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Corrective Action Plans

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Finding 1173974 (2025-001)
Material Weakness 2025
City of Missoula
MT
Cash Management Reporting Significant Deficiency § 200.302 § 200.327 § 200.329
The City concurs with the finding. Audit testing identified no reporting errors, no noncompliance, and no questions costs; however, the City acknowledges that documentation of independent supervisory review was not formally required or retained prior to submission of federal reports and reimbursemen...
The City concurs with the finding. Audit testing identified no reporting errors, no noncompliance, and no questions costs; however, the City acknowledges that documentation of independent supervisory review was not formally required or retained prior to submission of federal reports and reimbursement requests. To strengthen documentation of internal control over compliance, the City will implement a formalized and documented secondary review process for all federal financial reports, performance reports, and reimbursement requests, to be retained in grant files in accordance with CFR §200.334 record retention requirements.
View Audit 387608
Finding 1173970 (2025-002)
Material Weakness 2025
City of Tustin
CA
Subrecipient Monitoring § 200.332
Corrective Action Plan: Management agrees with the finding. The City had a preexisting agreement with the subrecipient for a project that was already in progress when the federal grant was awarded. The subrecipient had in-depth involvement during the federal grant application process and is aware of...
Corrective Action Plan: Management agrees with the finding. The City had a preexisting agreement with the subrecipient for a project that was already in progress when the federal grant was awarded. The subrecipient had in-depth involvement during the federal grant application process and is aware of specific compliance requirements under the Uniform Guidance (2CFR Part 200). We will make sure that all future subrecipients of pass-through federal grants are notified in writing of the responsibility to adhere to federal administrative, cost, and audit requirements.
View Audit 387586
Finding 1173969 (2025-002)
Material Weakness 2025
Harvard Community Unit School District No. 50
IL
School Nutrition Programs
Corrective Action Plan Finding Number 2025-002 Condition: At June 30, 2025, the District maintained fund balances in excess of three months’ average expenditures. Management Response/Plan: The District has created a Spend Down Plan for the food service program based off guidance from the Illinois St...
Corrective Action Plan Finding Number 2025-002 Condition: At June 30, 2025, the District maintained fund balances in excess of three months’ average expenditures. Management Response/Plan: The District has created a Spend Down Plan for the food service program based off guidance from the Illinois State Board of Education. The District is working on replacing equipment and renovating cafeterias. Anticipated Date of completion: June 2026 Name of Contact Person: Melissa Geyman Sell
View Audit 387572
Finding 1173964 (2025-001)
Material Weakness 2025
Food for the Hungry
AZ
Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Significant Deficiency
Corrective Action Plan Description: Effective October 2025, FH will strengthen its documentation controls to ensure that only the final, approved version of each timesheet is maintained as support for payroll charges to federal awards. Any timesheet revised during the review and approval process wil...
Corrective Action Plan Description: Effective October 2025, FH will strengthen its documentation controls to ensure that only the final, approved version of each timesheet is maintained as support for payroll charges to federal awards. Any timesheet revised during the review and approval process will be clearly marked as “void,” and removed from the official support file. Payroll and grant personnel will be instructed on this updated procedure to ensure compliance with 2 CFR 200 documentation standards. FH will perform periodic reviews to confirm consistent application of the revised process. Responsible: GSC Grants Finance Officer Due Date: 02/28/2026
View Audit 387560
Finding 1173954 (2025-002)
Material Weakness 2025
Bates College
ME
Matching / Level of Effort / Earmarking Student Financial Aid Eligibility
Finding 2025-002 - Eligibility - Student Financial Assistance Cluster, ALN 84.268, June 30, 2025 Award Year, U.S. Department of Education Condition Calculation of Benefits: In addition to the requirements and limits, awards must be coordinated among the various programs and with other federal and no...
