Corrective Action Plans

Finding 384721 (2023-002)

Significant Deficiency 2023

IL

Internal Control / Segregation of Duties Cash Management Reporting

Corrective Action Plan Finding No: 2023-002 Condition: During our audit testing we noted that the District Cashier prepares and submits monthly reimbursement claims to ISBE and that these submissions are not reviewed or approved by anyone else. No formal documentation of the review. Plan: Th...

Corrective Action Plan Finding No: 2023-002 Condition: During our audit testing we noted that the District Cashier prepares and submits monthly reimbursement claims to ISBE and that these submissions are not reviewed or approved by anyone else. No formal documentation of the review. Plan: The District will implement a process in which the Business Manager will review and approve monthly reimbursement claim submissions prior to them being submitted. Anticipated Date of Completion: June 30, 2024 Name of Contact Person: Ryan Leonard, Business Manager/CSBO (708) 496-8700 x 5004

View Audit 297860

Finding 384713 (2023-002)

Material Weakness 2023

Harrisburg Area Community College

PA

Cash Management Material Weakness Reporting

Friday, March 15, 2024 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the June 30, 2023 audit report dated March 15, 2024 schedule of findings and questioned cost are discussed below. The findings are ...

Friday, March 15, 2024 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the June 30, 2023 audit report dated March 15, 2024 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding) U.S. Department of Education Audit Period: July 1, 2022 – June 30, 2023 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants 804 Wayne Avenue Chambersburg, Pennsylvania Finding Type: (per Finding) Federal Awards: Material Weakness in internal Controls over Compliance and NonCompliance Internal Control Type: (please choose the type per the finding) o Material Weakness(es) o Significant Deficiencies Audit Finding No.: 2023-002 Federal Program: (per Finding) Student Financial Aid Cluster Compliance Requirement: (per Finding) Reporting Audit Finding Title/Statement of Condition: (copy from audit findings documentation) Institutions are required to report the website (URL) to the Department of Education that explains where students can obtain information concerning the outside organization that is processing refunds for the institution. This is published in the cash management contracts database. The URL noted above was not reported to the Department of Education for publication in the cash management contracts database. Auditor Recommendation: (copy from audit findings documentation) We recommend that the College ensure the URL is reported to the Department of Education for publication in the Cash Management contracts database. Additionally, we recommend the College review reporting requirements and processes to ensure any new requirements are addressed in a timely fashion. Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). On February 15, 2024 HACC filed its contract URL with the Department of Education per 34 CFR 668.164(e)(2)(viii). HACC will ensure that we review our reporting requirements and processes annually to ensure that any new requirements are addressed in a timely fashion. HACC has subscribed to any 34 CFR updates to be made aware of any new requirements, which will allow us to update our policies, procedures and task lists to ensure compliance going forward. Anticipated Completion Date: 3/15/2024 Name(s) and Title(s) of contact person(s) responsible for correction action: Dawn K Mull Director, Finance and Assistant Controller

View Audit 297844

Finding 384712 (2023-001)

Material Weakness 2023

Harrisburg Area Community College

PA

Student Financial Aid Reporting Material Weakness

Friday, March 15, 2024 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the June 30, 2023 audit report dated March 15, 2024 schedule of findings and questioned cost are discussed below. The findings are ...

Friday, March 15, 2024 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. The findings from the June 30, 2023 audit report dated March 15, 2024 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding) U.S. Department of Education Audit Period: July 1, 2022 – June 30, 2023 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants 804 Wayne Avenue Chambersburg, Pennsylvania Finding Type: (per Finding) Student Financial Aid Cluster: Material Weakness in internal Controls over Compliance and NonCompliance Internal Control Type: (please choose the type per the finding) o Material Weakness(es) o Significant Deficiencies Audit Finding No.: 2023-001 Federal Program: (per Finding) Student Financial Aid Cluster: Compliance Requirement: (per Finding) Reporting Audit Finding Title/Statement of Condition: (copy from audit findings documentation) Institutions are required to report enrollment information under the Pell grant and the Direct loan programs via the National Student Loan Data System (NSLDS). Two student’s enrollment changes were not properly reported to NSLDS and this was not initially addressed by the College. Seven student’s enrollment changes were not timely reported. These students were enrolled during the Spring 2023 semester and the changes were not reported to NSLDS until September 2023, beyond the 60-day reporting requirement. Auditor Recommendation: (copy from audit findings documentation) We recommend that the College ensure all error reports are reviewed and followed up on timely to ensure students information is being properly reported to NSLDS. Additionally, we recommend the college review its policies and procedures and training processes to ensure reporting is happening in a timely manner. Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). 1) The College will correct the enrollment discrepancies that were reported/uncovered in the audit process. 2) The College will review its existing reporting process for enrollment to the National Clearinghouse. 3) The College will regularly cross reference National Clearinghouse reporting to ensure accurate transfer into NSLDS. 4) The College will address any issues with NSLDS reporting carryover/transfer with NSLDS staff support. Anticipated Completion Date: Corrections to the students’ enrollment errors will be addressed by March 31, 2024. Name(s) and Title(s) of contact person(s) responsible for correction action: Tim Barshinger, Assistant Vice-president of Student Enrollment Services

