Corrective Action Plans

Finding 1175563 (2025-007)

Material Weakness 2025

AL

Reporting § 200.302 § 200.328 § 200.329

Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures for financial and performan...

Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures for financial and performance report preparation to ensure information is supported by proper documentation and agrees with the general ledger. These policies and procedures will also include a requirement that all reports are reviewed by a member of management who is not involved in the preparation of the reports.

View Audit 389347

Finding 1175562 (2025-006)

Material Weakness 2025

Northeast Alabama Health Services, Inc.

AL

Procurement, Suspension & Debarment § 200.320

Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance, as well as the Financial Policies and Procedures Manual. • Develop and implement policies...

Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance, as well as the Financial Policies and Procedures Manual. • Develop and implement policies and procedures that include monitoring of procurements to ensure policies and procedures are being followed. • Include in policies and procedures that a member of the finance department or management will review the SF-425 for correctness before submission.

View Audit 389347

Finding 1175561 (2025-005)

Material Weakness 2025

Northeast Alabama Health Services, Inc.

AL

Cash Management Allowable Costs / Cost Principles Material Weakness § 200.302 § 200.305

Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures that ensure grant funds are...

Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures that ensure grant funds are drawn at the time of, or following, expenditures for allowable costs. These policies and procedures will include that, for each draw from a Federal award, 1) detailed documentation of the expenditures for which the grant funds are being drawn is prepared prior requesting the draw, including transactional details such as vendor, invoice number, invoice amount, check number, check date, payee, and check amount; 2) that the documentation supporting the draw is reviewed and approved by a member of management (other than the person who prepares the documentation) prior to requesting the draw, and 3) that the documentation supported each draw is maintained as part of the Organization's accounting records. • Return H8F funds, including interest, to the Federal grantor agency.

View Audit 389347

Finding 1175560 (2025-004)

Material Weakness 2025

Northeast Alabama Health Services, Inc.

AL

Reporting Allowable Costs / Cost Principles Period of Performance

Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all financial staff and management, covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures that ensure: 1) all staff are ...

Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all financial staff and management, covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures that ensure: 1) all staff are aware of the period of performance for each federal award; 2) the financial management records and systems include the ability to monitor and track the status of each federal award throughout its period of performance, especially for one-time funding awards. • Return H8F funds, including interest, to the Federal grantor agency.

View Audit 389347

Finding 1175547 (2025-002)

Material Weakness 2025

Estancia Municipal Schools

NM

Cash Management School Nutrition Programs Internal Control / Segregation of Duties

The District acknowledges the oversight and confirms that the March 2025 claim had been properly prepared and fully supported but was inadvertently not submitted. The District has since contacted NMPED to resolve the matter and submitted the claim. To prevent future occurrences, the District is impl...

The District acknowledges the oversight and confirms that the March 2025 claim had been properly prepared and fully supported but was inadvertently not submitted. The District has since contacted NMPED to resolve the matter and submitted the claim. To prevent future occurrences, the District is implementing a new tracking and reminder system and is providing targeted training to staff involved in the claims process. Efforts are also underway to strengthen internal controls to ensure timely submission moving forward.

View Audit 389344

Finding 1175546 (2025-002)

Material Weakness 2025

Floyd County Community Action Agency, Inc.

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Management acknowledges that the Agency did not meet the required 20 percent non-federal share for the budget period ended May 31, 2025, and that the waiver request was submitted after the close of the budget period. While allowable in-kind contributions were tracked throughout the year, communicati...

Management acknowledges that the Agency did not meet the required 20 percent non-federal share for the budget period ended May 31, 2025, and that the waiver request was submitted after the close of the budget period. While allowable in-kind contributions were tracked throughout the year, communication from OHS provided differing guidance regarding the timing of submission for a Non-Federal Share waiver, which contributed to the delay. To address this matter, the Agency has implemented the following corrective actions: 1. A formal monthly Non-Federal Share Monitoring Report has been implemented and is reviewed by the Director and CFO. This report calculates the required match based on cumulative federal expenditures and compares it to documented in-kind contributions to ensure ongoing compliance. 2. Quarterly match projections are now prepared to identify potential shortfalls in advance of the budget period end. If projections indicate a deficit, corrective measures will be initiated immediately, including intensified in-kind collection efforts or submission of a waiver request prior to the end of the budget period. 3. The Governing Board and Policy Council will receive quarterly updates on non-federal share status to strengthen governance oversight and ensure transparency. 4. Written internal procedures for in-kind documentation, valuation, and monitoring have been formalized and incorporated into the Agency's fiscal policies and procedures manual. 5. The CFO has received additional training regarding federal matching requirements under 45 CFR §75 and Head Start Program Performance Standards to reinforce compliance expectations and ensure timely action in future budget periods. Management believes these corrective actions will strengthen internal controls, improve monitoring, and prevent recurrence in future budget periods.

