Corrective Action Plans

Finding 1227514 (2025-003)

Material Weakness 2025

Chrysalis Center

CA

Allowable Costs / Cost Principles Subrecipient Monitoring Internal Control / Segregation of Duties § 200.302 § 200.403 § 200.430

Description: During our testing of payments charged to the federal major program, we noted that employee timesheets lacked evidence of review and approval. Certain employees charged to the grant did not prepare timesheets and a separate tracking system was used. Federal regulations require that expe...

Description: During our testing of payments charged to the federal major program, we noted that employee timesheets lacked evidence of review and approval. Certain employees charged to the grant did not prepare timesheets and a separate tracking system was used. Federal regulations require that expenditures charged to Federal awards be properly reviewed, approved, and documented to ensure allowability and compliance with grant terms. Recommendation: Review the requirements of CFR 200.430 and ensure that current processes, whether digital or hard-copy driven, are consistent with the requirements of the Uniform Guidance. In addition, management should consider adding additional staff to its accounting and/or grants management team. Responsible Contact: Laura McQuay, Vice President & Chief Financial Officer Corrective Action Planned: The Organization has made significant progress in strengthening its timekeeping processes, as described in finding number 2025-002. This program ended in March 2025, and therefore management was unable to complete full remediation of the processes before completion of the grant. Anticipated Completion Date: December 31, 2027

View Audit 409537

Finding 1227513 (2025-002)

Material Weakness 2025

Chrysalis Center

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.403 § 200.430

Description: During our testing of payments charged to the federal major program, we noted that employee timesheets lacked evidence of review and approval. Federal regulations require that expenditures charged to Federal awards be properly reviewed, approved, and documented to ensure allowability an...

Description: During our testing of payments charged to the federal major program, we noted that employee timesheets lacked evidence of review and approval. Federal regulations require that expenditures charged to Federal awards be properly reviewed, approved, and documented to ensure allowability and compliance with grant terms. Recommendation: Review the requirements of CFR 200.430 and ensure that current processes, whether digital or hard-copy driven, are consistent with the requirements of the Uniform Guidance. In addition, management should consider adding additional resources to its payroll approval process. Responsible Contact: Laura McQuay, Vice President & Chief Financial Officer Corrective Action Planned: Management: The Organization has made significant progress in strengthening its timekeeping processes over the past 18 months. In 2025, the agency transitioned approximately 800 weekly transitional workers from a paper-based timekeeping process to an electronic timekeeping system. In 2026, the agency implemented an upgraded workforce management system that provides enhanced scheduling, monitoring, and supervisory oversight capabilities. Management recognizes the importance of full compliance with timekeeping requirements. Given the size and complexity of the Organization's operations, including a large workforce distributed across multiple programs and locations, implementation of system and process changes requires substantial planning, training, and operational coordination. To support these efforts, the agency has dedicated additional resources and established clearly defined responsibilities to drive implementation and oversight. The agency continues to refine procedures, provide training, and leverage system capabilities to strengthen controls and ensure consistent compliance across the Organization. Anticipated Completion Date: December 31, 2027

View Audit 409537

Finding 1227489 (2025-001)

Material Weakness 2025

Kids in Crisis Inc.

CT

Cash Management

Management concurs with the finding and notes that the Organization has increased the controls to ensure that appropriate review of payroll expenses occurs. The Organization never benefited from the erroneous charge to the grant as the overpayment issue was resolved and adjusted prior to the final a...

Management concurs with the finding and notes that the Organization has increased the controls to ensure that appropriate review of payroll expenses occurs. The Organization never benefited from the erroneous charge to the grant as the overpayment issue was resolved and adjusted prior to the final accounting to the Department of Health and Human Services. The final drawdown request for the grant year also reflected the correct expenditures after removal of the overpayment.

View Audit 409528

Finding 1227488 (2025-001)

Material Weakness 2025

Talmud Torah Darkei Avos - Monsey

NY

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.512

The Organization should implement an effective monitoring system to keep track of the compliance calendar, which includes financial reporting deadlines, and automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Orga...

The Organization should implement an effective monitoring system to keep track of the compliance calendar, which includes financial reporting deadlines, and 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. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. Additionally, the Organization should implement a system that will file documents in an organized manner and make them easily accessible to the Organization and auditors. Furthermore, 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.

View Audit 409525

Finding 1227485 (2025-001)

Material Weakness 2025

Wellpinit School District No. 49

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Corrective action the auditee plans to take in response to the finding: Wellpinit School District acknowledges the audit finding regarding the absence of a written methodology for allocating state and local funding and staffing to the high school grade span in compliance with Title I, Part A supplem...