View Audit 297844

Finding 384711 (2023-002)

Material Weakness 2023

Montgomery County Housing Authority

TX

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Corrective Action Plan Finding: Finding 2023-002-Software Subscription Costs Not Properly Accounted For-Reporting Condition: For June 30, 2023 year-ends and forward, Government Auditing Standard (GASB) No. 96 applies. This requires a new accounting for subscription (lease)-based information tec...

Corrective Action Plan Finding: Finding 2023-002-Software Subscription Costs Not Properly Accounted For-Reporting Condition: For June 30, 2023 year-ends and forward, Government Auditing Standard (GASB) No. 96 applies. This requires a new accounting for subscription (lease)-based information technology arrangements (SBITAs). The Authority entered into a five-year agreement that started May 1, 2021 with a software company. Corrective Action Planned We will comply with the auditor’s recommendation. Person responsible for corrective action: Roxanne Albizuri, Executive Director Telephone: (936) 539-4984 Housing Authority of Montgomery County, Texas Fax: (936) 539-4758 1500 N Frazier, Ste 101 Conroe, TX 77301 Anticipated Completion Date: June 30, 2024

View Audit 297841

Finding 384710 (2023-001)

Material Weakness 2023

Montgomery County Housing Authority

TX

HUD Housing Programs Reporting

MONTGOMERY COUNTY HOUSING AUTHORITY 1500 N. Frazier, Ste 101 Conroe, TX 77301 Phone No. (936) 539-4984 Fax No. (936) 539-4758 HOUSING AUTHORITY OF MONTGOMERY COUNTY, TEXAS CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Corrective Action Plan Finding: Finding 2023-001-Non current Valuation...

MONTGOMERY COUNTY HOUSING AUTHORITY 1500 N. Frazier, Ste 101 Conroe, TX 77301 Phone No. (936) 539-4984 Fax No. (936) 539-4758 HOUSING AUTHORITY OF MONTGOMERY COUNTY, TEXAS CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Corrective Action Plan Finding: Finding 2023-001-Non current Valuations and Inadequate Disclosure for Defined Benefit Pension Plan Condition: All material amounts included in the financial statements should have valuations as of the last day of the audit year. In addition, the footnotes should include all of the disclosures that are required. Both of these elements are required by accounting principles generally accepted in the United States. Corrective Action Planned I am Roxanne Albizuri, Executive Director and Designated Person to answer this finding. We will comply with the auditor’s recommendation. Person responsible for corrective action: Roxanne Albizuri, Executive Director Telephone: (936) 539-4984 Housing Authority of Montgomery County, Texas Fax: (936) 539-4758 1500 N Frazier, Ste 101 Conroe, TX 77301 Anticipated Completion Date: June 30, 2024

View Audit 297841

Finding 384709 (2023-002)

None 2023

St. Anne Residence

IL

HUD Housing Programs

U.S. Department of Housing and Urban Development 2023-002 Supportive Housing for the Elderly– CFDA No. 14.157 Recommendation: We recommend management compare the security deposit cash account to the security deposit liability account on a regular basis as well as when a move-in or move-out occurs. ...

U.S. Department of Housing and Urban Development 2023-002 Supportive Housing for the Elderly– CFDA No. 14.157 Recommendation: We recommend management compare the security deposit cash account to the security deposit liability account on a regular basis as well as when a move-in or move-out occurs. Explanation of disagreement with audit finding: There is no disagreemet with the finding. Management will closely monitor the security deposit balances to ensure they maintain compliance with the regulatory agreement. Name(s) of the contact person(s) responsible for corrective action: Margaret Perine Planned completion date for corrective action plan: In process

View Audit 297826

Finding 384708 (2023-001)

None 2023

St. Anne Residence

IL

HUD Housing Programs

U.S. Department of Housing and Urban Development 2023-001 Supportive Housing for the Elderly– CFDA No. 14.157 Recommendation: The Project should ensure the move-out notifications are provided to the accounting office in a timely manner and ensure the tenant's security deposit is processed and refund...

