Corrective Action Plans

Finding 1175262 (2025-004)

Material Weakness 2025

NJ

Eligibility Allowable Costs / Cost Principles Reporting

Condition/Finding: There were instances in which payroll timesheets and resolutions authorizing payroll expenseswere not available for review at the time of audit. Recommendation:The District should ensure that all payroll timesheets and resolutions authorizing payroll expenses are available for rev...

Condition/Finding: There were instances in which payroll timesheets and resolutions authorizing payroll expenseswere not available for review at the time of audit. Recommendation:The District should ensure that all payroll timesheets and resolutions authorizing payroll expenses are available for review at the time of audit. Method of Implementation: The district will improve the filing and retention of payroll timesheets and resolutions authorizing payroll expenses for federal programs. All payroll documentation will be properly maintained and made readily available for review at the time of audit.

View Audit 388988

Finding 1175261 (2025-003)

Material Weakness 2025

Woodbine Community School District

IA

Reporting Internal Control / Segregation of Duties

We will continue to review our procedures and implement controls when possible.

View Audit 388984

Finding 1175259 (2025-002)

Material Weakness 2025

Northeast Iowa Community College

IA

Special Tests & Provisions Student Financial Aid Significant Deficiency

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Return of Title IV Funds Significant deficiency in internal control Findi...

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Return of Title IV Funds Significant deficiency in internal control Finding Summary: One instance was identified where the amount of funds to be returned was not calculated/remitted correctly. Responsible Individuals: Randy Mashek, Financial Aid Director and Dawn Fleming, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid Office will collaborate with the full Student Services team (Advising, Registrar, Financial Aid, Finance) in order to continue a strong focus on the importance of the Return of Title IV Funds (R2T4) policy and procedures. This focus will improve the process in order to better accurately calculate R2T4s as well as communicate the importance of dates more effectively with students and staff regarding withdrawals and earned aid and the financial impacts of them. Implementation of certain measures has already begun in 2025-26 with the following steps: 1. Return of Title IV Funds (R2T4) calculations in real time as students withdraw from classes throughout the semester. Cross training for the administration staff processing withdrawals was implemented over the past two years. A checks and balances system are now in place to alert the Assistant Director and Director of Financial Aid whenever a complete withdrawal is made. Once the notification is made the Assistant Director reviews, calculates and processes the R2T4. The Director will perform a monthly quality sampling throughout the semester in order to review and test R2T4 calculations for accuracy and document when that happens. This process was in practice as the Assistant Director was being trained by the Director over the past year and now, we will begin to formalize that process as well as document each instance and build it into the workflow starting with the spring 2026 semester. 2. Additionally, ongoing training for R2T4 rules and regulations is completed throughout the year through our state and national associations (NASFAA and IASFAA) by the Assistant Director and Director as well as webinar and training from Federal Student Aid (FSA). From these trainings we will continue to share with Advising and support staff in order to educate and train them on the implications of withdrawals and the importance of earned aid dates, modular classes, class start and end dates, and college breaks that all impact the calculation of days in the R2T4 process and communication. Anticipated Completion Date: Ongoing. Fully functional with the start of 2026-27 year

View Audit 388965

Finding 1175253 (2025-001)

Material Weakness 2025

Northeast Iowa Community College

IA

Special Tests & Provisions Student Financial Aid Material Weakness

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Material Weakness in Internal Control Finding Summar...

Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing #: 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Material Weakness in Internal Control Finding Summary: During testing of compliance for Enrollment Reporting, there were 9 instances out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time frame of 60 days from the effective date of the student’s change in enrollment status. Responsible Individuals: Karla Winter, Registrar and Randy Mashek, Financial Aid Director Corrective Action Plan: The Registrar’s Office will collaborate with the Financial Aid Office to provide oversight to the Enrollment Reporting process. Oversight includes timely batch reporting of student enrollment statuses to the National Student Clearinghouse (NSC) for all periods of enrollment, NSC Error Report review and resolution between NICC’s internal Student Information System (Colleague) with the National Student Loan Data System (NSLDS), as well as having documented policies and procedures in place in order to administer, implement and comply with the full scope of Enrollment Reporting on an ongoing basis. The Policies and Procedures will address the previously recommended requirement of the Registrar’s Office to conduct and retain evidence of quality sampling once a semester. Implementation of certain measures has already begun in 2025-26 with the following steps: 1. The Registrar implemented a new reporting schedule with NSC to capture the Winterim semester (which is part of the spring financial aid semester) to accurately reflect the enrollment from that special mini session. This was implemented for the Winterim 2025 session (December 2025-January 2026) and reporting began 1/9/2026. 2. The Financial Aid Office is implementing a new system to review and resolve NSC Error Reports (NSLDS SSCR) beginning with the spring 2026 semester. These reports are provided by the Registrar, and produced by NSC after each enrollment submission. The Financial Aid staff will review Colleague and NSLDS records in order to determine corrective action in the required timeframe and then provide enrollment changes to NSC to have the student’s NSLDS record updated with accurate information. 3. NSC will update NICC’s reporting codes from the current two branches (00 Calmar and 01 Peosta) to a single reporting branch (00) beginning with the fall 2026 semester (2026-27 academic year). This change will align with recent updates over the past few years from two individual school codes (Calmar and Peosta) to just one code with several Federal Student Aid (FSA) systems. These systems include Student Loan origination at the Common Origination & Disbursement Web Site (COD), FSA Partner Connect as well as the Free Application for Federal Student Aid (FAFSA) school codes. The decision to transition from two codes to one in many reporting areas was made in order to reduce student confusion between campuses when completing the FAFSA, reduce reporting inefficiencies and errors, as well as streamline multiple reporting challenges for federal and state aid reporting. The actual process presented many challenges for NICC and FSA and was implemented over the past two years successfully. However, the transition did not include the enrollment reporting side with NSC/NSLDS which has been the source of many of our multiple student record errors. Anticipated Completion Date: Ongoing. Fully functional with the start of 2026-27 year.

View Audit 388965

Finding 1175247 (2025-004)

Material Weakness 2025

Bay Cove Human Services, Inc. & Affiliate

MA

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

Management acknowledges that certain internal controls did not operate effectively during the year ended June 30, 2025. Management is in the process of implementing additional controls to ensure a stable control environment that supports compliance with cash management and special tests and provisio...

Management acknowledges that certain internal controls did not operate effectively during the year ended June 30, 2025. Management is in the process of implementing additional controls to ensure a stable control environment that supports compliance with cash management and special tests and provisions requirements.

View Audit 388951

Finding 1175246 (2025-003)

Material Weakness 2025

Bay Cove Human Services, Inc. & Affiliate

MA

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring

Management acknowledges that certain internal controls did not operate effectively during the year ended June 30, 2025. Management is in the process of implementing additional controls to ensure a stable control environment that complies with procurement requirements.

View Audit 388951

Finding 1175245 (2025-002)

Material Weakness 2025

Bay Cove Human Services, Inc. & Affiliate

MA

Subrecipient Monitoring Internal Control / Segregation of Duties

Management acknowledges that certain internal controls did not operate effectively during the year ended June 30, 2025. Management is in the process of implementing additional controls to ensure a stable control environment that supports accurate and timely financial reporting in future periods.

View Audit 388951

Finding 1175244 (2025-001)

Material Weakness 2025

Iona College

NY

Student Financial Aid Reporting

FINDING 2025-001 Name of Responsible Individual: Daniel Arndt, Registrar Corrective Action: Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. We also acknowledge that this is technically a repeat findi...

FINDING 2025-001 Name of Responsible Individual: Daniel Arndt, Registrar Corrective Action: Management acknowledges the finding regarding the inaccurate reporting of student data elements under the Program-Level record on the NSLDS website. We also acknowledge that this is technically a repeat finding from the prior year; however, the finding identified for one student out of the forty students selected was prior to the implementation of the University’s Corrective Action Plan on January 31, 2025. The University previously addressed this issue and implemented a corrective action plan that included updating our reporting frequency and enhancing our data review processes as follows: Updated Reporting Frequency: As of January 2025, the University now includes the non-compulsory terms, summer 1 and winter sessions, in its reporting. The previous institutional practice did not include reporting program-level data for these terms given that said terms do not involve federal financial aid. This change ensures that all program-level data, regardless of federal financial aid involvement, is accurately reported. Secondary Check Process: Each month, the Compliance Officer reviews a sample of 100 students from NSLDS to verify significant data elements, including program enrollment effective dates. After the initial review, the Compliance Officer summarizes the findings and shares them with the Associate Registrar and Registrar for a secondary review. Any necessary edits are made, followed by a review of an additional 25 students to ensure accuracy. We believe the corrective action steps are critical in ensuring accurate reporting and preventing this issue in the future, and we believe they have been effectively implemented. We believe that the fact that only one of forty students selected was reported incorrectly is an indication that our corrective action plan has been effective. Completion Date: January 31, 2025

View Audit 388945

Finding 1175243 (2025-001)

Material Weakness 2025

San Miguel Joint Union School District

CA

Cash Management Significant Deficiency Internal Control / Segregation of Duties

This district has implemented a process where meal counts are reviewed and verified by the Business Office. Each month the business office receives a copy of the meal claim along with all backup with meal counts. The business office reviews the meal counts, verifies the totals and then verifies that...