Corrective action the auditee plans to take in response to the finding: Wellpinit School District acknowledges the audit finding regarding the absence of a written methodology for allocating state and local funding and staffing to the high school grade span in compliance with Title I, Part A supplement not supplant requirements. At the time of the audit, the District operated under a partial exemption and believed it was appropriately following guidance from the Office of Superintendent of Public Instruction (OSPI). However, the District did not fully understand that a written methodology was still required for the non-exempt high school grade span. While allocation decisions were made using consistent practices, they were not formally documented in a manner that demonstrates compliance with federal requirements. To address this finding, the District is implementing the following corrective actions: 1. Development and Adoption of a Written Methodology The District is developing a formal, written methodology for allocating state and local funds and staffing to its high school grade span. The methodology will: • Allocate resources based on objective, neutral criteria such as student enrollment, program offerings, and staffing ratios • Ensure each high school receives the state and local resources it would otherwise receive if it were not receiving Title I, Part A funds • Clearly document that Title I status is not considered in the allocation process This methodology will be formally adopted and applied beginning with the next annual budget development cycle. 2. Strengthening Internal Controls The District is establishing internal control procedures to ensure compliance with supplement not supplant requirements, including: • Annual documentation of allocation formulas and staffing decisions • Review and approval of allocations by the Business Manager prior to budget adoption • Maintenance of supporting documentation demonstrating consistent application of the methodology 3. Training and Capacity Building District leadership and business office staff will participate in training on Title I, Part A fiscal requirements, including supplement not supplant provisions and documentation standards, utilizing guidance provided by OSPI and federal program resources. 4. Ongoing Monitoring and Oversight The Business Manager will be responsible for monitoring implementation and ensuring compliance by: • Conducting annual reviews of allocation practices • Verifying that documentation is complete and audit-ready • Updating the methodology as needed to reflect changes in enrollment, programming, or regulatory guidance 5. Implementation Timeline The written methodology and internal control procedures will be finalized prior to the development of the upcoming fiscal year budget and fully implemented for that cycle. Documentation supporting compliance will be retained annually.

View Audit 409521

Finding 1227484 (2025-005)

Material Weakness 2025

Warren County, North Carolina

NC

Eligibility Material Weakness Equipment & Real Property Management

Name of contact person: Renae Alston Corrective Action: The County will continue to train employees on a monthly basis and as needed when new and updated policies are received. Supervisors and lead workers will continue to conduct second party reviews and utilizing any findings to aid in training st...

Name of contact person: Renae Alston Corrective Action: The County will continue to train employees on a monthly basis and as needed when new and updated policies are received. Supervisors and lead workers will continue to conduct second party reviews and utilizing any findings to aid in training staff on any necessary policy information. The department will continue to implement changes as necessary to achieve the overall improvement of eligibility determinations. Proposed Completion Date: June 30, 2026

View Audit 409520

Finding 1227483 (2025-005)

Material Weakness 2025

Art Academy of Cincinnati

OH

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

Condition: During testing of Student Financial Assistance (SFA) disbursements, the Institution did not maintain documentation demonstrating that required Title IV disbursement notifications were provided to students. For the students selected for testing, the Institution could not provide evidence t...

Condition: During testing of Student Financial Assistance (SFA) disbursements, the Institution did not maintain documentation demonstrating that required Title IV disbursement notifications were provided to students. For the students selected for testing, the Institution could not provide evidence that students were notified of the amount and type of Title IV funds they were scheduled to receive, nor the timing and method of the disbursements, as required by federal regulations and the Federal Student Aid (FSA) Handbook. As a result, we were unable to verify that the required notifications were issued. Views of Responsible Officials: AAC officials concur with the audit finding and acknowledge that the Institution did not maintain sufficient documentation to demonstrate that required Title IV disbursement notifications were provided to students. Although it was the AAC's practice to communicate financial aid awards and disbursement information to students, management recognizes that documentation supporting compliance with the federal notification requirements was not consistently retained. Corrective Action Plan: The AAC has reviewed its Title IV disbursement notification process and is implementing procedures to ensure that all required notifications are generated, issued to students prior to disbursement, and retained in accordance with federal regulations and institutional record retention requirements. The AAC will also establish a standardized process for documenting the date, method, and content of each notification. Additionally, financial aid staff will receive refresher training on Title IV disbursement notification requirements, and supervisory reviews will be incorporated into the disbursement process to verify that required notifications have been issued and properly documented before funds are disbursed. Management believes these enhanced controls will strengthen compliance with federal requirements and ensure adequate documentation is maintained for future audits. Responsible Party: Executive Director of Administration and Finance Completion Date: The corrective action will be developed and implemented during the 2025-2026 fiscal year and will continue to be implemented in the 2026-2027 fiscal year.