U.S. Department of Housing and Urban Development 2023-001 Supportive Housing for the Elderly– CFDA No. 14.157 Recommendation: The Project should ensure the move-out notifications are provided to the accounting office in a timely manner and ensure the tenant's security deposit is processed and refunded within 30 days of the move-out date. Explanation of disagreement with audit finding: There is no disagreement with the finding. Management will notify the accounting department of impending move-outs when tenants give notice of moving out. This will provide additional processing time for processing the security deposit payment within 30 days of the actual move-out date. Name(s) of the contact person(s) responsible for corrective action: Margaret Perine Planned completion date for corrective action plan: In process

View Audit 297826

Finding 384707 (2023-002)

Significant Deficiency 2023

Massachusetts Maritime Academy

MA

Questioned Costs Student Financial Aid

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Federal Pell Grants AL #’s: 84.063 Award year: 2023 Corrective Action Plan: Once the new Federal Pell Grant amounts are announced by the DOE, the Director will run a report of all students that have already been awarded ...

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Federal Pell Grants AL #’s: 84.063 Award year: 2023 Corrective Action Plan: Once the new Federal Pell Grant amounts are announced by the DOE, the Director will run a report of all students that have already been awarded a Federal Pell Grant to recalculate their Federal Pell Grant amount. Additionally, an internal audit will be done after the first disbursements are done in the Fall to ensure that all students are receiving the correct Pell amount. Timeline for Implementation of Corrective Action Plan: This policy was already implemented and began with the 2023-2024 academic year. Contact Person Catherine Kedski, Director of Student Financial Services

View Audit 297824 Questioned Costs: $1

Finding 384706 (2023-001)

Significant Deficiency 2023

Massachusetts Maritime Academy

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans AL #’s: 84.268 Award year: 2023 Corrective Action Plan: The Loan Counselor will automatically submit a Direct Loan disbursement report immediately following the disbursement of any federal lo...

Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans AL #’s: 84.268 Award year: 2023 Corrective Action Plan: The Loan Counselor will automatically submit a Direct Loan disbursement report immediately following the disbursement of any federal loan. The Director will monitor when the Loan Counselor runs any disbursements and confirm that the disbursement report has been sent to COD in a timely fashion. Timeline for Implementation of Corrective Action Plan: This plan has already been implemented beginning with the 2023-2024 academic year. Contact Person Catherine Kedski, Director of Student Financial Services

View Audit 297824

Finding 384705 (2023-101)

Significant Deficiency 2023

Lead Charter Schools

AZ

Allowable Costs / Cost Principles § 200.303 § 200.430

CORRECTIVE ACTION PLAN JUNE 30, 2023 REFERENCE: 2023-101 CFDA NUMBER 84.425D – COVID 19 – EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION – 2023 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the ...

CORRECTIVE ACTION PLAN JUNE 30, 2023 REFERENCE: 2023-101 CFDA NUMBER 84.425D – COVID 19 – EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION – 2023 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Michelle Borja, Finance Director 2. Corrective action planned: Time and Effort documentation for employees who work solely on a single cost objective is prepared semi-annually and signed by the employee and/or a supervisor having firsthand knowledge of the work performed by the employee. Time and Effort documentation is collected semi-annually by the Accounting Office. The Finance Director will review forms to ensure the form is completed appropriately. Forms will be reviewed to ensure the period of performance is recorded accurately and signatures obtained from employees and/or supervisors are dated appropriately. 3. Anticipated completion date: Implemented immediately and completed by June 30, 2024

View Audit 297816

Finding 384704 (2023-101)

Significant Deficiency 2023

Leading Edge Academy Maricopa

AZ

Allowable Costs / Cost Principles § 200.303 § 200.430

CORRECTIVE ACTION PLAN JUNE 30, 2023 REFERENCE: 2023-101 CFDA NUMBER 84.425D – COVID 19 – EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION – 2023 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the co...

