of Fiscal Year 2024 had elapsed, so there was not adequate time for the University to fully implement corrective action. While these corrective measures were implemented during Fiscal Year 2025, they did not fully resolve the issue. The University continues to strengthen its accounts payable processes and sign-off approvals to help ensure reimbursements to subrecipients are paid timely. Additional updates to procedures for payment processing are also being developed. Methods for more accurate tracking of invoice receipt dates are being developed to ensure the 30-day period begins on the correct day. Principal investigators and designated administrative personnel within academic departments will be reminded of the need to initiate payments to subrecipients timely. Accounts payable training has been held for such personnel and will persist. Name(s) of the contact person(s) responsible for corrective action: Ms. Andrea Sherwood, Assistant Director, Grants and Contracts Financial Administration at Oklahoma State University and Ms. Nykkia Harris, Controller for Fiscal and Administrative Affairs Planned completion date for corrective action plan: May 2026

View Audit 395389

Finding 1191228 (2025-001)

Material Weakness 2025

Brownsville Housing Authority

TN

HUD Housing Programs Special Tests & Provisions

Auditors’ Recommendation: The Authority should perform housing quality control re-inspections according to HUD guidelines. Grantee Response: We will comply with the auditors’ recommendation. Anticipated Completion Date: June 30, 2026 Views of responsible officials and planned corrective actions: We ...

Auditors’ Recommendation: The Authority should perform housing quality control re-inspections according to HUD guidelines. Grantee Response: We will comply with the auditors’ recommendation. Anticipated Completion Date: June 30, 2026 Views of responsible officials and planned corrective actions: We will comply with the auditors’ recommendations.

View Audit 395383

Finding 1191227 (2025-004)

Material Weakness 2025

Isd # 13 Columbia Heights

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties School Nutrition Programs § 200.318

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-004 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Findi...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-004 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Bryan Hennekens, Director of Finance and Operations. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Bryan Hennekens, Director of Finance and Operations, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

View Audit 395377

Finding 1191224 (2025-003)

Material Weakness 2025

University of Pikeville

KY

Student Financial Aid Eligibility

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.165(a). Condition: During our eligibility testing, 10 of 38 students who received Direct Loans were...

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.165(a). Condition: During our eligibility testing, 10 of 38 students who received Direct Loans were not notified of their disbursements timely by the University. Cause: The University did not have controls in place to ensure students were being notified of Direct Loan disbursements in a timely manner (within 30 days before or 30 days after crediting the students' account). Effect: The provisions of 34 CFR 668.165(a) were not followed and thus a total of 10 students were not notified of Direct Loan disbursements in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University update their internal controls related to Direct Loan disbursements and send required communications prior to crediting the students' accounts. Corrective Actions Taken or Planned: We agree with this finding and recommendation. The financial aid office has automated the process to send disbursement notifications. Disbursement notifications are sent the day after loans are posted to a student’s account. Responsible Parties: Daniel Donner, Director of Financial Aid Completion Date: November 05, 2025

View Audit 395369

Finding 1191223 (2025-002)

Material Weakness 2025

University of Pikeville

KY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR 685.309(b). Condition: During our testing of 40 students for NSLDS enrollment, we noted eight...

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR 685.309(b). Condition: During our testing of 40 students for NSLDS enrollment, we noted eight students' enrollment effective date was the commencement date instead of the last day of the term. One student's graduation status was not reported to the NSLDS and one student's graduation was not certified to the NSLDS within the 60-day requirement. Cause: The University did not have controls in place to ensure students' classification were being properly reported to the NSLDS or reported in a timely manner. Effect: There were ten student status changes that were either not reported, not reported accurately, or not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus, students were subsequently not placed into loan repayment status in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to the NSLDS. In addition, we recommend that the University submit roster files on a regular basis. Corrective Actions Taken or Planned: We agree with this finding and recommendation. The Director of Institutional Research will report the last day of the term for NSLDS reporting. Responsible Parties: Margaret Sidle, Director of Institutional research Completion Date: March 4, 2026

View Audit 395369

Finding 1191222 (2025-001)

Material Weakness 2025

University of Pikeville

KY

Student Financial Aid Reporting

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.22(a). Condition: During our testing of six official withdrawals, we noted one instance where the U...