View Audit 409518

Finding 1227482 (2025-004)

Material Weakness 2025

Art Academy of Cincinnati

OH

Student Financial Aid Eligibility Significant Deficiency

Condition: During testing of eligibility, 1 out of 40 students were not awarded their maximum subsidized loan amounts they should have been awarded. Views of Responsible Officials: AAC officials concur with the audit finding and acknowledge that one student did not receive the maximum subsidized loa...

Condition: During testing of eligibility, 1 out of 40 students were not awarded their maximum subsidized loan amounts they should have been awarded. Views of Responsible Officials: AAC officials concur with the audit finding and acknowledge that one student did not receive the maximum subsidized loan amount for which the student was eligible. The error resulted from an oversight during the financial aid packaging process and was not identified through the Academy's review procedures. Upon notification of the finding, the AAC reviewed the student's eligibility, recalculated the award, and initiated the appropriate corrective action to ensure the student received the correct subsidized loan amount, if still permissible under federal regulations. Management also reviewed its loan awarding procedures to identify opportunities to strengthen internal controls. Corrective Action Plan: To prevent similar occurrences, the AAC will implement an additional supervisory review of loan awards before disbursement, utilize system-generated eligibility reports to verify that students are awarded the maximum subsidized loan amount for which they qualify, and provide refresher training to financial aid staff on federal Direct Loan awarding requirements. Management believes these enhancements will improve the accuracy of loan packaging and reduce the likelihood of similar errors in future award years. Responsible Party: Executive Director of Administration and Finance Completion Date: The corrective action will be developed and implemented during the 2025-2026 fiscal year and will continue to be implemented in the 2026-2027 fiscal year.

View Audit 409518

Finding 1227481 (2025-003)

Material Weakness 2025

Art Academy of Cincinnati

OH

Student Financial Aid Subrecipient Monitoring Eligibility

Condition: During testing of Student Financial Assistance (SFA) eligibility and awarding, the Institution did not consistently apply federal requirements related to Cost of Attendance (COA), financial need determination, and award packaging. Specifically: • One student was awarded aid in excess of t...

Condition: During testing of Student Financial Assistance (SFA) eligibility and awarding, the Institution did not consistently apply federal requirements related to Cost of Attendance (COA), financial need determination, and award packaging. Specifically: • One student was awarded aid in excess of the federally allowable COA. • One student’s COA was overstated, which resulted in the student being potentially overawarded. • Six student’s were awarded the incorrect COA based on the grade level reported on the Institutional Student Information Record (ISIR). However, there is no code for year 4 on the ISIR, which resulted in the students receiving year 3 COA. • Two students received aid in excess of their calculated financial need, and the Institution did not maintain documentation supporting the adjustments or exceptions. • One student was enrolled at three quarter time during the fall semester and full time during the spring semester; however, the student received three quarter time Pell Grant disbursements for both semesters, resulting in an underpayment for the spring term and inaccurate Pell reporting. These errors demonstrate inconsistent application of federal awarding rules and insufficient review of eligibility and enrollment status changes. Views of Responsible Officials: AAC officials concur with the audit finding and acknowledge that the identified errors resulted from inconsistencies in the application of federal Student Financial Assistance awarding requirements and insufficient review of student eligibility, Cost of Attendance calculations, financial need determinations, and enrollment status changes. Management has reviewed each of the identified student files and is taking appropriate corrective action, including recalculating awards, making any required adjustments or corrections, and updating reporting where necessary. The AAC has also evaluated the circumstances surrounding the use of Cost of Attendance budgets, including the limitation of the Institutional Student Information Record (ISIR), which does not include a separate code for fourth-year undergraduate students. Procedures are being revised to ensure that staff apply the appropriate institutional Cost of Attendance budget regardless of the ISIR grade level code and that any manual adjustments are adequately documented. Corrective Action Plan: To strengthen internal controls, the AAC will implement enhanced review procedures for financial aid packaging, Cost of Attendance determinations, financial need calculations, enrollment status changes, and Pell Grant disbursements prior to disbursement. In addition, financial aid personnel will receive refresher training on federal awarding requirements, documentation standards, and exception processing. Management believes these corrective actions will improve compliance with federal regulations and reduce the likelihood of similar errors in future award years. Responsible Party: Executive Director of Administration and Finance Completion Date: The corrective action will be developed and implemented during the 2025-2026 fiscal year and will continue to be implemented in the 2026-2027 fiscal year.