Finding 2025-002 - Eligibility - Student Financial Assistance Cluster, ALN 84.268, June 30, 2025 Award Year, U.S. Department of Education Condition Calculation of Benefits: In addition to the requirements and limits, awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). The determination of need-based SFA award amounts is based on financial need. Non-need based SFA awards are not limited to financial need but cannot exceed the student’s COA. To determine non-need based SFA awards (unsubsidized aid) one would use the following formula – COA minus OFA. (November 2025 OMB Compliance Supplement pages 5-3-10 and 5-3-11) Out of forty students tested, two students were under-awarded both Subsidized and Unsubsidized loans and one student was under-awarded Subsidized loans. This was not a statistic. Corrective Actions To address the finding, loan certification procedures have been revised to include step-by-step procedures for determining loan eligibility. A standardized template has been created for calculating subsidized and unsubsidized loan amounts, with clear instructions that subsidized loans must be maximized before awarding unsubsidized loans. Comprehensive training on the calculation of loan eligibility has been provided for new staff, including subsidized versus unsubsidized loan rules, and one-on-one coaching is being provided for staff members with knowledge gaps. A quality assurance program that includes a random sample review of loan awards will be performed between the fall and winter semesters to identify errors and ensure that loans are being certified in accordance with applicable rules and limits. Reviews and findings will be documented so that errors can be addressed immediately. Responsible Official: Wendy G. Glass, Director of Student Financial Services Completion Date: December 4, 2025
View Audit 387552
Finding 1173953 (2025-001)
Material Weakness 2025
Bates College
ME
Student Financial Aid
Finding 2025-001 - Reporting: Financial Reporting - Student Financial Assistance Cluster, ALN 84.268 and 84.063, June 30, 2025 Award Year, U.S. Department of Education Condition Institutions submit Direct Loan, Pell Grant, and TEACH Grant origination records to the Common Origination and Disbursemen...
Finding 2025-001 - Reporting: Financial Reporting - Student Financial Assistance Cluster, ALN 84.268 and 84.063, June 30, 2025 Award Year, U.S. Department of Education Condition Institutions submit Direct Loan, Pell Grant, and TEACH Grant origination records to the Common Origination and Disbursement (“COD”) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes the disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. (November 2025 OMB Compliance Supplement page 5- 3-24) Three out of forty disbursements tested were reported late to COD, one was 3 days late and two were 23 days late. Corrective Actions To address the finding, procedures have been revised to specifically address COD reporting during school closures, emergency situations, and off-cycle disbursements. As part of this effort, key dates have been noted on a shared calendar for staff to reference to ensure timely reporting under various circumstances. To maintain compliance going forward, staff will perform weekly reviews of all disbursements to ensure timely COD reporting, and monthly audits of COD reporting will be conducted to identify late submissions and address issues promptly. Responsible Official: Wendy G. Glass, Director of Student Financial Services Completion Date: December 4, 2025
View Audit 387552
Finding 1173951 (2025-001)
Material Weakness 2025
Hope House, Inc.
MO
Allowable Costs / Cost Principles Internal Control / Segregation of Duties Significant Deficiency § 200.306
Matching – Assistance Listing No. 93.671 Recommendation: We recommend the Organization enhance its internal controls over the review of the payroll allocation to ensure matching contributions are accurately calculated and supported. Explanation of disagreement with audit finding: There is no disagre...
Matching – Assistance Listing No. 93.671 Recommendation: We recommend the Organization enhance its internal controls over the review of the payroll allocation to ensure matching contributions are accurately calculated and supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Senior Accountant or Director of Grants and Compliance will conduct the initial review to ensure that match costs are allowable, properly supported, and accurately calculated. The Chief Financial Officer will perform a secondary review and approval to validate completion of the initial review and confirm that reported match amounts reconcile to supporting documentation. Evidence of review will be documented through dated signatures or electronic approval within the grant billing file. Name of the contact person responsible for corrective action: Ashley Freivogel Planned completion date for corrective action plan: September 30, 2026
View Audit 387549
Finding 1173946 (2025-001)
Material Weakness 2025
Noblesville Schools
IN
Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303
Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.027X Federal Award Year (or Other Identifying Numbers): 22611-023-PN01, 22611-023-ARP, 23611-023-PN01 , 24611-...
Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.027X Federal Award Year (or Other Identifying Numbers): 22611-023-PN01, 22611-023-ARP, 23611-023-PN01 , 24611-023- PN01 , 25611-023-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Suspension and Debarment Audit Findings: Significant Deficiency Condition: An effective system of internal controls was not in place at the School Corporation to ensure the HamiltonBoone- Madison Special Education Cooperative's compliance with applicable requirements related to the Special Education Cluster (IDEA), specifically with respect to Suspension and Debarment requirements. No instances of noncompliance (entering a contract with a vendor that was suspended or debarred) were identified in the transactions selected for testing. The matter represents a deficiency in internal controls over the Suspension and Debarment process, rather than identified noncompliance with program requirements. Context: Suspension and Debarment As part of its internal control procedures, the Cooperative utilizes the System for Award Management (SAM.gov) to verify the eligibility status of vendors prior to engaging in financial transactions. This verification process is designed to ensure that vendors are not suspended, debarred, or otherwise excluded from participation in federal programs, in accordance with applicable procurement regulations. Three covered transactions that equaled or exceeded $25,000 were identified. Of the three transactions, all were selected for testing, totaling $141,578. The Cooperative did not verify the vendors' suspension and debarment status prior to payment for two of the three covered transactions. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will enhance oversight of the Hamilton-Boone-Madison Special Education Cooperative's procurement process to ensure all applicable procurement steps, including suspension and debarment checks, are completed and follow federal regulations for the program, prior to entering into a contract with the respective vendor. Responsible Party and Timeline for Completion: David Hortemiller, CFO and Susan Wilson, Director of Finance met with Steven Wornhoff, Director of HBM Cooperative and Kim Kuersteiner, HBM Technology Manager to establish a process to review all vendors for suspension and debarment. Training was provided in regard to the Sam.gov website. Since August 2024, the Hamilton-Boone-Madison Special Services Cooperative (the Cooperative) has used the System for Awards Management (SAM.gov) to verify the eligibility status of vendors prior to engaging in financial transactions. The Cooperative will continue to use this process for any transaction equaling or exceeding $25,000. Documentation of the verification process will be retained by the Cooperative.
View Audit 387537
Finding 1173850 (2025-002)
Material Weakness 2025
Carleton College
MN
Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties
Title: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review all R2T4 calculations to confirm accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken...
Title: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review all R2T4 calculations to confirm accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We added an additional validation step in our process to confirm that the original charge amounts are accurate. Name(s) of the contact person(s) responsible for corrective action: Danielle Hayden Planned completion date for corrective action plan: October 1, 2025
View Audit 387518
Finding 1173845 (2025-001)
Material Weakness 2025
Carleton College
MN
Student Financial Aid Reporting Significant Deficiency
Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disag...
Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We identified that the issue is related to transferring data between NSC (where we report enrollment for all students) and NSLDS (where federal aid recipients are monitored). To bridge this gap, we have provided a member of the Registrar’s Office with access to NSLDS to audit the data submitted to NSC and the transfer of information. Additionally, we are conducting research to determine if there are alternative reporting options that may provide greater accuracy. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: March 2026
View Audit 387518
Finding 1173840 (2025-003)
Material Weakness 2025
St James R-I School District
MO
§ 200.514
Views of Responsible Officials and Planned Corrective Action: Management acknowledges the material weakness identified regarding the lack of sufficient appropriate audit evidence to support compliance with federal program requirements for the Special Education Cluster (IDEA) and the Child Nutrition ...
Views of Responsible Officials and Planned Corrective Action: Management acknowledges the material weakness identified regarding the lack of sufficient appropriate audit evidence to support compliance with federal program requirements for the Special Education Cluster (IDEA) and the Child Nutrition Cluster. We recognize that the inability to provide certain customary accounting records and supporting documentation resulted in a disclaimer of opinion on the District’s compliance. We take this finding seriously and are committed to strengthening our internal controls and recordkeeping practices. To address this issue, management has implemented the following corrective actions: 1. Enhanced Recordkeeping Procedures: We have established and communicated clear procedures to ensure that all financial transactions and program activities are properly documented and that supporting records are maintained in accordance with federal and state requirements. Management is committed to maintaining the integrity of our financial reporting and compliance with all applicable federal program requirements. We believe these corrective actions will address the material weakness and prevent recurrence in future periods. 2. Staff Training: Relevant staff have received additional training on documentation standards and compliance requirements for federal programs to ensure understanding and consistent application of these procedures. 3. Periodic Internal Reviews: Management will conduct periodic internal reviews to verify that records are being maintained appropriately and are readily available for audit purposes. 4. Ongoing Monitoring: We will continue to monitor compliance with these procedures and make improvements as necessary to ensure that all required documentation is available for future audits.
View Audit 387513
Finding 1173833 (2025-003)
Material Weakness 2025
Martins Ferry City School District
OH
Allowable Costs / Cost Principles § 200.430
2025-003 The District will implement procedures to ensure all expenditures are for allowable purposes prior to disbursement. 6/30/2026 Holly Skulich, Treasurer
2025-003 The District will implement procedures to ensure all expenditures are for allowable purposes prior to disbursement. 6/30/2026 Holly Skulich, Treasurer
View Audit 387512
Finding 1173824 (2025-002)
Material Weakness 2025
Independent School District No. 199
MN
Internal Control / Segregation of Duties Cash Management School Nutrition Programs
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.559 2025-002 Internal Control Over Compliance with Allowable Activities Requirements Finding Su...
