Corrective Action Plans

Finding 1180931 (2025-013)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring § 200.303 § 200.332

Corrective action plan: TANF/SEGIF: To ensure that correct UEIs are included on all Early Childhood Initiatives (ECI) contracts, the Early Childhood Initiatives (ECI) program has implemented a review system of the contracts and amendments prior to routing them through CAPPS FIN. The contract develop...

Corrective action plan: TANF/SEGIF: To ensure that correct UEIs are included on all Early Childhood Initiatives (ECI) contracts, the Early Childhood Initiatives (ECI) program has implemented a review system of the contracts and amendments prior to routing them through CAPPS FIN. The contract developer will create the document, and the assigned performance specialist will review the data included in the contract/amendment to ensure it is accurate before the contract is routed for approval. SUBG: Behavioral Health Services’ pass-through agreements effective September 1, 2026, will include 2 CFR §200.332 requirements. Implementation dates: TANF/SEGIF: September 1, 2025 SUBG: December 31, 2026 Responsible persons: TANF/SEGIF: Janene Roch, Manager, ECI Contracts and Finance SUBG: Roderick Swan, Associate Commissioner, Behavioral Health Services Operations

View Audit 392506

Finding 1180922 (2025-005)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking

Corrective action plan: HHSC will discuss and make a decision on submitting a waiver request for the 10% setaside requirement. Implementation date: September 1, 2026 Responsible person: Roderick Swan, Associate Commissioner, Behavioral Health Services Operations

View Audit 392506

Finding 1180919 (2025-004)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Cash Management § 200.303

Corrective action plan: HHSC will run quarterly expenditure reports for this grant to monitor administrative earmarking thresholds. Implementation date: July 31, 2026 Responsible person: Roderick Swan, Associate Commissioner, Behavioral Health Services Operations

View Audit 392506

Finding 1180912 (2025-007)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Reporting Significant Deficiency § 200.303

Corrective action plan: HHSC implemented a final review by all agencies who receive SSBG funding and all HHSC staff. In the future, the federal funds office will coordinate efforts with the Federal Reporting personnel to ensure the amounts noted on the ACF-196 report are consistent with the amount o...

Corrective action plan: HHSC implemented a final review by all agencies who receive SSBG funding and all HHSC staff. In the future, the federal funds office will coordinate efforts with the Federal Reporting personnel to ensure the amounts noted on the ACF-196 report are consistent with the amount on the Post Expenditure Report. Implementation date: March 30, 2026 Responsible person: Racheal Kane, Director, Federal Funds Office

View Audit 392506

Finding 1180910 (2025-001)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

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

Corrective action plan: ITS will: • Work with HR and Security to analyze and validate the size and scope of the late submission of access termination requests for separated employees. Communicate the analysis results and recommendations on or before May 1, 2026. • Work with the Information Security ...

Corrective action plan: ITS will: • Work with HR and Security to analyze and validate the size and scope of the late submission of access termination requests for separated employees. Communicate the analysis results and recommendations on or before May 1, 2026. • Work with the Information Security Office for continuation of periodic reconciliation of HR data and network accounts. Schedule for reconciliation to be established on or before May 1, 2026. • Work with Human Resources to establish a schedule of periodic reconciliation for HR data and case management application accounts. Schedule for reconciliation to be established on or before May 1, 2026. • Review existing business process for offboarding separated employees and provided recommendations to HR for training and communication for staff. Recommendations to be provided by May 1, 2026. • Determine what technology solution may be needed by August 31, 2026, with consideration of effectiveness of mitigation actions, as noted above. Implementation dates: See Corrective action plan Responsible person: Angie Lindemann, Deputy Chief Information Officer

View Audit 392506

Finding 1180909 (2025-018)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Corrective action plan: Program staff will ensure that a formal review by the Team Lead and the Manager of Fiscal and Reporting is completed prior to submission. The Team Lead will initiate the process by obtaining the obligation amount from the LIHEAP Contract Specialist and entering the amount int...