View Audit 409518

Finding 1227470 (2025-003)

Material Weakness 2025

CITY OF TWO RIVERS

WI

Procurement, Suspension & Debarment § 200.320

2025-003 Suspension and Debarment – Assistance Listing Number 66.468 Recommendation: We recommend the City evaluate its existing policies and procedures to determine where additional enhancements should be made or new policies created to ensure vendors are not suspended or debarred. Explanation of d...

2025-003 Suspension and Debarment – Assistance Listing Number 66.468 Recommendation: We recommend the City evaluate its existing policies and procedures to determine where additional enhancements should be made or new policies created to ensure vendors are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned in response to finding: The City immediately began reviewing its policy related to suspension and debarment and is reviewing procedures to ensure that requirements are consistently followed in future years. Name(s) of the contact person(s) responsible for corrective action: Kassandra Paider, Finance Director Planned completion date for corrective action plan: The City immediately began evaluating procedures and will implement as soon as possible. If the granting agencies have questions regarding this schedule, please call Kassandra Paider, Finance Director, at (920) 793-7274.

View Audit 409505

Finding 1227468 (2025-004)

Material Weakness 2025

City of Albany, Georgia

GA

Reporting Internal Control / Segregation of Duties

Management will implement a process to ensure expenditures/expenses and related balances are properly stated in a timely manner.

View Audit 409493

Finding 1227463 (2025-003)

Material Weakness 2025

City of Albany, Georgia

GA

Reporting Internal Control / Segregation of Duties

Management will implement a process to ensure revenues and related balances are properly stated in a timely manner.

View Audit 409493

Finding 1227459 (2025-007)

Material Weakness 2025

The Institute of World Politics

DC

Internal Control / Segregation of Duties Material Weakness Reporting § 200.512

Identifying Number: 2025-007 Data Collection Form (DCF) Late Filing Finding: The Institute did not submit the fiscal year 2024 Data Collection Form (DCF) and related reporting package to the Federal Audit Clearinghouse within the required time frame. Corrective Actions Taken or Planned: Management a...

Identifying Number: 2025-007 Data Collection Form (DCF) Late Filing Finding: The Institute did not submit the fiscal year 2024 Data Collection Form (DCF) and related reporting package to the Federal Audit Clearinghouse within the required time frame. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with Uniform Guidance reporting requirements: 1. Establish Formal Single Audit Reporting Procedures • The Institute will develop and maintain written procedures governing the annual Single Audit reporting process, including the preparation, review, approval, and submission of the Data Collection Form and reporting package. Procedures will clearly identify filing deadlines, responsible personnel, required approvals, and submission requirements. 2. Assign Responsibility and Accountability • Management will formally designate responsibility for coordinating the annual audit reporting process, including monitoring auditor requests, gathering required documentation, preparing the Data Collection Form, obtaining management approvals, and ensuring timely submission to the Federal Audit Clearinghouse. 3. Implement an Audit and Compliance Calendar • The Institute will establish a compliance calendar that includes all critical audit and federal reporting deadlines. Key milestones will include audit preparation activities, auditor request completion, draft financial statement review, issuance of the auditor's reports, Data Collection Form preparation, management certification, and FAC submission deadlines. 4. Strengthen Management Review Controls • Management will implement documented review procedures for the reporting package and Data Collection Form prior to submission. Review controls will verify the accuracy, completeness, and timeliness of information reported and ensure compliance with Uniform Guidance requirements. 5. Monitor Audit Requests and Submission Readiness • A tracking mechanism will be implemented to monitor the status of auditor requests, outstanding items, and reporting package preparation throughout the audit process. Periodic status meetings will be conducted to identify potential delays and ensure timely resolution of open items. 6. Maintain Evidence of Filing and Review • The Institute will retain documentation supporting preparation, review, approval, and submission of the Data Collection Form and reporting package, including filing confirmations, management approvals, submission receipts, and related correspondence. 7. Ongoing Oversight and Compliance Monitoring • Senior management will periodically review compliance with federal reporting deadlines and monitor the effectiveness of implemented controls. Any compliance issues identified will be evaluated and addressed promptly to prevent future late filings. Responsible Officials: • Executive Vice President – Ariane Sweeney • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Director of Financial Aid – Dr. Thelbert Snowden Anticipated completion date: The Institute will implement formal reporting procedures, deadline tracking tools, management review controls, and accountability measures by December 31, 2026. These procedures will be incorporated into all future Single Audit reporting cycles.