View Audit 389340

Finding 1175539 (2025-001)

Material Weakness 2025

Southwestern University

TX

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Student Financial Aid Corrective Action Plan Institution Name: Southwestern University Audit/Review Period: FY 2024-2025 Date of Plan: Feb 4, 2026 Finding: 2025-001 Effect: The University did not report withdraw changes to the NSLDS timely. Recommendation: The University should put in place a proces...

Student Financial Aid Corrective Action Plan Institution Name: Southwestern University Audit/Review Period: FY 2024-2025 Date of Plan: Feb 4, 2026 Finding: 2025-001 Effect: The University did not report withdraw changes to the NSLDS timely. Recommendation: The University should put in place a process to timely capture student status changes so that they can be reported to the NSLDS. Management Response: The University concurs with this finding. University Corrective Action Plan: Every 30 days, the University reports updated student enrollment activity, encompassing attendance levels, graduation status, withdrawals, dropouts, and enrollment changes, to the National Student Loan Database System via the National Student Clearinghouse. Regrettably, during the 2024-25 academic year, an unforeseen error from the Clearinghouse resulted in the dissemination of incorrect enrollment statuses for a subset of our students. This oversight was beyond the Registrar's Office's knowledge, leading to an unintended delay in rectifying the reported statuses. We believe this Clearinghouse error was an isolated incident, having never occurred in any preceding academic year. The issue has been effectively resolved and should not recur in the future. Nevertheless, as a proactive measure, commencing with the 2025-26 academic year, the Financial Aid Office will collaborate with the Registrar's Office to review a representative sample of at least 10% of student records transmitted to the Clearinghouse. This review process will serve as an additional safeguard, ensuring the accuracy and timeliness of our reporting requirements.

View Audit 389325

Finding 1175536 (2025-005)

Material Weakness 2025

St Vincent Depaul Mission of Waterbury, Inc.

CT

Internal Control / Segregation of Duties Material Weakness Reporting

Lack of Segregation of Duties in Financial Reporting - Compliance Recommendation: Management should reassign responsibilities so that the preparation, review and submission of required reports is performed by different individuals. If staffing limitations prevent full segregation, compensating contr...

Lack of Segregation of Duties in Financial Reporting - Compliance Recommendation: Management should reassign responsibilities so that the preparation, review and submission of required reports is performed by different individuals. If staffing limitations prevent full segregation, compensating controls, such as periodic independent reviews by a supervisor or board member, should be implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Due to staffing limitations, the organization has not been able to implement the optimal level of oversight. Going forward, all reports prepared by the Accountant will undergo a formal review and approval process by the Treasurer to strengthen internal controls and ensure appropriate oversight. Names of the contact persons responsible for corrective action: Robert Loiseau, Finance Director and Gary Beaulieu, Executive Director

View Audit 389324

Finding 1175535 (2025-004)

Material Weakness 2025

St Vincent Depaul Mission of Waterbury, Inc.

CT

Allowable Costs / Cost Principles § 200.405 § 200.430

Allowable Costs/Cost Principles Recommendation: Update and revise the cost allocation plan annually to reflect actual program usage including the board of directors approval. Implement a time and effort reporting system for all shared staff and provide training to ensure compliance with federal requ...