This district has implemented a process where meal counts are reviewed and verified by the Business Office. Each month the business office receives a copy of the meal claim along with all backup with meal counts. The business office reviews the meal counts, verifies the totals and then verifies that the totals match the claim for reimbursement. Any discrepancies found are reported to the Cafeteria Manager for corrections to be made to the claim reimbursement.

View Audit 388928

Finding 1175224 (2025-002)

Material Weakness 2025

Ide Center Apartments Ii, Inc. 042-Hd045

OH

Internal Control / Segregation of Duties HUD Housing Programs Material Weakness

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Unadjusted Rental Rates Recommendation: Adjust rental rates immediately, and request adjustment on next HAP Voucher to begin repayment. Ensure proper training of employees, prepare the budget worksheet as soon as possib...

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Unadjusted Rental Rates Recommendation: Adjust rental rates immediately, and request adjustment on next HAP Voucher to begin repayment. Ensure proper training of employees, prepare the budget worksheet as soon as possible and promptly read all correspondence for HUD and forward to management company. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Amounts will be adjusted over the next few HAP voucher to repay HUD and adjust rental rates on the next voucher. Name(s) of the contact person(s) responsible for corrective action: Stacy Lawson, CFO Planned completion date for corrective action plan: June 30, 2026

View Audit 388921

Finding 1175222 (2025-001)

Material Weakness 2025

Casa Santa Maria

CA

HUD Housing Programs

Management’s Response – Management acknowledges the error and agrees to the amount owed for the overpayment of property management fees and have updated their procedures to ensure future compliance. The Project was reimbursed for the overpayment as of the independent auditor’s report date.

View Audit 388916

Finding 1175216 (2025-002)

Material Weakness 2025

Mannheim School District 83

IL

Internal Control / Segregation of Duties

Corrective Action Plan Finding No. 2025-002 Unsupported claimed expenditures Condition – The District claimed expenditures in excess of amounts that could be supported by the Accounting records by $77,940. Plan – The District will implement a policy that aligns grant expenditures as closely as possi...

Corrective Action Plan Finding No. 2025-002 Unsupported claimed expenditures Condition – The District claimed expenditures in excess of amounts that could be supported by the Accounting records by $77,940. Plan – The District will implement a policy that aligns grant expenditures as closely as possible with the District’s fiscal year. Reports from the accounting software system that are utilized to prepare expenditure claims will be reviewed, reconciled, and approved by an appropriate member of management prior to final submission. Supporting documentation for each grant expenditure claim submission will be maintained electronically for future reference. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Christopher Whelton, Director of Fiscal Services/CSBO

View Audit 388895

Finding 1175212 (2025-001)

Material Weakness 2025

Baker University

KS

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Management is responsible for establishing and maintaining effective internal controls over compliance under Uniform Guidance. Personnel Responsible for Corrective Action Plan: Jana Parks, Student Financial Aid Director, and Melissa VanLeiden, Chief Accounting Officer. Anticipated Completion Date: T...

Management is responsible for establishing and maintaining effective internal controls over compliance under Uniform Guidance. Personnel Responsible for Corrective Action Plan: Jana Parks, Student Financial Aid Director, and Melissa VanLeiden, Chief Accounting Officer. Anticipated Completion Date: The corrective action plan will be implemented by June 30, 2026. Corrective Action Plan: We have re-established automated enrollment report generation through our SIS, which is now configured to generate enrollment reports for submission to the National Student Clearinghouse (NSC). Before current reports can be submitted, we are required to submit manually created enrollment reports for each missed reporting period from December 2024 through December 2025. Preparation of these reports is currently underway, and we expect to resume submissions on our established enrollment reporting schedule no later than the end of the Spring 2026 semester.