View Audit 409492

Finding 1227458 (2025-006)

Material Weakness 2025

The Institute of World Politics

DC

Subrecipient Monitoring Special Tests & Provisions Allowable Costs / Cost Principles

Identifying Number: 2025-006: Special Tests—Gramm-Leach-Bliley Act Noncompliance Finding: - The Institute does not have a written information security program that addresses the seven required elements under the Gramm-Leach-Bliley Act. Corrective Actions Taken or Planned: Management agrees with the ...

Identifying Number: 2025-006: Special Tests—Gramm-Leach-Bliley Act Noncompliance Finding: - The Institute does not have a written information security program that addresses the seven required elements under the Gramm-Leach-Bliley Act. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with the Gramm-Leach-Bliley Act and Department of Education requirements: 1. Comprehensive Review and Revision of the Written Information Security Program (WISP) • The Institute will conduct a comprehensive review of its existing Written Information Security Program (WISP) to ensure that all required elements of the GLBA Safeguards Rule are incorporated. The revised program will be approved by senior management and maintained as a formal institutional policy. 2. Formal Risk Assessment Process • The Institute will develop and implement a documented risk assessment process to identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of student information. Risk assessments will be performed periodically and updated as significant operational, or technology changes occur. 3. Implementation of Required Security Safeguards • Management will document and implement administrative, technical, and physical safeguards designed to mitigate identified risks and protect student information. Safeguards will be reviewed periodically to ensure continued effectiveness. 4. Ongoing Monitoring and Testing of Controls • The Institute will establish procedures for ongoing monitoring of information security controls, including periodic evaluations of the effectiveness of safeguards, review of security incidents, vulnerability assessments, and corrective action tracking. Results will be documented and retained for review. 5. Vendor and Service Provider Oversight • The Institute will strengthen oversight procedures for third-party service providers that have access to protected student information. Contracts and vendor management procedures will be reviewed to ensure appropriate security expectations and monitoring requirements are established. 6. Security Awareness Training • Annual information security and data privacy training will be provided to employees with access to student information. Training will address GLBA requirements, cybersecurity risks, data protection responsibilities, incident reporting procedures, and institutional security policies. 7. Designation of Responsible Personnel • Management will formally designate individual(s) responsible for coordinating and overseeing the Information Security Program, including risk assessment activities, monitoring efforts, policy updates, and compliance reporting. 8. Periodic Reporting to Senior Management and the Board • The Information Security Program Coordinator will provide periodic reports to senior management and the Board or appropriate governing committee regarding information security risks, monitoring activities, cybersecurity incidents, and the status of GLBA compliance efforts. 9. Annual Review of the Information Security Program • The Institute will conduct an annual review of its Information Security Program to ensure continued alignment with GLBA requirements, Department of Education guidance, emerging cybersecurity risks, and institutional operations. Identifying Number: 2025-006: Special Tests—Gramm-Leach-Bliley Act Noncompliance (Continued) Responsible Officials: • Executive Vice President – Ariane Sweeney • Chief Information Officer - Dean Lane • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Director of Financial Aid – Dr Thelbert Snowden Anticipated completion date: The revised Written Information Security Program, formal risk assessment process, monitoring procedures, and training program will be fully implemented by December 31, 2026. Ongoing monitoring, risk assessments, and annual reviews will continue thereafter.

View Audit 409492

Finding 1227457 (2025-005)

Material Weakness 2025

The Institute of World Politics

DC

Special Tests & Provisions Student Financial Aid Allowable Costs / Cost Principles

Identifying Number: 2025-005: Special Tests—Credit Balances Noncompliance Finding: - During our testing of the Student Financial Assistance Cluster, we identified an instance in which the Institute did not refund a Title IV credit balance within the required 14-day time frame. Corrective Actions Tak...