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553, 10.555, AND 10.559 2025-002 Internal Control Over Compliance with Allowable Activities Requirements Finding Summary 7 CFR § 210.8 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program allowable activities, including meal count requirements applicable to child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls over meals counts submitted for afterschool snack reimbursement claims. For two months tested, the District’s internal tracking records for afterschool snacks served did not agree to the meal counts submitted to the Minnesota Department of Education (MDE) for reimbursement. In both cases, the internal records had been altered after the meal counts submissions to the MDE had been completed to add eligible afterschool snacks that had been missed. This resulted in underclaimed meals for eligible snacks served. Corrective Action Plan Actions Planned – The District will review and update its policies and procedures relating to eligible afterschool snack meal tracking and reimbursement submission for its child nutrition cluster federal program to ensure compliance with the Uniform Guidance in the future. Official Responsible – The District’s Director of Food Service, Dorie Pavel. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Director of Food Service, Dorie Pavel, will assure appropriate internal controls and procedures are updated and in place for afterschool snack meal tracking and reimbursement submission to ensure the accuracy of District claims for eligible meal reimbursements in the future.
View Audit 387498
Finding 1173821 (2025-001)
Material Weakness 2025
Central Columbia School District
PA
Cash Management Reporting School Nutrition Programs
Corrective Action Plan The Central Columbia School District respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the Single Audit Report Year Ended June 30, 2025 included in the schedule of findings and questioned costs are discussed below. Fi...
Corrective Action Plan The Central Columbia School District respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the Single Audit Report Year Ended June 30, 2025 included in the schedule of findings and questioned costs are discussed below. Finding 2025-001: Reporting Contact Person: Steven Dolak, Business Administrator Recommendation: The District should revise procedures to ensure the data entered into the claim for reimbursement is reviewed for accuracy prior to the report being submitted. Evidence of the approval of submission should be documented in writing, such as with an initial, to demonstrate the review of the information has been performed. Action: The Business Administrator will prepare the reports for submission. Prior to submitting the report through the reimbursement system, a second individual will review the information entered. Upon satisfactory completion of the review, the second individual will acknowledge review by initialing and dating the document(s). Date for Completion: This procedure will be implemented at the beginning of the 2025-26 school year.
View Audit 387494
Finding 1173816 (2025-003)
Material Weakness 2025
Rockdale Independent School District
TX
Corrective Action Planned: Cause: A staffing change occurred between the 2023-24 to 2024-25 school years when a teacher coded 100% to Special Education retires and was not replaced. Corrective Action:  When a Special Education staff position is vacated, the Business Office will review MOE impact. ...
Corrective Action Planned: Cause: A staffing change occurred between the 2023-24 to 2024-25 school years when a teacher coded 100% to Special Education retires and was not replaced. Corrective Action:  When a Special Education staff position is vacated, the Business Office will review MOE impact.  The district will identify allowable expenditures to be coded to IDEA-B if staffing changes.  The district plans to appeal in the Spring for an exception for the teacher that was not replaced. Anticipated Completion Date: Spring 2026 Contact Person(s): Rebecca King, Business Manager
View Audit 387478
Finding 1173814 (2025-002)
Material Weakness 2025
Herkimer Housing Authority
NY
HUD Housing Programs § 200.303
Name of Auditee: Herkimer Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: June 30, 2025 CAP prepared by; Richard Dowe, Executive Director (A) Current Finding on the Schedule of Findings and Questioned Costs (2) Finding 2025-002 (a) Comments on the finding an...
Name of Auditee: Herkimer Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: June 30, 2025 CAP prepared by; Richard Dowe, Executive Director (A) Current Finding on the Schedule of Findings and Questioned Costs (2) Finding 2025-002 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action. (b) Action taken - The Authority will strengthen internal controls and training of staff to ensure compliance deadlines are met and immediately obtain the missing leases. (c) Planned implementation date - The Authority expects to complete the corrective actions by June 30, 2026.
View Audit 387466
Finding 1173803 (2025-002)
Material Weakness 2025
Western Boone County Community School Corporation
IN
School Nutrition Programs Internal Control / Segregation of Duties § 200.303
FINDING 2025-002 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Ide...