Corrective action plan: Program staff will ensure that a formal review by the Team Lead and the Manager of Fiscal and Reporting is completed prior to submission. The Team Lead will initiate the process by obtaining the obligation amount from the LIHEAP Contract Specialist and entering the amount into the quarterly report. The Manager of Fiscal and Reporting will review and confirm the amount to be submitted. Implementation date: April 30, 2026 Responsible persons: Michael De Young, Director of Community Affairs Cathy Jung, Senior Manager of Finance and Reporting

View Audit 392506

Finding 1180907 (2025-017)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Cash Management Significant Deficiency Internal Control / Segregation of Duties § 200.303

Corrective action plan: The Department will enhance current procedures for the compilation and review of the Period 1 clearance pattern calculation in accordance with the Cash Management Improvement Act (CMIA) and as required in the Texas-State Agreement. The Manager of Accounting will use the State...

Corrective action plan: The Department will enhance current procedures for the compilation and review of the Period 1 clearance pattern calculation in accordance with the Cash Management Improvement Act (CMIA) and as required in the Texas-State Agreement. The Manager of Accounting will use the State Auditor Office’s template spreadsheet provided to agencies to calculate their annual Period 1 calculation and retain the worksheet as supporting documentation. The Director of Financial Administration will review the spreadsheet and calculation prior to CMIA certification. Implementation date: August 2026 Responsible persons: Jose Guevara, Director of Financial Administration Cristina Ortega, Manager of Accounting.

View Audit 392506

Finding 1180905 (2025-021)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Reporting Special Tests & Provisions Significant Deficiency § 200.303

Corrective action plan: Vendor System Safeguards: TWC's I3 (Department of Analytics & Evaluation), IT (Information Technology), and WFA (Workforce Automation) resources will require our WorkInTexas.com vendor, Geographic Solutions Inc (GSI), to implement additional system safeguards to prevent the d...

Corrective action plan: Vendor System Safeguards: TWC's I3 (Department of Analytics & Evaluation), IT (Information Technology), and WFA (Workforce Automation) resources will require our WorkInTexas.com vendor, Geographic Solutions Inc (GSI), to implement additional system safeguards to prevent the duplication of hour entries when extracting data from the WIT system and creating files. TWC resources will maintain oversight of the implementation and ongoing effectiveness of these safeguards. Joint Anomaly Detection: TWC's I3 (Department of Analytics & Evaluation), IT (Information Technology), and WFA (Workforce Automation) resources will require our WorkInTexas.com vendor, Geographic Solutions Inc (GSI), to establish automated validation checks to identify anomalies such as duplicate lines, unexpected variances, and irregular hour totals prior to ingesting vendor files into TWC systems. TWC resources will maintain oversight of the implementation and ongoing effectiveness of these validation checks. TWC IT Data Reconciliation: TWC IT (Information Technology) will enhance supervisory review vendor procedures to reconcile data received from third-party vendors against source records, verifying completeness and accuracy before supplying to I3 (Department of Analytics & Evaluation) for inclusion in federal reporting. Implementation date: December 31, 2026 Responsible persons: Greg Waugh, Director, Workforce Automation (WFA), TWC Richard Yashewski, Director, IT Maintenance & Operations, TWC Geoffrey Miller, Director, Department of Analytics & Evaluation (I3), TWC

View Audit 392506

Finding 1180899 (2025-010)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

Corrective action plan: HHSC will conduct an end-to-end review of the sanctions process to identify and implement any needed changes to the business process, training, or system. Implementation date: May 31, 2026 Responsible person: Carrie Robertson, Manager, Strategy and Innovation–Business Integra...

Corrective action plan: HHSC will conduct an end-to-end review of the sanctions process to identify and implement any needed changes to the business process, training, or system. Implementation date: May 31, 2026 Responsible person: Carrie Robertson, Manager, Strategy and Innovation–Business Integration and Support

View Audit 392506

Finding 1180893 (2025-008)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.329

Corrective action plan: HHSC has taken steps to improve the consistency and reliability of financial reporting related to Maintenance of Effort (MOE) expenditures, specifically, amounts reported on the ACF 204, submitted by HHSC Budget and the ACF 196R, submitted by HHSC Federal Reporting (FR). To a...