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.22(a). Condition: During our testing of six official withdrawals, we noted one instance where the University incorrectly treated a student as withdrawn for Return of Title IV (R2T4) purposes. The student was enrolled in both modules for the Fall term, earned six credit hours in the first module and subsequently withdrew during the second module. The University reported the student as withdrawn to the National Student Loan Data System (NSLDS) and performed a R2T4 calculation using the total days of both modules in the denominator of the R2T4 calculation. However, since the student successfully completed six credit hours in the first module, which exceeds the coursework required for the University's definition of half time enrollment, the student should not have been classified as withdrawn nor had a R2T4 calculation performed. Upon further analysis from management, there were an additional five students that were enrolled in modules, earning half-time enrollment, who were reported as withdrawn to the NSLDS and a R2T4 calculation was erroneously completed for them. Cause: This error occurred due to inadequate internal controls over identifying withdrawal status for students enrolled in module courses, specifically related to assessing whether completed coursework met or exceeded the half-time enrollment threshold prior to performing an R2T4 calculation or reporting them as withdrawn to the NSLDS. Effect: The provisions of 34 CFR 668.22(a) were not followed and thus a total of six students had a R2T4 calculation erroneously performed. Six students were also erroneously reported as withdrawn to the NSLDS. Questioned Costs: There were no questioned costs associated with this finding Recommendation: We recommend that the University strengthen its internal controls related to R2T4 calculations by: (a) implementing a system control to evaluate whether or not completed module coursework meets the half-time threshold before classifying a student as withdrawn, (b) providing additional training to financial aid staff on withdrawal determinations and performing an R2T4 calculation for students enrolled in modules, and (c) performing a supervisory review of all R2T4 calculations related to module students. Corrective Actions Taken or Planned: We agree with this finding and recommendation. After further review of R2T4 rules for module programs, the University of Pikeville will no longer perform R2T4’s on any student that has met the Exemption rules per FSA handbook, Vol 5, Chapter 1, “R2T4 Withdrawal Exemptions”. Responsible Parties: Daniel Donner, Director of Financial Aid Completion Date: March 4, 2026

View Audit 395369

Finding 1191221 (2025-001)

Material Weakness 2025

Housing Authority of Gilmer

TX

HUD Housing Programs Allowable Costs / Cost Principles

Corrective Action Plan - Public and Indian Housing - interfund receivable balance. Contact person: Alana Burnet, Executive Director, Housing Authority of Gilmer, 104 Circle Drive, Gilmer, TX 75644-0397, telephone number (903) 843-3141. Correction action planned: The PHA will have its Section 8 new c...

Corrective Action Plan - Public and Indian Housing - interfund receivable balance. Contact person: Alana Burnet, Executive Director, Housing Authority of Gilmer, 104 Circle Drive, Gilmer, TX 75644-0397, telephone number (903) 843-3141. Correction action planned: The PHA will have its Section 8 new construction program reimburse the Public and Indian Housing Program for the interfund balance and make sure any interfund activity is reimbursed on a monthly basis. Anticipated completion date: Immediately.

View Audit 395356

Finding 1191220 (2025-003)

Material Weakness 2025

Talladega College

AL

Procurement, Suspension & Debarment § 200.318

1. Finding Summary: The College entered into contracts with vendors without verifying their eligibility to receive federal funds. Testing of 50 procurement transactions identified that the College could not provide documentation that a suspension or debarment check had been performed via SAM.gov pri...