CORRECTIVE ACTION PLAN JUNE 30, 2023 REFERENCE: 2023-101 CFDA NUMBER 84.425D – COVID 19 – EDUCATION STABILIZATION FUND U.S. DEPARTMENT OF EDUCATION – 2023 PASSED THROUGH ARIZONA STATE DEPARTMENT OF EDUCATION GRANT NUMBER: S425D210038 CLIENT RESPONSE AND CORRECTIVE ACTION PLAN We concur with the condition. 1. Name of the contact person responsible for corrective action: Michelle Borja, Finance Director 2. Corrective action planned: Time and Effort documentation for employees who work solely on a single cost objective is prepared semi-annually and signed by the employee and/or a supervisor having firsthand knowledge of the work performed by the employee. Time and Effort documentation is collected semi-annually by the Accounting Office. The Finance Director will review forms to ensure the form is completed appropriately. Forms will be reviewed to ensure the period of performance is recorded accurately and signatures obtained from employees and/or supervisors are dated appropriately. 3. Anticipated completion date: Implemented immediately and completed by June 30, 2024

View Audit 297815

Finding 384699 (2023-003)

Material Weakness 2023

Cherokee Communith School District

IA

Internal Control / Segregation of Duties

SEE RESPONSE AND CORRECTIVE ACTION PLAN AT 2023-001.

View Audit 297813

Finding 384695 (2023-003)

Significant Deficiency 2023

Independent School District No. 197

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties 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 10.555, 10.559, 10.556, AND 10.553 2023-003 Internal Control Over Compliance With Federal Suspension and Debarment R...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, 10.556, AND 10.553 2023-003 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Summary of Finding Criteria – 2 CFR § 180 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster program. Condition – The District did not have sufficient controls in place within its child nutrition cluster program to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – Peter Olson-Skog, the District’s Superintendent. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Peter Olson-Skog, the District’s Superintendent, will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

View Audit 297807

Finding 384694 (2023-007)

Significant Deficiency 2023

Columbia College

MO

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

2023-007 Exit Counseling (Significant Deficiency) Criteria: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower ...

2023-007 Exit Counseling (Significant Deficiency) Criteria: Federal regulations stipulate that an institution must ensure that exit counseling is conducted with each Federal Direct Loan borrower shortly before the student borrower ceases at least half-time study at the school. If a student borrower withdraws from the school without prior knowledge or fails to complete the exit counseling as required, exit counseling must, within 30 days after the school learns that the student has withdrawn from school or failed to complete the exit counseling as required, be provided either through interactive electronic means, by mailing written counseling materials to the student borrower at the student borrower’s last known address, or by sending written counseling materials to an email address provided by the student borrower that is not an email address associated with the school sending the counseling materials. Condition: During our testing, we noted eight instances, in a sample of nine students requiring exit counseling, in which evidence of exit counseling and notification of exit counseling could not be provided by the College. Action Taken: We concur with this finding. Currently, students receive a withdrawal notification that provides them with a link to complete their exit counseling. Moving forward and during the completion of the withdrawal, the students will be presented with an exit counseling digital page. On this page, withdrawal information will be provided to the student along with the deadline to complete the exit counseling. Students will also certify that they have received and understood the information. Once the withdrawal form is completed, students will get a follow up email that will also direct them to the exit counseling at www.studentaid.gov and inform them of the 30-day deadline. Responsible Party: Lola Kennedy, Senior Director of Financial Aid and Sharon Murphy, Registrar Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) and Sharon Murphy, Registrar (smurphy@columbiasc.edu) Expected date of correction: April 1, 2024

View Audit 297799

Finding 384693 (2023-006)

Significant Deficiency 2023

Columbia College

MO

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

2023-006 Return of Title IV Funds (Significant Deficiency) Criteria: When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of ...

2023-006 Return of Title IV Funds (Significant Deficiency) Criteria: When a recipient of Title IV grant or loan assistance withdraws from a school during a payment period in which the recipient began attendance, the school must determine the amount of Title IV assistance earned by the student as of the student’s withdrawal date. If the total of the Title IV assistance earned by the student is less than the amount that was distributed to the student, the difference must be returned to the Title IV programs. A school must return Title IV funds to the programs from which the student received aid as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. Four of the students refund calculations were not completed in a timely fashion and two students that completed a withdrawal form did not have a refund calculations prepared. The College did not return Title IV funds for the two students that should have had refund calculations and the College did not return Title IV funds within 45 days after the date of determination of the student’s withdrawal for the four students that had refund calculations prepared. Action Taken: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the communication list for withdrawals was updated with the Director of Financial Aid’s information to ensure the financial aid office receives all withdrawal information in a timely manner. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: July 2023

View Audit 297799

Finding 384692 (2023-005)

Significant Deficiency 2023

Columbia College

MO

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

2023-005 Reporting Student Withdraw Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance ...