Corrective action plan: HHSC has taken steps to improve the consistency and reliability of financial reporting related to Maintenance of Effort (MOE) expenditures, specifically, amounts reported on the ACF 204, submitted by HHSC Budget and the ACF 196R, submitted by HHSC Federal Reporting (FR). To address potential discrepancies and strengthen internal controls, HHSC Federal Reporting has implemented and documented a formal reconciliation process. This process involves the following key components: • Implementation and documentation of a formal reconciliation process that compares all MOE expenditures for HHSC, TEA, and TWC reported on the ACF 204 to those reported on the ACF 196R before report submission. The process outlines specific steps for data cross-referencing and validation to ensure completeness and accuracy. • Research, resolve, and correct any discrepancies identified during the reconciliation process before the reports are finalized and submitted for management review. • Reinforcement of management review and documentation of the reconciliation between the ACF-204 and ACF-196R will be incorporated into the approval process prior to report certification. Implementation date: February 28, 2026 Responsible person: Alan Flynn, Manager, Federal Reporting

View Audit 392506

Finding 1180880 (2025-019)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Corrective action plan: THECB ITS will: • Develop and implement a standardized process for all user access reviews, including a required template which documents review date, reviewer identity, scope, results, and remediation actions. • Maintain all documentation in a centralized location on our ITS...

Corrective action plan: THECB ITS will: • Develop and implement a standardized process for all user access reviews, including a required template which documents review date, reviewer identity, scope, results, and remediation actions. • Maintain all documentation in a centralized location on our ITS SharePoint site. • Implement regular monitoring to ensure reviews are performed time, and the proper documentation is retained. • We will seek to automate processes where possible. Implementation date: July 1, 2026 Responsible person: Layla Young, Brian Nolte, Joel Anguiano

View Audit 392506

Finding 1180877 (2025-015)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303 § 200.317 § 200.318 § 200.327

Corrective action plan: TCEQ will provide targeted training to program staff on federal procurement requirements, including the necessity of coordinating all purchases through the Procurements & Contracts Section and completing required vendor compliance checks. Training will emphasize procedures fo...

Corrective action plan: TCEQ will provide targeted training to program staff on federal procurement requirements, including the necessity of coordinating all purchases through the Procurements & Contracts Section and completing required vendor compliance checks. Training will emphasize procedures for sole source or limited source procurements and reinforce staff responsibilities under 2 CFR procurement and internal control standards. Regular refresher sessions and documented guidance will help ensure consistent understanding and adherence to required procurement practices across all program areas. Implementation date: May 31, 2026 Responsible person: Yolanda Davis, Deputy Director, Financial Administration Division

View Audit 392506

Finding 1180876 (2025-002)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

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

Corrective action plan: ITS Management will establish a formal, documented user access review program applicable to both privileged and non-privileged network users. Key actions include: 1. Policy Updates: Revise information technology access control policies and procedures to re-quire periodic (at ...

Corrective action plan: ITS Management will establish a formal, documented user access review program applicable to both privileged and non-privileged network users. Key actions include: 1. Policy Updates: Revise information technology access control policies and procedures to re-quire periodic (at least annual) reviews of all network user access. 2. Standardized Process and Documentation: Implement a consistent, documented review process and maintain records in a centralized repository to ensure accountability and auditability. 3. Monitoring and Oversight: Implement oversight procedures to track completion of access re-views and remediation of identified issues, with reporting to IT and information security leadership to support governance. Implementation dates: 1. Policy and procedure updates: Expected completion by April 30, 2026 2. Standardized process and repository implementation: Expected completion by May 31, 2026 3. First completed annual review under the revised process: Expected completion by June 30, 2026 Responsible persons: Tara Mitchell, Director of IT Operations Sean Peterson, Chief Information Officer

View Audit 392506

Finding 1180875 (2025-020)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Internal Control / Segregation of Duties § 200.303

Corrective action plan: TWC will establish a new policy of 3 defined roles (preparation, review, and approval) and a standardized process for each role on each report. TWC will establish a log to capture the name and date of the staff completing each role for each report, and we will use the log to ...