View Audit 388894

Finding 1175210 (2025-001)

Material Weakness 2025

Upper Iowa University

IA

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Upper Iowa University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: Of the 25 students tested, one student was not reported to NSLDS. There is an issue with the student’s record in NSLDS stemming from information reported by a prior school. The University is rep...

Upper Iowa University Corrective Action Plan For the Year Ended June 30, 2025 Finding 2025-001 Condition: Of the 25 students tested, one student was not reported to NSLDS. There is an issue with the student’s record in NSLDS stemming from information reported by a prior school. The University is reporting information to the National Student Clearinghouse (NSC) servicer but the information is failing to link up to their NSLDS record resulting in her record ultimately not being reported. Corrective Action Plan: Although the University is not able to prevent or resolve rejected records directly when they occur for this reason, we can provide additional information to the Clearinghouse that may allow them to resolve the issue. This sometimes requires requesting that the student provide additional documents and/or submitting information to the Clearinghouse for their review. Rejected records are reviewed by the University after each submission. In addition to this initial review, we have added additional reject tracking in our database. This allows us to better monitor and follow up on records with this issue while we wait for needed information or for the Clearinghouse to review additional information we have submitted. Completion Date: 9/17/2025 Name(s) of Contact Person(s) Responsible for Corrective Action: Jill Austin, CRM Administrator

View Audit 388889

Finding 1175205 (2025-001)

Material Weakness 2025

Kingsburg Elementary Charter School District

CA

School Nutrition Programs Procurement, Suspension & Debarment

Finding Identification: 2025 – 001 Federal – Child Nutrition Cluster #50000 Name of contact person: Bricki McNulty Corrective Action: Upon identification of the finding, the Child Nutrition Director immediately contacted the Tri-County Co-op to obtain the formal "Buy American" certification and stat...

Finding Identification: 2025 – 001 Federal – Child Nutrition Cluster #50000 Name of contact person: Bricki McNulty Corrective Action: Upon identification of the finding, the Child Nutrition Director immediately contacted the Tri-County Co-op to obtain the formal "Buy American" certification and statement for the 2024-25 school year. Upon discovery that a formal statement was not currently on file from the vendors for that specific period, the SFA took proactive measures to secure the appropriate certification for the 2025-26 school year to ensure immediate and future compliance. To prevent a recurrence of this finding, the Child Nutrition Director will be responsible for verifying and obtaining the updated "Buy American" certification from the Tri-County Co-op at the start of every school year. The School Food Authority (SFA) remains committed to purchasing domestic commodities and products to the maximum extent practicable. To support this, the Child Nutrition Director will oversee the continued use of the Buy American Exception Log. This log will be used to document any non-domestic items—such as bananas or other seasonal fruits not grown in the U.S. in sufficient quantities—including the specific justification (availability or price) for each exception. By integrating these steps into our annual administrative calendar, the SFA ensures that all food served in the National School Lunch and Breakfast Programs meets the domestic requirements mandated by 7 CFR 210.21(d). Proposed Completion Date: September 2025

View Audit 388875

Finding 1175204 (2025-002)

Material Weakness 2025

City of Owensville, Missouri

MO

Procurement, Suspension & Debarment § 200.214

The City agrees with the finding and will revise its procurement procedures and train staff to ensure verification is completed and retained for all federally funded procurements.

View Audit 388871

Finding 1175203 (2025-002)

Material Weakness 2025

Dickinson Public School District No. 1

ND

Allowable Costs / Cost Principles

Contact Person Naomi Obrigewitch, Accounting Manager Corrective Action Plan The current process of completing the annual IDEA, Part B budget along with the corresponding time and effort certifications were reviewed by Naomi Obrigewitch and the grant director, Sheri Twist, Director of Student Service...

Contact Person Naomi Obrigewitch, Accounting Manager Corrective Action Plan The current process of completing the annual IDEA, Part B budget along with the corresponding time and effort certifications were reviewed by Naomi Obrigewitch and the grant director, Sheri Twist, Director of Student Services. It was realized that an additional step of communication between the director and the grant specialist who processes the time and effort certifications needs to happen at the beginning of the fiscal year when the budget is created. The director will ensure the IDEA, Part B salary breakdown is forwarded to both the grant specialist and the payroll manager. This will ensure the federal grant guidelines are met. Completion Date On-going

View Audit 388851

Finding 1175201 (2025-006)

Material Weakness 2025

Lennox School District

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

The District is updating the contract templates to include the missing federal provisions identified by the auditors. Additional training will be provided to all staff involved in federal program management and procurement.