2023-005 Reporting Student Withdraw Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with 34 CFR Section 685.309(a)(2). Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that six of the seven required a refund calculation and return of funds. The change in status was not reported to NSLDS for one student and the last date of the semester was reported instead of the withdrawal date for four students. Action Taken: The Registrar’s Office maintains the institution’s enrollment records. During the fall of 2023, the enrollment reporting process was moved to the Registrar’s Office to ensure the accuracy of reporting. Responsible Party: Sharon Murphy, Registrar Point of Contact: Sharon Murphy, Registrar (smurphy@columbiasc.edu) Expected date of correction: August 2023

View Audit 297799

Finding 384691 (2023-004)

Significant Deficiency 2023

Columbia College

MO

Student Financial Aid Significant Deficiency

2023-004 Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consec...

2023-004 Incorrect Calculation of Title IV Funds Refunds (Significant Deficiency) Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. If a student withdrawals by providing notification to designated officials, the withdrawal date is the date notification was provided. Institutional charges used in the refund calculation are the charges that were initially assessed the student for the entire payment period. Condition: From a population of 61 students that withdrew during the fiscal year, we tested seven and noted that four of the seven had refund calculations prepared. From these calculations we noted the following: 1. Breaks of five or more consecutive days were not deducted from total days in all refunds. 2. The date of the college’s determination was used as the withdrawal date for three of the four students.3. Institutional charges for the period used in the refund calculations included tuition and fee credits processed due to the withdrawal for two of the four students. Action Taken: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training on R2T4 processing along with other regulations. System updates are performed during the Fall semester for the next year. During this update, R2T4 parameters are set and monitored to ensure accuracy. In addition, the R2T4 calculations now include adjustments made to the students’ account at the time of withdrawal. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: August 1, 2023

View Audit 297799

Finding 384690 (2023-003)

Significant Deficiency 2023

Columbia College

MO

Student Financial Aid Significant Deficiency

2023-003 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency) Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. I...

2023-003 Treatment of a student who fails to receive a passing grade in any class (Significant Deficiency) Criteria: An institution must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: From a population of 140 students that received all failing grades in a term, we tested fourteen students and noted that documentation of the last date of attendance could not be provided for any of the students tested. Action Taken: We concur with this finding. With enhancements to the Jenzabar ONE system, the institution has implemented a new process that requires professors to enter the Last Day of attendance (LDA) for any student who earned an F grade. Going forward, the Registrar will present a report to the Office of Financial Aid two days after final grades post for the semester. The report will have the students who have all Fs with their LDS listed for each class. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: April 2024

View Audit 297799

Finding 384689 (2023-002)

Significant Deficiency 2023

Columbia College

MO

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

2023-002 Disbursement of Title IV Funds (Significant Deficiency) Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to...

2023-002 Disbursement of Title IV Funds (Significant Deficiency) Criteria: An institution must disburse during the current payment period, with certain qualifying exceptions, the amount of Title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to receive for that payment period, 34 CFR 668.164(b)(1). Condition: During our testing, we noted three instances in a sample of 26 students in which Direct Loan awards were not disbursed to the student during the payment period. Qualified exceptions were not met and the three students received disbursements for the 2022-2023 academic year on August 14, 2023. Action Taken: We concur with this finding. During the 2022-2023 academic year, the Office of Financial Aid experienced much transition. The office is now fully staffed. In addition, the staff attend internal and external training sessions regularly. Currently, disbursements are processed at least 3 times a week. The Office of Financial Aid works diligently to ensure all funds are fully disbursed by the end of each semester. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: January 2024

View Audit 297799

Finding 384688 (2023-001)

Material Weakness 2023

Columbia College

MO

Student Financial Aid Material Weakness Reporting

2023-001 Special Reporting – Fiscal Operations Report and Application to Participate (FISAP) (Material Weakness) Criteria: As a Campus-Based Program participant, the College is required to submit an accurate FISAP yearly by October 1. The information reported on the FISAP is used to determine the s...