1. Finding Summary: The College entered into contracts with vendors without verifying their eligibility to receive federal funds. Testing of 50 procurement transactions identified that the College could not provide documentation that a suspension or debarment check had been performed via SAM.gov prior to the award for 13 contracts (exceeding the $25,000 threshold). Additionally, the contracts did not include a provision requiring the contractor to certify their eligibility. While the subsequent search of SAM.gov revealed that the vendors involved were not actually suspended or debarred, the College was in violation of federal compliance requirements. 2. Management’s Position – Management agrees with the finding. We are currently implementing a new procurement checklist that requires a printed copy of the SAM.gov search results to be attached to the purchase order packet. Staff training on federal procurement requirements will be required. 3. Corrective Action – Management will adhere to new procurement checklist that requires a printed copy of the SAM.gov search results to be attached to the purchase order packet. Management will consider whether certain contracts will require the contractor to certify their eligibility as part of the request for proposal or submission of a final contract. Staff training on federal procurement requirements will be required, with a target completion date prior to July 1, 2026. 4. Responsible Party – While the Office of Sponsored Research and Programs will be responsible for adherence to the policy and completing the checklist, the VP of Finance & Administration will monitor compliance of this process. Additionally, the VP of Finance & Administration will reinforce adherence of the new policy with personnel involved with any federal contracts, specifically ensuring that the executive cabinet members are aware as well as the Director of Sponsored Programs. 5. Implementation Timeline – Implementation effective July 1, 2026. 6. Status of Corrective Action (if related to prior year) – Corrective actions are in progress.

View Audit 395352

Finding 1191219 (2025-006)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management

Finding Reference 2025-06 Corrective Action Plan: To strengthen internal controls, improve monitoring, and reduce delays in the certification and payment process, the Authority will implement the following operational improvements: The Authority is using the Finance Office Dashboard to track the sta...

Finding Reference 2025-06 Corrective Action Plan: To strengthen internal controls, improve monitoring, and reduce delays in the certification and payment process, the Authority will implement the following operational improvements: The Authority is using the Finance Office Dashboard to track the status of certifications and invoices in real time, identify bottlenecks in the approval process, and support proactive management of pending payments. A standardized Construction Certification Compliance Checklist will be used to validate all required federal compliance documentation before certifications are submitted to the Finance Office. This measure is expected to reduce the number of returned submissions and prevent delays during the billing review process. The Authority will develop a Help Desk platform for certification and invoice inquiries to formally manage, document, and track inquiries or claims related to Construction Certifications and Pre- Construction invoices, improving transparency and response times. The Authority will launch the ICMM Payment Tracking Table to consolidate and monitor the payment status of certifications and invoices. Additionally, the Authority is establishing intermediate milestones to progressively reduce the payment processing cycle, with the objective of moving from the current 40-day average toward the 30-day target. As part of this initiative, the Authority is expanding the use of the Project Management Information System (PMIS) to standardize and streamline the processing of construction certifications and payment documentation. Responsible: Mr. Angel M. Felix Cruz, Acting Director, Confidential Finance Office Planned Implementation Date: In process. The first operational improvement has been implemented. The remaining three measures are pending implementation. Expected to be completed on or before June 30, 2026.

View Audit 395336

Finding 1191218 (2025-005)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

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

Finding Reference 2025-05 Corrective Action Plan: The Authority implemented the following actions in March 2026 to ensure compliance with the Davis-Bacon Act and strengthen payroll certification process: On March 11, 2026, all personnel of the Construction Office receive adequate training on Davis-B...

Finding Reference 2025-05 Corrective Action Plan: The Authority implemented the following actions in March 2026 to ensure compliance with the Davis-Bacon Act and strengthen payroll certification process: On March 11, 2026, all personnel of the Construction Office receive adequate training on Davis-Bacon Act requirements and payroll certification processes. On March 20, 2026, the Authority prepared a formal communication to reinforce the compliance with the Davis Bacon Act and to provide updated forms and instructions for completing certification payroll process. On March 3, 2026, the Authority contracted external consultants to enhance monitoring procedures over contractors and subcontractors, including timeliness tracking of properly certified payroll on a weekly basis and follow-up on missing or incomplete documentation Responsible: Mr. Emilio Garay, PE, Construction Office Director Planned Implementation Date: In process. Expected to be completed on or before June 30, 2026.