FINDING 2025-002 Information on the federal program: Subject: Child Nutrition Cluster - Reporting Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirement. Context: During the testing of claim reimbursements, we noted that monthly reimbursements are prepared and reconciled by Food Service Director. The reimbursements are reviewed informally by the Treasurer but this review is not formally documented and therefore, auditable evidence of the review was not available. The lack of formal, documented review existed throughout the audit period. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Management will implement a formal, documented review of the monthly reimbursement claims submitted by the Food Service Director prior to submission to the State. Responsible Party and Timeline for Completion: The Food Service Director will prepare and reconcile monthly claims. The FSD will forward to the cafeteria supervisor for review. Both the FSD and cafeteria supervisor will sign off before being submitted to the state for reimbursement. This measure has already been implemented beginning with the November 2025 claim submitted in January 2026.
View Audit 387461
Finding 1173799 (2025-001)
Material Weakness 2025
College of Idaho
ID
Special Tests & Provisions Student Financial Aid Material Weakness
Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit find...
Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit finding and is committed to strengthening internal controls over enrollment status reporting to ensure continued compliance with federal requirements. During management’s review of the audit results, the Registrar’s Office was unable to reproduce the specific enrollment status reporting errors identified during audit testing and could not definitively determine how the errors occurred. Notwithstanding this, the College recognizes that weaknesses in monitoring and documentation contributed to the inability to detect and prevent the reporting discrepancies in a timely manner. Accordingly, management has developed the following corrective actions. The College will enhance coordination among Registrar’s Office, Financial Aid, and Information Technology to ensure enrollment status changes including graduation, withdrawal, and changes in enrollment status are identified promptly and reported accurately to the National Student Loan Data System (NSLDS) within the required 60-day timeframe in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. For over 20 years, the College of Idaho has been a member of the National Student Clearinghouse (NSCH). One of the many advantages of membership to the NSCH is that the NSCH serves as a conduit to NSLDS and sends reports to the NSLDS for the college. Ellucian Colleague has written a series of reports that result in a .txt file that is uploaded to NSCH who in turn uploads to NSLDS. The College of Idaho submits regular transmissions to NSCH so that the 60-day timeframe is met. Corrective Action Plan: • Process Review and Clarification of Roles The Registrar’s Office will review and formalize procedures related to enrollment status determination and reporting. Roles and responsibilities for identifying enrollment changes, preparing NSLDS files, and submitting updates will be clearly documented to ensure accountability and continuity. • Student Information System Reporting Improvements The College will refine and validate student information system (SIS) reports used for enrollment reporting to ensure accurate capture of enrollment status changes and effective dates. Reports will be reviewed regularly to confirm continued reliability. • Internal Review and Oversight Controls Prior to submission to NSCH, enrollment status reports will be reviewed by the Registrar supervisory personnel to confirm accuracy and completeness. Evidence of review will be retained in accordance with institutional record retention practices. • Established Reporting Timeline A recurring reporting calendar will be implemented to ensure enrollment status updates are submitted within required federal timeframes. Backup personnel will be identified to support continuity during staff absences. • Training and Ongoing Communication Staff involved in enrollment reporting will receive periodic training on federal enrollment reporting requirements and institutional procedures. Regular communication between Enrollment Services and Financial Aid will support timely identification and resolution of discrepancies. Responsible Official(s): Mark Heidrich (Registrar/Associate Vice President for Institutional Effectiveness), in coordination with Stephanie House (Director of Financial Aid) and Imad Sweidan (Chief Information Officer), as appropriate. Anticipated Completion Date: June 30, 2026 Current Status: Corrective action is in progress. Management expects these actions to be fully implemented prior to the next audit period and believes the strengthened controls will prevent recurrence of this finding.
View Audit 387449
Finding 1173783 (2025-005)
Material Weakness 2025
Culver-Stockton College
MO
Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid
The College will diligently check each financial aid disbursement roster to review and refund any student account credit balances generated from a disbursement. This process is to maintain compliance with this requirement. The College will also create an Infomaker report each week to identify any cr...
The College will diligently check each financial aid disbursement roster to review and refund any student account credit balances generated from a disbursement. This process is to maintain compliance with this requirement. The College will also create an Infomaker report each week to identify any credit balances that need refunded.
View Audit 387430
Finding 1173778 (2025-004)
Material Weakness 2025
Culver-Stockton College
MO
Student Financial Aid
All Registrar staff were re-trained on the proper procedures as they relate to updating enrollment status for students. A double check system was put into place to have two members of the Registrar staff check each student to ensure proper enrollment status accuracy is achieved.