2023-001 Special Reporting – Fiscal Operations Report and Application to Participate (FISAP) (Material Weakness) Criteria: As a Campus-Based Program participant, the College is required to submit an accurate FISAP yearly by October 1. The information reported on the FISAP is used to determine the school’s Campus Based Program funding for the upcoming award year as well as report Campus‑Based Program expenditures for the prior award year. The College is required to submit a Fiscal Operations Report plus other information required; the information must be accurate and shall be submitted on the form at the time specified, 34 CFR 674.19(d)(2). Condition: During our review of the College’s FISAP it was determined that tuition and fee revenue was overstated and Pell amount reported was understated. Action Taken: We concur with this finding. Staff made a “change request” to the US Department of Education (USDOE) to adjust the FISAP. Once the “change request” was approved by the USDOE, we edited the FISAP report to appropriately reflect the audited numbers. It is important to note that the FISAP is due by September 30th, and the USDOE allows institutions until December 15th to adjust the figures. Our audited financial statements are due no later than September 30th, which normally allows time to ensure that the figures on the FISAP are reconciled to the ones on the audited financial statements. Nevertheless, if the audited statements are not completed by the September 30th deadline, we will make sure that any adjusting entries to the FISAP are made by the final date of December 15th. Responsible Party: Lola Kennedy, Senior Director of Financial Aid Point of Contact: Lola Kennedy, Senior Director of Financial Aid (lkennedy@columbiasc.edu) Expected date of correction: February 2024

View Audit 297799

Finding 384687 (2023-001)

Material Weakness 2023

Housing Authority of the City of Brownsville

TX

Questioned Costs HUD Housing Programs Eligibility

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor on the inspection of tenant files and has made arrangements to comply with the Section 8 Housing Choice Vouchers and Emergency Housing Vouchers programs. Leticia Gonzalez, Director o...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor on the inspection of tenant files and has made arrangements to comply with the Section 8 Housing Choice Vouchers and Emergency Housing Vouchers programs. Leticia Gonzalez, Director of Client Services, will be responsible to implement this corrective action by June 30, 2024.

View Audit 297792 Questioned Costs: $1

Finding 384683 (2023-004)

Significant Deficiency 2023

Gila Crossing Community School

AZ

Reporting Significant Deficiency Program Income

Finding Number: 2023‐004 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Indian School Equalization Program 15.042 Administrative Cost Grants for Indian Schools 15.046 COVID‐19 Education Stabilization Fund 84.425 Contact Person: Jim Mosley, Superintendent Anticipated Completion ...

Finding Number: 2023‐004 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Indian School Equalization Program 15.042 Administrative Cost Grants for Indian Schools 15.046 COVID‐19 Education Stabilization Fund 84.425 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: The School reported incorrect expenditures for one of four quarterly reports reviewed. Acknowledged that one of the quarterly SF‐425 reports did contain an error with the additional revenue and expenses of non‐federal monies included in the report. Future reports will be reviewed more closely to prevent such errors.

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Finding 384681 (2023-003)

Significant Deficiency 2023

Gila Crossing Community School

AZ

Equipment & Real Property Management

Finding Number: 2023‐003 Program Name/Assistance Listing Title: COVID‐1 Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: The School has not been able to devote proper resour...

Finding Number: 2023‐003 Program Name/Assistance Listing Title: COVID‐1 Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. The School has hired a new person in the role of Purchasing and Payables that has some experience in capital assets. Additional training will be needed and pursued along with outside consulting services sought after.

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Finding 384679 (2023-002)

Significant Deficiency 2023

Gila Crossing Community School

AZ

Procurement, Suspension & Debarment § 200.320

Finding Number: 2023‐002 Assistance Listing Numbers: Indian School Equalization Program 15.042 Administrative Cost Grants for Indian Schools 15.046 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: The responsible role of Purchasing and...

Finding Number: 2023‐002 Assistance Listing Numbers: Indian School Equalization Program 15.042 Administrative Cost Grants for Indian Schools 15.046 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: The responsible role of Purchasing and Payables changed during fiscal year 2022‐23. The new person was not made aware of the need to perform an annual check for suspension and debarment. Training has seen occurred and a new schedule established for performing the required check of vendors over the threshold of $25,000. Also, a newly established procedure will be established to clarify Sole Source approval by the governing board for vendors.

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Finding 384678 (2023-001)

Significant Deficiency 2023

Gila Crossing Community School

AZ

Special Tests & Provisions Significant Deficiency

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: During fiscal year 2022‐23, there was a change in staf...

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Contact Person: Jim Mosley, Superintendent Anticipated Completion Date: June 30, 2024 Planned Corrective Action: During fiscal year 2022‐23, there was a change in staffing in Human Resources and a delay occurred in the training and certification of the new HR person. Action has already been taken to complete the reinvestigations that were missed; a new schedule has been put in place to ensure that this issue does not repeat in the future.

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