Allowable Costs/Cost Principles Recommendation: Update and revise the cost allocation plan annually to reflect actual program usage including the board of directors approval. Implement a time and effort reporting system for all shared staff and provide training to ensure compliance with federal requirements. This should include proper review and approval of all costs, explicitly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Management will establish and implement formal procedures to ensure the proper allocation of allowable costs across all grant components. These procedures will include appropriate oversight mechanisms to verify accuracy, compliance with grant requirements, and consistent application of cost-allocation methodologies. Names of the contact persons responsible for corrective action: Robert Loiseau, Finance Director and Gary Beaulieu, Executive Director

View Audit 389324

Finding 1175534 (2025-001)

Material Weakness 2025

University of Tulsa

OK

Student Financial Aid Reporting

February 18, 2026 2025 - 001 Federal Program - Student Financial Assistance Cluster - Asstance Listing Nos. 84.063, Federal Pell Grant Program and 84.268 Federal Direct Student Loans U.S. Department of Education Program Year 2024 - 2025 - Enrollment Reporting Summary of Findings: A student record gr...

February 18, 2026 2025 - 001 Federal Program - Student Financial Assistance Cluster - Asstance Listing Nos. 84.063, Federal Pell Grant Program and 84.268 Federal Direct Student Loans U.S. Department of Education Program Year 2024 - 2025 - Enrollment Reporting Summary of Findings: A student record graduation status was not reported correctly. The student was flagged by the Clearinghouse as not having a graduation status applied after the spring degree file submission, but that error was not resolved by the registrar. The failure to resolve this issue was due to staffing issues within the Office of the Registrar. Additionally, another student's withdrawal status was not reported correctly. This student submitted a complete withdrawal form prior to the end of the 2025 spring semester effective for the 2025 fall semester and had their program closed in the school's SIS after the spring semester ended. Students who separate from the university in between regular semesters, and who don't have enrollment in the non-standard summer term, need to be reported as withdrawn individually. Their status change will not be picked up by our normal enrollment process. Recommendations: Staffing issues may be problematic again in the future. Cross-training and adequate staffing is necessary to make sure enrollment reporting is finished in a timely manner. A change to how summer enrollment reporting is handled is necessary to ensure student status changes are reported correctly. Action taken in response to findings: The university has eliminated the hourly graduation specialist position and moved the resposibility for submitting and resolving errors on the degree file to the Associate Registrar. The registrar has also created an enrollment and degree reporting checklist to ensure the process of submitting and resolving errors is completed. The university is changing how it handles complete withdrawals. The Registrar's Office will be responsible for closing out student programs and processing the complete withdrawal form starting this spring. Derrick Weddle University Registrar

View Audit 389303

Finding 1175532 (2025-001)

Material Weakness 2025

Blackhawk School District

PA

Procurement, Suspension & Debarment § 200.318 § 200.320

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Western PA Psych Care’ totaling $40,000. This is a repeat finding from the previous fiscal year 2024-001 CRITERI...

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Western PA Psych Care’ totaling $40,000. This is a repeat finding from the previous fiscal year 2024-001 CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, the District adheres to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance.MANAGEMENT’S PLANNED CORRECTIVE ACTION: For noncompetitive procurement, the District will maintain records sufficient to detail the history of procurement. These records will include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. The District’s timeframe for implementation is effective immediately. The District has a formal procurement policy for federal programs (#626) in place. The District hired a Business Manager effective with the 2024-2025 fiscal year who, in conjunction with the District’s Federal Program Coordinator, will be responsible for following the District’s existing procurement policy for federal programs, in particular related to this finding, the implementation of noncompetitive procurement procedures to ensure that they are followed appropriately. The implementation of this procedure took place after the questioned cost noted this fiscal year and will be effective for all future District procurements.

View Audit 389297

Finding 1175529 (2025-005)

Material Weakness 2025

Bay City Independent School District

TX

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.403

Material weakness in internal control over compliance - Lack of control over monitoring of excess costs Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of excess costs during the year. Program staff and business office personnel will meet regula...

Material weakness in internal control over compliance - Lack of control over monitoring of excess costs Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of excess costs during the year. Program staff and business office personnel will meet regularly to identify any potential issues for noncompliance with excess costs and develop a plan accordingly to ensure compliance is met. Staff training and utilization of the calculation tools provided by TEA will be provided to ensure all involved gain the necessary understanding. Responsible Contact Person: Farrah Jernigan, Chief Financial Officer Anticipated Completion Date: June 30, 2026

View Audit 389296

Finding 1175528 (2025-004)

Material Weakness 2025

Bay City Independent School District

TX

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personne...

Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personnel will meet regularly to identify any potential issues for noncompliance with maintenance of effort and develop a plan accordingly to ensure compliance is met. Staff training and utilization of the calculation tools provided by TEA will be provided to ensure all involved gain the necessary understanding. Responsible Contact Person: Farrah Jernigan, Chief Financial Officer Anticipated Completion Date: June 30, 2026

View Audit 389296

Finding 1175527 (2025-003)

Material Weakness 2025

Bay City Independent School District

TX

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personne...

Material weakness in internal control over compliance - Lack of control over monitoring of maintenance of effort Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of maintenance of effort during the year. Program staff and business office personnel will meet regularly to identify any potential issues for noncompliance with maintenance of effort and develop a plan accordingly to ensure compliance is met. Staff training and utilization of the calculation tools provided by TEA will be provided to ensure all involved gain the necessary understanding. Responsible Contact Person: Farrah Jernigan, Chief Financial Officer Anticipated Completion Date: June 30, 2026

View Audit 389296

Finding 1175526 (2025-001)

Material Weakness 2025

Rowan County, North Carolina

NC

Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Finding 2025-001: Name of Contact Person: Joshua Stutts & Alanna Burkhart Corrective Action/Management Response: The Agency acknowledges nine instances of claims entered in EPI where adequate case documentation was not maintained. Nine case files did not include a signed form 1682. 1. The agency ack...

Finding 2025-001: Name of Contact Person: Joshua Stutts & Alanna Burkhart Corrective Action/Management Response: The Agency acknowledges nine instances of claims entered in EPI where adequate case documentation was not maintained. Nine case files did not include a signed form 1682. 1. The agency acknowledges findings of three instances of claims entered into EPI where adequate case documentation was not maintained due to staff turnover. 2. Current vacancy for Income Maintenance Investigator II position will be filled by December 1, 2025. 3. Train new staff on the revision of Program Integrity training curriculum beginning by December 31, 2025, and will be completed by June 30, 2026. A copy of the training program curriculum will be available for review. Proposed Completion Date: December 31, 2025

View Audit 389295

Finding 1175524 (2025-004)

Material Weakness 2025

St. Catherine University

MN

Student Financial Aid

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding:...

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Outdated Banner jobs have been updated. After review, the 3PELL disbursement on 08/28/2024 was not caused by human intervention. The early disbursement occurred because Automic ran during that period using the outdated RPEDISB job, which can, in rare cases, trigger a disbursement without a COD Document ID. The Pell grant did not officially originate in COD until 09/12/2024, so the disbursement technically occurred earlier than expected. This was due to the legacy process still running in Automic despite Ellucian phasing out RPEDISB. Name of the contact person responsible for corrective action: This change was made by our former IT Department, prior to contracting with our current IT Managed Services partner, Collegis Education. Going forward, any similar technical issues would fall under the leadership of our new CIO, Debra Lang. Planned completion date for corrective action plan: September 2024 If the United States Department of Education has questions regarding this schedule, please call LaNita Robinson at 651-690-7795.

View Audit 389292

Finding 1175518 (2025-003)

Material Weakness 2025

St. Catherine University

MN

Student Financial Aid

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There i...

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to have system-related issues, for example, the NSC FTP didn't accept our October report, so it was late and it took a long time for us to figure out what had happened. Also, the wrong dates were sent in fall. Our system sent summer dates during the fall semester. Student Affairs staff are now contacting students who have withdrawn in the semester to encourage them to complete a “Leave of Absence” (LOA) request if they think they will not be returning in the subsequent semester. Students have the ability to make their decision at any time. Once we are notified of an LOA, we are updating our system and sending that information to NSLDS. Name of the contact person responsible for corrective action: Kerri Vickers, Registrar. Planned completion date for corrective action plan: On-going.

View Audit 389292

Finding 1175512 (2025-003)

Material Weakness 2025

Region III Workforce Investment Board of Kanawha County, Inc.

WV

Matching / Level of Effort / Earmarking § 200.303

2025-003 EARMARKING U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of Earmarking requirements for Youth Activities, we noted that approximately 13 percent of Youth activity finds allocated to the local area, except for the local area expenditure...