View Audit 395336

Finding 1191217 (2025-004)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Subrecipient Monitoring § 200.303 § 200.332

Finding Reference 2025-04 Corrective Action Plan: The Authority will implement the following plan to perform this sub recipient monitoring within the required threeyear cycle established in its State Management Plan: 1. Scheduled On-site Monitoring Visit Scheduled for June 1 O, 2026 The visit will i...

Finding Reference 2025-04 Corrective Action Plan: The Authority will implement the following plan to perform this sub recipient monitoring within the required threeyear cycle established in its State Management Plan: 1. Scheduled On-site Monitoring Visit Scheduled for June 1 O, 2026 The visit will include programmatic, financial, and compliance reviews in accordance with FTA requirements and 2 CFR 200 2. Pre-visit Desk Review A comprehensive desk review will be conducted prior to the visit, including financial reports, subrecipient agreements, audit reports, and prior monitoring documentation 3. Standardized Monitoring Procedures ' The Authority will use an Oversight Review Checklist to ensure consistency, compliance, and proper documentation. 4. Monitoring Report Issuance A monitoring letter will be issued within 30 days of the visit, detailing findings, concerns, and required corrective actions, if applicable. 5, Follow-up and Resolution The Subrecipient will be required to submit a CAP, if findings are identified. The Authority will conduct follow-up procedures until full resolution is achieved. Preventive Measures The Authority will implement the following measures to prevent recurrence of this finding: Establish and maintain a risk-based Oversight Visit Schedule Ensure inclusion of: Subrecipients receiving reimbursement-based funding Subrecipients identified as high-risk based on financial, operational, or compliance factors Strengthen internal controls to ensure adherence to monitoring cycles Maintain centralized and complete documentation of all monitoring activities Responsible: Ora. Norma L. Garcf a Lebron, Management Officer, Federal Coordination Office Luis F. Colon Morales, Director, Federal Coordination Office Planned Implementation Date: In process. Expected to be completed on or before July 31, 2026.

View Audit 395336

Finding 1191216 (2025-003)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Internal Control / Segregation of Duties Subrecipient Monitoring

Finding Reference 2025-03 Corrective Action Plan: The Authority has assigned an Analyst and a Supervisor the responsibility of monitoring compliance with all federal requirements related to the reporting process of these funds. In addition, an adequate training will be provided to the personnel invo...

Finding Reference 2025-03 Corrective Action Plan: The Authority has assigned an Analyst and a Supervisor the responsibility of monitoring compliance with all federal requirements related to the reporting process of these funds. In addition, an adequate training will be provided to the personnel involved in the administration of this program. The Authority has also implemented the following procedure to ensure accurate financial reporting and supervision: The Analyst will prepare the reports in accordance with the work plan and submit them to the Supervisor for review and approval. The Supervisor will review the reports and will send an email confirming the approval. Once approved, the Analyst will send the reports to the pass though entity. Responsible: Mrs. Johanna Perez Falcon, Acting Director of the Office of Budget Planned Implementation Date: Completed.

View Audit 395336

Finding 1191215 (2025-002)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Reporting Internal Control / Segregation of Duties § 200.510

Finding Reference 2025-02 Corrective Action Plan: The Designated Office responsible for processing federal funds received through state agencies will deliver to the Finance Office a transaction list and a reconciliation of the disbursements made during the fiscal year. The Finance Office will review...