All Registrar staff were re-trained on the proper procedures as they relate to updating enrollment status for students. A double check system was put into place to have two members of the Registrar staff check each student to ensure proper enrollment status accuracy is achieved.
View Audit 387430
Finding 1173773 (2025-003)
Material Weakness 2025
Culver-Stockton College
MO
Student Financial Aid Subrecipient Monitoring Reporting
Financial Aid personnel responsible for loan disbursements will review both COD and Pfaid records to ensure they align with the corresponding student account disbursement information. Additionally, the office will conduct monthly COD mismatch reviews to determine whether maintenance files need to be...
Financial Aid personnel responsible for loan disbursements will review both COD and Pfaid records to ensure they align with the corresponding student account disbursement information. Additionally, the office will conduct monthly COD mismatch reviews to determine whether maintenance files need to be submitted. This process will help ensure continued accuracy and compliance in federal reporting.
View Audit 387430
Finding 1173768 (2025-002)
Material Weakness 2025
Culver-Stockton College
MO
Subrecipient Monitoring Eligibility
All Financial Aid personnel were re-trained on the SEOG minimum and maximum award parameters. The office will conduct quarterly reviews of awards to ensure compliance and verify that no students are incorrectly awarded.
All Financial Aid personnel were re-trained on the SEOG minimum and maximum award parameters. The office will conduct quarterly reviews of awards to ensure compliance and verify that no students are incorrectly awarded.
View Audit 387430
Finding 1173763 (2025-002)
Material Weakness 2025
New American Association of Massachusetts, Inc.
MA
Subrecipient Monitoring Reporting § 200.512
The Organization will reinforce its filing control environment by implementing a documented reporting calendar and assigning responsibility to finance leadership for reviewing and certifying timely submission of future single audit reporting packages.
The Organization will reinforce its filing control environment by implementing a documented reporting calendar and assigning responsibility to finance leadership for reviewing and certifying timely submission of future single audit reporting packages.
View Audit 387428
Finding 1173712 (2025-001)
Material Weakness 2025
Bellarmine University
KY
Student Financial Aid Internal Control / Segregation of Duties
Views of responsible officials and planned corrective actions: The University does not agree with the conclusion of this finding. The University determines a student’s withdrawal date based on the student’s official notification or, where applicable, the date of determination when a student ceases a...
Views of responsible officials and planned corrective actions: The University does not agree with the conclusion of this finding. The University determines a student’s withdrawal date based on the student’s official notification or, where applicable, the date of determination when a student ceases attendance without providing official notice. Based on the University’s review of institutional records and applicable regulatory guidance in effect during the audit period, management believes the withdrawal processing methodology applied was reasonable and consistent with institutional procedures and Title IV requirements. For three of the four students identified, the data reported to NSLDS reflected the institution’s determination date rather than the withdrawal date. Management maintains that this approach was the result of interpretation applied to specific withdrawal circumstances and did not materially misrepresent the students’ enrollment status or Title IV outcomes. For the remaining student, management agrees that a clerical data-entry error resulted in an incorrect withdrawal date being reported to NSLDS; however, this instance was isolated and does not represent a systemic control deficiency. While the University does not agree that the instances cited constitute noncompliance, management acknowledges the auditor’s concern regarding consistency in distinguishing withdrawal dates from determination dates for NSLDS reporting purposes. In response, and without conceding noncompliance, the University will enhance its policies, procedures, and internal controls to promote consistent application of regulatory definitions and reduce the risk of future discrepancies.
View Audit 387426
Finding 1173699 (2025-001)
Material Weakness 2025
Hope's Door, INC
NY
Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.430 § 200.431
Management engaged an external HR consultant to assist with revising the Accounting Policy Manual to formally document written policies and procedures related to compensation and fringe benefits. Draft policies have been developed and are currently under management review for accuracy and alignment ...
Management engaged an external HR consultant to assist with revising the Accounting Policy Manual to formally document written policies and procedures related to compensation and fringe benefits. Draft policies have been developed and are currently under management review for accuracy and alignment with existing practices. The finalized policies will be presented for Board approval and implemented by March 18, 2026, and responsibility for ongoing monitoring and periodic review has been assigned to the Chief Financial Officer and Director of Administration to ensure continued compliance. Training will be provided to applicable staff, and compliance with the updated policies will be incorporated into management’s periodic internal reviews.
View Audit 387413
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