View Audit 388845

Finding 1175198 (2025-005)

Material Weakness 2025

Lennox School District

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

The District has implemented new procedures to ensure time and effort reporting is completed timely and accurately. In addition, all journal entries will be reviewed prior to posting to ensure the expenditures are allowable to the program.

View Audit 388845

Finding 1175195 (2025-008)

Material Weakness 2025

Lennox School District

CA

Subrecipient Monitoring Material Weakness Reporting

District is committed to strengthening internal controls and has already begun implementing procedures such as reporting actuals only and retaining the records in a centralized place with back up documents to ensure compliance with the CARES Act and 2 CFR 200.333.

View Audit 388845

Finding 1175193 (2025-007)

Material Weakness 2025

Lennox School District

CA

Equipment & Real Property Management

The District will implement a new asset management software program and will also conduct a district-wide physical inventory starting in the Spring of 2026 In addition, the Business Office will implement a new review process to ensure compliance with 2 CFR §200.313.

View Audit 388845

Finding 1175192 (2025-001)

Material Weakness 2025

Keystone College

PA

Student Financial Aid Reporting

The records in the student sample that were tested were from the Fall semester 2024. In addition to strengthening controls and staff training, the College completed an internal audit on 4/30/25 of all student accounts to ensure compliance with cash management practices for future federal awards and ...

The records in the student sample that were tested were from the Fall semester 2024. In addition to strengthening controls and staff training, the College completed an internal audit on 4/30/25 of all student accounts to ensure compliance with cash management practices for future federal awards and corrected any findings. As a means of maintaining compliance under the Heightened Cash Monitoring 1 Payment Method (HCM1) as described under 34 C.F.R. § 668.162(d)(1), Keystone first makes disbursements to eligible students and parents and pays any remaining credit balances before it requests or receives funds for the amount of those disbursements from the Department. The College’s practices and internal controls for Title IV, HEA program funds received from the Department reflect the compliance criteria as required.

View Audit 388821

Finding 1175190 (2025-003)

Material Weakness 2025

Columbus Community Clinical Oncology Program

OH

Procurement, Suspension & Debarment

Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : Per the compliance requirements, transactions should be made only with the vendors who are not suspended or debarred. Condition : Out of 8 vendors tested, we noted that there was no proper documentation maintained...

Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : Per the compliance requirements, transactions should be made only with the vendors who are not suspended or debarred. Condition : Out of 8 vendors tested, we noted that there was no proper documentation maintained for eight vendors showing that the vendor was not suspended or debarred. Management’s Response : Columbus NCORP acknowledges vendors were not confirmed to have not been suspended or debarred. Columbus NCORP is updating its internal policies to clearly include this requirement so that all future purchases meeting this requirement are properly documented and compliant with grant guidelines. Columbus NCORP staff directly responsible for grant management will also continue to attend training sessions to strengthen their knowledge of grant reporting, grant requirements, and compliance responsibilities. Anticipated Completion Date: January 31, 2026

View Audit 388818

Finding 1175189 (2025-002)

Material Weakness 2025

Columbus Community Clinical Oncology Program

OH

Internal Control / Segregation of Duties

Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : All deposits should be supported by detailed documentation, properly recorded and retained as per the internal controls in place in the organization. Condition : Detailed supporting documentation was not found for...

Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : All deposits should be supported by detailed documentation, properly recorded and retained as per the internal controls in place in the organization. Condition : Detailed supporting documentation was not found for three sampled deposits and three other deposits could not be traced to bank statements. Management’s Response : Columbus NCORP will retain all support for cash receipts moving forward. Anticipated Completion Date: January 31, 2026

View Audit 388818

Finding 1175188 (2025-001)

Material Weakness 2025

Columbus Community Clinical Oncology Program

OH

Internal Control / Segregation of Duties

Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : Cash disbursements should be approved and reviewed as per the internal controls in place in the organization and the related documentation should be retained. Condition : No supporting documentation could be locat...

Information on the Federal Program : ALN – 93.399 – Cancer Control Research Criteria : Cash disbursements should be approved and reviewed as per the internal controls in place in the organization and the related documentation should be retained. Condition : No supporting documentation could be located for three of the expenses selected for testing. Management’s Response : Columbus NCORP will retrain all support for cash disbursements moving forward. Anticipated Completion Date: January 31, 2026

View Audit 388818

Corrective Action Plans

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