Finding Reference 2025-02 Corrective Action Plan: The Designated Office responsible for processing federal funds received through state agencies will deliver to the Finance Office a transaction list and a reconciliation of the disbursements made during the fiscal year. The Finance Office will review all transactions recorded during the current fiscal year and will prepare an accrual entry. These transactions will be reconciled against the transactions recorded during the subsequent fiscal year to confirm that funds were recorded in the appropriate fiscal period. The review and recording of these transactions will be completed during the final phase of the accounting closing process and prior to delivery of the Trial Balance to the external auditors. Responsible: Ms. Maria Del R. Ramos Ocasio, Accounting and Finance Manager Planned Implementation Date: In process. Expected to be completed on or before September 30, 2026.

View Audit 395336

Finding 1191214 (2025-003)

Material Weakness 2025

Concordia University Chicago

IL

Student Financial Aid Significant Deficiency § 200.303

2025-003 Documentation of Review Recommendation: We recommend the University re-evaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to ...

2025-003 Documentation of Review Recommendation: We recommend the University re-evaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The Office of Financial Aid will re-evaluate its current policies and procedures to clearly define internal control objectives and strengthen overall compliance. 2) The Office of Financial Aid has implemented – and will continue to maintain - a dual-review process (second-level review) for Return of Title IV Funds, federal award packaging, and the review of the FISAP report to ensure accuracy and regulatory compliance. 3) The Director and Assistant Director of Financial Aid will continue cross-training staff to promote operational continuity, reinforce internal controls, and maintain clear oversight of key processes. Name(s) of the contact person(s) responsible for corrective action: Vanesa Teran-Martinez, Jennifer Monroy Planned completion date for corrective action plan: June 30, 2026 If the Department of Education has questions regarding this schedule, please call Vanesa Teran-Martinez at 708-209-3338.

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Finding 1191208 (2025-002)

Material Weakness 2025

Concordia University Chicago

IL

Student Financial Aid Reporting Significant Deficiency

2025-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with au...

2025-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) All enrollment reporting was submitted to the National Student Clearinghouse in a timely manner. The delay occurred during the National Student Clearinghouse’s processing and submission to NSLDS. 2) The Office of the Registrar will work with the Office of Financial Aid to learn more about NSLDS compliance requirements and gain a better understanding of their relationship with the National Student Clearinghouse. 3) The Office of the Registrar will work with the National Student Clearinghouse to confirm the submitted reporting schedule for academic year 2026 – 2027 complies with and meets their expectations and will adjust (if needed). 4) The Office of the Registrar will continue to work with the Enrollment Offices to remind them that students who are not enrolled (and not on leave of absence, graduated, and/or deceased) must be marked as withdrawn based on external reporting compliance requirements. 5) The Office of the Registrar continues to work with IT (Banner Team) to improve reporting to capture students who are not enrolled (and not on leave of absence, graduated, and/or deceased) to be marked as withdrawn to comply with the National Student Clearinghouse and NSLDS compliance reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Ingrid Sorensen, Katarzyna Rodriguez Planned completion date for corrective action plan: June 30, 2026

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Finding 1191202 (2025-001)

Material Weakness 2025

Concordia University Chicago

IL

Student Financial Aid Eligibility Significant Deficiency

2025-001 Pell Grant Under Award Recommendation: We recommend the University implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit ...

2025-001 Pell Grant Under Award Recommendation: We recommend the University implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The Office of Financial Aid will continue to run monthly or bi-monthly enrollment reports for Pell Grant recipients to ensure awards are accurately determined based on enrollment status. 2) Financial Aid Counselors will continue to review the daily and weekly Hour Change Reports for each payment period to ensure Pell Grant awards are adjusted appropriately in response to enrollment status changes. 3) The Director and Assistant Director of Financial Aid will continue providing Banner (student information system) training to staff to ensure Pell Grant amounts are updated accurately within the system. Name(s) of the contact person(s) responsible for corrective action: Vanesa Teran-Martinez, Jennifer Monroy Planned completion date for corrective action plan: June 30, 2026

View Audit 395330

Corrective Action Plans

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