2025-003 EARMARKING U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of Earmarking requirements for Youth Activities, we noted that approximately 13 percent of Youth activity finds allocated to the local area, except for the local area expenditures for administration, was used to provide paid and unpaid work experience, which is not in compliance with the provisions stated in the Uniform Grant Guidance under the WIOA Cluster for Youth Activities. Recommendation: We recommend that the Board regularly review the grant expenditures for each of its programs and activities to ensure that all requirements for earmarking within the Uniform Grant Guidance are met. Region 3 Action: the Board will conduct formal monthly reviews of all WIOA grant expenditures by program and funding stream. These reviews will compare actual expenditure to budget allocations and earmarking requirements to ensure compliance with Uniform Grant Guidance and WIOA statutory requirements. Financial staff will prepare monthly expenditure reports, which will then be reviewed and approved by the Executive Director and presented quarterly to the Finance Committee of the Board. The Finance Committee will document its review in meeting minutes. The Board believes these corrective measures strengthen internal controls and ensure ongoing compliance with federal grant requirements. We are committed to maintaining sound fiscal oversight and full adherence to all applicable WIOA and Uniform Grant Guidance requirements.

View Audit 389289

Finding 1175511 (2025-002)

Material Weakness 2025

Region III Workforce Investment Board of Kanawha County, Inc.

WV

Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2025-002 Eligibility- WIOA intake applications were not signed properly U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of WIOA participants, it was noted that for one of the six youth participants selected for testing the WIOA intake application...

2025-002 Eligibility- WIOA intake applications were not signed properly U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of WIOA participants, it was noted that for one of the six youth participants selected for testing the WIOA intake application was not signed by the case manager. Recommendation: We recommend that the Board thoroughly review all applications for Youth Activities to ensure that all required eligibility documentation is completed and properly approved. Region 3 Action:ln direct response to this finding, the Board developed and implemented a comprehensive Youth Eligibility Policy, effective February 25, 2025. This policy establishes clear and enforceable procedures to ensure that all youth participants are properly vetted prior to receiving WIDA-funded services.Specifically, the policy includes a dedicated "Eligibility Verification" and "Documents for Verifying WIOA Eligibility" section which requires that service providers confirm each individual meets all applicable WIOA eligibility requirements including age, selective service registration and citizenship status at the time of registration. The policy further requires that each participant file contain a completed application along with supporting documentation confirming general WIOA eligibility and all applicable Youth eligibility data elements. Additionally, all questions on the intake form must be fully answered and both the applicant and the intake staff member are required to sign the intake forms prior to the delivery of services. Primary Eligibility Review is the Local Board's program staff's responsibility to ensure all registration paperwork is complete and accurate before WIOA enrollment.The Board is confident that these policy requirements provide the necessary framework and controls to ensure consistent, documented eligibility verification across all service providers administering youth activities under WIOA. The Board will continue to monitor compliance with this policy through its oversight activities to ensure the controls remain effective on an ongoing basis.

View Audit 389289

Finding 1175510 (2025-001)

Material Weakness 2025

Region III Workforce Investment Board of Kanawha County, Inc.

WV

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2025-001 REPORTING-MACC reports did not contain evidence of supervisory approval Condition: For all MACC reports selected for testing, management was unable to provide adequate support that the reports were properly reviewed and approved prior to being submitted. Recommendation: We recommend that th...

2025-001 REPORTING-MACC reports did not contain evidence of supervisory approval Condition: For all MACC reports selected for testing, management was unable to provide adequate support that the reports were properly reviewed and approved prior to being submitted. Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately in a timely fashion, with proper review and approval prior to submission. Region 3 action: Although Region 3 has established a monthly checklist that is reviewed and signed off by Brenda Hunt CPA, it is a work in progress and ad ustments will be made to reflect an additional review and approval prior to submission.

View Audit 389289

Finding 1175485 (2025-003)

Material Weakness 2025

Pathfinder Services, Inc.

IN

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties § 200.403 § 200.405

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will document the allocation methods used for employees and expenses.

View Audit 389278

Finding 1175483 (2025-002)

Material Weakness 2025

Pathfinder Services, Inc.

IN

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has implemented various approval and documentation procedures.

View Audit 389278

Finding 1175481 (2025-001)

Material Weakness 2025

Center Township Elderly Housing, Inc.

PA

HUD Housing Programs

Management will update internal procedures to ensure that RFR deposits are recorded only when cash is transferred and will review the RFR account regularly to ensure compliance with HUD requirements.