Identifying Number: 2025-005: Special Tests—Credit Balances Noncompliance Finding: - During our testing of the Student Financial Assistance Cluster, we identified an instance in which the Institute did not refund a Title IV credit balance within the required 14-day time frame. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with Title IV credit balance requirements: 1. Development of Written Policies and Procedures • The Institute will develop and maintain formal written policies and procedures governing the identification, tracking, review, approval, and refunding of Title IV credit balances. Procedures will clearly define responsible personnel, required timelines, supervisory review requirements, and documentation retention standards. 2. Implementation of Credit Balance Tracking Process • Management will implement a standardized tracking process to identify Title IV credit balances immediately upon creation and monitor outstanding balances through refund issuance. The tracking log will include the student name, credit balance amount, date created, refund due date, refund date, and reviewer approval. 3. Monitoring of 14-Day Compliance Requirement • The Institute will establish controls to monitor compliance with the 14-day refund requirement, including periodic review of open credit balances and automated or manual reminders for approaching refund deadlines. Any overdue items will be escalated to management for immediate resolution. 4. Documentation of Review and Approval • Evidence of review and approval will be maintained for all Title IV credit balance refunds. Documentation will include supporting reports, refund calculations, processing dates, and supervisory approval demonstrating that refunds were processed accurately and timely. 5.Monthly Management Review • Management will perform monthly reviews of all Title IV credit balances and refund activity to verify compliance with Department of Education requirements. Review procedures will include verification that all refunds were issued within required timeframes and that supporting documentation has been retained. 7. Staff Training • Financial Aid, Student Accounts, and Finance personnel involved in processing Title IV funds will receive training on federal credit balance requirements, documentation standards, and internal control responsibilities. Training will emphasize the importance of timely refund processing and compliance monitoring. 8. Ongoing Compliance Monitoring • The Institute will periodically review credit balance activity and related controls to ensure procedures are operating effectively. Any exceptions identified will be documented, investigated, and corrected timely, with results reported to senior management. Responsible Officials: • Director of Financial Aid – Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Executive Vice President – Ariane Sweeney Anticipated completion date: The Institute will fully implement credit balance tracking procedures, documentation requirements, management review controls, and staff training by December 31, 2026. Ongoing monitoring and periodic compliance reviews will continue thereafter.

View Audit 409492

Finding 1227456 (2025-004)

Material Weakness 2025

The Institute of World Politics

DC

Allowable Costs / Cost Principles Material Weakness Reporting

Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records Finding: - During our testing of the Student Financial Assistance Cluster, we noted that the Institute did not perform monthly reconciliations between its intern...

Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records Finding: - During our testing of the Student Financial Assistance Cluster, we noted that the Institute did not perform monthly reconciliations between its internal records and COD system data. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen controls over COD reporting and reconciliation activities. 1. Implementation of Monthly Reconciliation Procedures • The Institute will establish formal monthly reconciliation procedures requiring comparison of: o COD system data to internal financial aid records; o Student financial aid records to the student information system; and o COD activity to the general ledger and related financial reporting records. • The reconciliation process will be designed to verify that all aid originated, disbursed, adjusted, and reported to the Department of Education is complete and accurate. 2. Development of Written Policies and Procedures • Management will develop and maintain formal written policies and procedures governing COD reconciliation activities. These procedures will identify responsible personnel, reconciliation timelines, required documentation, review expectations, and procedures for investigating and resolving discrepancies. 3. Timely Investigation and Resolution of Differences • Any discrepancies identified during the reconciliation process will be reviewed, documented, and resolved timely. Management will maintain documentation explaining the nature of reconciling items, corrective actions taken, and the date of resolution. 4. Documentation and Retention Requirements • The Institute will maintain completed reconciliation workpapers each month, including supporting reports, reconciliations performed, explanations of variances, and documentation of corrective actions taken. Reconciliation records will be retained in accordance with federal record retention requirements. 5. Management Review and Approval • Completed reconciliations will be reviewed by supervisory personnel independent of the preparation process. Evidence of review will be documented through signed and dated approvals, electronic workflow approvals, or other documentation demonstrating that reconciliations were reviewed for completeness and accuracy. 6. Staff Training • Financial Aid and Finance personnel responsible for COD reporting and reconciliation activities will receive training regarding Department of Education requirements, reconciliation procedures, documentation standards, and internal control responsibilities. 7. Ongoing Monitoring and Compliance Oversight • Management will perform periodic monitoring of reconciliation activities to ensure procedures are operating effectively and reconciliations are completed on a timely basis. Compliance results and any significant reconciliation issues will be communicated to senior management and tracked through resolution. Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records (Continued) Responsible Officials: • Director of Financial Aid 0 Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Executive Vice President – Ariane Sweeney Anticipated completion date: Formal reconciliation procedures, documentation standards, and management review controls will be fully implemented by December 31, 2026. Monthly reconciliations will be performed and documented on an ongoing basis thereafter.

View Audit 409492

Finding 1227455 (2025-003)

Material Weakness 2025

The Institute of World Politics

DC

Student Financial Aid Reporting Special Tests & Provisions

Identifying Number: 2025-003: Special Test-National Student Loan Data System (NSLDS) Enrollment Reporting Noncompliance. Finding - Instances of noncompliance have been identified where student enrollment changes were not reported to the NSLDS within the 60-day requirement. Corrective Actions Taken o...