View Audit 389276

Finding 1175480 (2025-003)

Material Weakness 2025

Knox College

IL

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

Identifying Number: 2025-003 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA: • The College has performed a risk assessment utilizing internal reso...

Identifying Number: 2025-003 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA: • The College has performed a risk assessment utilizing internal resources but has not fully integrated the information security program on the results of this assessment, nor has the College included all required elements of internal and external risks to the security, confidentiality or integrity of customer information. The College’s risk assessment is in the process of implementing an inventory of IT systems that process and store customer information and the compliance with information security elements related to multifactor authentication, access control, change management, logging and alerting and encryption. • The College has not identified, designed or implemented safeguards for all of the risks identified in the risk assessment. The safeguards do not include the identification of security events the detection and response capabilities to support incident response is still being developed. • The College has not been able to test safeguards because safeguards have not been fully designed or implemented in response to the risk assessment. • The College has not developed written policies and procedures to ensure that personnel are able to enact the information security program. There is a lack of evidence of leadership being required to report to the board or an appropriate supervisory council to ensure those charged with governance are informed on the current state of the information security program. Corrective Actions Taken or Planned: 1. Integration of Risk Assessment Results • Corrective Actions Taken or Planned: Complete a new risk assessment for our new information systems and fully integrate the results including safeguards into the College’s information security program. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 2. Provide Training for Written Policies and Procedures • Corrective Actions Taken or Planned: Distribute written policies and procedures to ensure personnel can enact the information security program. Provide training to all relevant staff. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 3. Testing of Safeguards • Corrective Actions Taken or Planned: Conduct regular testing of implemented safeguards to ensure effectiveness. Document results and make improvements as needed. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 4. Comprehensive Inventory of IT Systems • Corrective Actions Taken or Planned: Update and maintain our inventory of all IT systems that process and store customer information. Ensure compliance with multifactor authentication, access control, change management, logging, alerting, and encryption requirements. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 5. Governance and Reporting • Corrective Actions Taken or Planned: Establish a formal process requiring leadership to report on the state of the information security program to the Board of Trustees and include in our security policies. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: 6/30/2026 6. GLBA Policy Enhancement • Corrective Actions Taken or Planned: Review and revise the information security policy to ensure all GLBA-required elements are included, referencing current regulatory guidance. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: 6/30/2026

View Audit 389269

Finding 1175475 (2025-002)

Material Weakness 2025

Knox College

IL

Student Financial Aid

Identifying Number: 2025-002 Finding: Disbursements to or on Behalf of Students (Credit Balances) The College did not pay the Title IV credit balances to the students directly within the required timeline noted above. Out of the 40 students tested, we noted 2 students (5%) whose credit balances were...

Identifying Number: 2025-002 Finding: Disbursements to or on Behalf of Students (Credit Balances) The College did not pay the Title IV credit balances to the students directly within the required timeline noted above. Out of the 40 students tested, we noted 2 students (5%) whose credit balances were not paid directly to the students within the required timeframe noted above. The incorrect timing did not have an effect on the total award given to students (timing only). The College did not have formally documented controls related to the process associated with disbursements to or on behalf of students (credit balances), which is required under Uniform Grant Guidance. Corrective Actions Taken or Planned: Knox College has implemented the following corrective measures to ensure compliance with federal credit balance requirements: 1. Automated Monitoring: A system-generated report (Aging Report) of all student credit balances is now produced twice per week from the Jenzabar J1 student information system. 2. Formal Workflow: The AVP of Student Financial Services (SFS) will review the Student Accounts Aging Report. Student Financial Services Advisors will review each of their student accounts that have a credit balance within 24 hours. If the student has a credit balance and has receive Title IV aid during the academic year, the advisor will review if the credit balance is derived by Title IV. A standardized credit balance processing schedule has been established, ensuring that credit balances are reviewed and released within 14 days of disbursement. Role Clarification: Responsibilities are now clearly defined: • SFS confirms refund eligibility. • Business Office processes refunds through Bill.com and posts to the student account. Staff Training: Relevant staff received training on: • Title IV credit balance requirements • Handling of student/parent authorizations • Timely return of unclaimed funds Documentation Controls: All credit balance disbursement and return transactions are documented and retained as part of the official audit record. Person Responsible: Leigh Brinson, Assistant Vice President of Student Financial Services, ltbrinson@knox.edu Anticipated Completion Date: November 10, 2025

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