Identifying Number: 2025-003: Special Test-National Student Loan Data System (NSLDS) Enrollment Reporting Noncompliance. Finding - Instances of noncompliance have been identified where student enrollment changes were not reported to the NSLDS within the 60-day requirement. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions: 1. Development of Formal Written Procedures • The Institute will develop and maintain formal written policies and procedures governing NSLDS enrollment reporting. These procedures will clearly define reporting requirements, timelines, responsible personnel, supervisory review responsibilities, and documentation retention requirements to ensure compliance with Department of Education regulations. 2. Establishment of Reporting Calendars and Tracking Controls • Management will implement a formal reporting calendar and tracking mechanism to monitor NSLDS reporting deadlines. The tracking process will identify enrollment status changes requiring reporting and ensure all submissions occur within the required 60-day timeframe. 3. Enhanced Monitoring and Reconciliation Procedures • The Institute will perform periodic reconciliations between student enrollment records and NSLDS submissions to verify that all enrollment status changes have been reported accurately and timely. Any discrepancies identified during reconciliation will be investigated and corrected promptly. 4. Documented Review and Approval Process • Management will require documented evidence of supervisory review for each NSLDS submission. Review documentation will include dated approvals, electronic workflow approvals, or other evidence demonstrating that submissions were reviewed for completeness, accuracy, and timeliness prior to certification. 5. Staff Training and Cross-Training • Financial Aid personnel responsible for enrollment reporting will receive training on NSLDS reporting requirements and internal control procedures. Cross training will be implemented to ensure coverage during staff absences and reduce the risk of reporting delays due to personnel changes. 6. Ongoing Compliance Monitoring • Management will conduct periodic reviews of NSLDS reporting performance and maintain monitoring documentation to verify ongoing compliance with federal requirements. Any exceptions identified will be addressed through corrective action and management follow-up. 7. Oversight and Accountability • The Director of Financial Aid and senior administration will review compliance monitoring results periodically and track remediation efforts until the finding has been fully resolved. Management will maintain documentation supporting the operation of controls and timely reporting activities. Responsible Officials • Director of Financial Aid – Dr Thelbert Snowden • Executive Vice President – Ariane Sweeney • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Registrar (as applicable) – Adele Hartswick Anticipated completion date: The Institute will implement formal policies, reporting calendars, monitoring controls, reconciliation procedures, and review documentation requirements by December 31, 2026. Ongoing compliance monitoring and periodic review activities will continue thereafter.

View Audit 409492

Finding 1227454 (2025-002)

Material Weakness 2025

The Institute of World Politics

DC

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance Finding: We noted that controls identified by management over all material compliance requirements lack sufficient documentation to conclude application of controls is in place. Corrective Actions Taken or Planned: Mana...

Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance Finding: We noted that controls identified by management over all material compliance requirements lack sufficient documentation to conclude application of controls is in place. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions: 1. Development of Written Policies and Procedures • The Institute will perform a comprehensive review of all applicable Student Financial Assistance compliance requirements and develop formal written policies and procedures documenting the processes and controls for each material compliance area. Procedures will include the individual responsible, required documentation, review requirements, and retention standards. 2. Documentation of Internal Controls • Management will establish standardized control documentation requirements for all compliance activities. Evidence of review and approval will be maintained through signatures, initials, electronic approvals, checklists, reconciliations, or other documented support sufficient to demonstrate that controls were performed and reviewed. 3. Compliance Monitoring Checklists • The Institute will implement compliance monitoring checklists covering all direct and material compliance requirements identified in the audit, including: o Cash Management o Reporting o Student Eligibility o Student Disbursements o Credit Balance Processing o NSLDS Reporting o Gramm-Leach-Bliley Act Information Security Requirements • The checklists will be completed and reviewed periodically to provide evidence of compliance and supervisory oversight. 4. Training and Cross-Training • Financial Aid and Administrative personnel will receive training on federal student aid compliance requirements, documentation expectations, and internal control responsibilities. Cross training will be performed to mitigate risks associated with employee turnover and ensure continuity of operations. 5. Management Review and Oversight • Management will implement periodic supervisory reviews of compliance activities and supporting documentation to verify controls operating as designed. Results of compliance monitoring activities and any identified deficiencies will be reported to senior administration, and corrective actions will be tracked to completion. 6. Annual Compliance Review • The Institute will conduct an annual review of Student Financial Assistance policies, procedures, and internal controls to ensure continued compliance with Department of Education regulations, Uniform Guidance requirements, and changes in federal program requirements. Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance (Continued) Responsible Officials: • Executive Vice President – Ariane Sweeney • Director of Financial Aid – Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Compliance and Information Security Personnel, as applicable Anticipated completion date: The written policies and procedures, compliance monitoring tools, and documentation standards will be fully implemented by December 31, 2026. Ongoing monitoring, training, and annual reviews will continue thereafter.

View Audit 409492

Finding 1227453 (2025-001)

Material Weakness 2025

Columbia Borough School District

PA

Subrecipient Monitoring Cash Management Reporting § 200.303

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will...

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will prepare the monthly SNP Claim for Reimbursement Summary report and compile all supporting meal count documentation. 2. Prior to submission, the Administrative Assistant to the Director of Food Services or another designated individual independent of the preparation process will: a. Review the claim for mathematical accuracy; b. Verify meal counts against supporting documentation; c. Confirm claims are submitted within required timelines; and 3. Evidence of the review and approval will be documented through: a. Signature or electronic approval on the reimbursement summary report; and b. Retention of supporting documentation in accordance with federal and state record retention requirements. 4. A written standard operating procedure (SOP) outlining these review and approval responsibilities will be developed and communicated to applicable personnel. The Business Manager will periodically monitor compliance with the procedure to ensure controls remain effective.

View Audit 409490

Finding 1227450 (2025-001)

Material Weakness 2025

Search for Common Ground

DC

Reporting Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.302 § 200.303

We will strengthen our controls around reporting of expenses on consolidated SEFA report for our subsidiary and related organizations. We will exclude expenses that exceed the total budget and recommend posting adjustments in the books so that these are not included in grant expenses.

View Audit 409488

Finding 1227449 (2025-004)

Material Weakness 2025

Housing and Redevelopment Authority of the City of Worthington

MN

Internal Control / Segregation of Duties

Uniform Guidance Written Policies and Procedures CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will establish written policies and procedures for Uniform Guidance. Officia...

Uniform Guidance Written Policies and Procedures CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will establish written policies and procedures for Uniform Guidance. Official Responsible for Ensuring CAP: Tanner Rogers, Executive Director, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding.

View Audit 409486

Finding 1227448 (2025-003)

Material Weakness 2025

Housing and Redevelopment Authority of the City of Worthington

MN

HUD Housing Programs

Signatures on Checks CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will make sure that all checks have the proper signatures that are required Official Responsible for Ens...

Signatures on Checks CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will make sure that all checks have the proper signatures that are required Official Responsible for Ensuring CAP: Tanner Rogers, Executive Director, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding.

View Audit 409486

Finding 1227447 (2025-002)

Material Weakness 2025

Housing and Redevelopment Authority of the City of Worthington

MN

HUD Housing Programs Special Tests & Provisions

Control Finding over Special Provisions CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will implement a checklist for documentation required to be obtained regarding specia...

Control Finding over Special Provisions CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will implement a checklist for documentation required to be obtained regarding special provisions compliance. They will also implement a formal review process of tenant files. Official Responsible for Ensuring CAP: Tanner Rogers, Executive Director, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding.

View Audit 409486

Finding 1227446 (2025-001)

Material Weakness 2025

Housing and Redevelopment Authority of the City of Worthington

MN

HUD Housing Programs

Rent Reasonableness CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will include rent reasonableness documentation in all required tenant files. Official Responsible for Ens...

Rent Reasonableness CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will include rent reasonableness documentation in all required tenant files. Official Responsible for Ensuring CAP: Tanner Rogers, Executive Director, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding.

View Audit 409486

Finding 1227395 (2025-002)

Material Weakness 2025

Southern Minnesota Regional Legal Services Inc.

MN

Allowable Costs / Cost Principles

Corrective Action Planned: Management agrees with the auditor’s findings. The Director of Litigation, Lisa Hollingsworth, will meet with the Regional Leaders and ensure that they remind their staff about the necessity of obtaining a written statement of facts from clients in each relevant case. Name...

Corrective Action Planned: Management agrees with the auditor’s findings. The Director of Litigation, Lisa Hollingsworth, will meet with the Regional Leaders and ensure that they remind their staff about the necessity of obtaining a written statement of facts from clients in each relevant case. Name(s) of Contact Person(s) Responsible for Corrective Action: Director of Litigation – Lisa Hollingsworth Southeast Regional Leader – Brian Lipford Southwest Regional Leader – Peter Hemberger Anticipated Completion Date: On or before December 31, 2026

View Audit 409471

Corrective Action Plans

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