Corrective action plan: TWC will establish a new policy of 3 defined roles (preparation, review, and approval) and a standardized process for each role on each report. TWC will establish a log to capture the name and date of the staff completing each role for each report, and we will use the log to confirm that no individual performs more than one role on a given report. For all staff with any participation in the ETA reporting function, TWC will have training on the new policy, procedures and log. Implementation date: June 30, 2026 Responsible person: Terri Warren, Unemployment Insurance Administration & Operational Support Department Director

View Audit 392506

Finding 1180873 (2025-014)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Corrective action plan: A formalized process will be implemented, utilizing Standard Operating Procedures, to cover changes of hardware or software in relationship with network and infrastructure components. A change management tracking and approval system is under development that will be utilized ...

Corrective action plan: A formalized process will be implemented, utilizing Standard Operating Procedures, to cover changes of hardware or software in relationship with network and infrastructure components. A change management tracking and approval system is under development that will be utilized to track and provide audit logs of all network and infrastructure changes. Implementation date: August 31, 2026 Responsible person: Lars Hjaltman, CIO

View Audit 392506

Finding 1180872 (2025-016)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Corrective action plan: • IT will coordinate with HR on strengthening the separation process, to include HR running separation reports quarterly and sending to IT to cross check. Will perform regular scheduled meetings to discuss the separation process/issues. • IT is testing automatic scripts that ...

Corrective action plan: • IT will coordinate with HR on strengthening the separation process, to include HR running separation reports quarterly and sending to IT to cross check. Will perform regular scheduled meetings to discuss the separation process/issues. • IT is testing automatic scripts that will aid in the process and will be implemented this year. • IT will document quarterly access reviews which are already done. • IT will work on enhancing automation and controls; Will utilize AI to assist. Implementation date: May 2026 Responsible person: Chris Bunton, CIO, Texas Department of Agriculture

View Audit 392506

Finding 1180855 (2025-001)

Material Weakness 2025

Catawba County, North Carolina

NC

Significant Deficiency Internal Control / Segregation of Duties

Finding: 2025-001 Name of Contact Person: Karen Harrington, DSS Director Corrective Action/Management’s Response: Agency agrees with finding. Corrective Action taken/to be taken below: Corrective Action: The Department will strengthen internal controls related to workstation security to prevent unat...

Finding: 2025-001 Name of Contact Person: Karen Harrington, DSS Director Corrective Action/Management’s Response: Agency agrees with finding. Corrective Action taken/to be taken below: Corrective Action: The Department will strengthen internal controls related to workstation security to prevent unattended access to state systems. Effective immediately, all DSS employees with access to state eligibility systems are required to lock their workstation when away from their desk or log out of the system entirely. Implementation Steps: 1. Policy Reinforcement: DSS management will reissue written guidance to all staff reminding them of the requirement to lock or log out of workstations when unattended, consistent with the DSS Fiscal Manual and county IT security standards. 2. Mandatory Staff Acknowledgment: All DSS employees with state system access will complete a brief acknowledgment confirming understanding of workstation security requirements. 3. IT Controls: In coordination with the County IT Department, automatic screen-lock settings will be verified on all DSS workstations accessing state systems. 4. Monitoring and Verification: Supervisors will conduct periodic unannounced walkthroughs to verify compliance with workstation security requirements. Results will be documented and reviewed by DSS management. 5. Corrective Follow-Up: Any noncompliance identified will be addressed promptly through retraining and, if necessary, progressive disciplinary action. Responsible Party: DSS Director, DSS Program Managers, and County DSS Staff Anticipated Completion Date: Immediately upon issuance of this CAP; monitoring will be ongoing. Plan to Prevent Recurrence: Ongoing supervisory monitoring, documented compliance checks, and annual refresher training will be used to ensure continued adherence to workstation security requirements.

View Audit 392499

Finding 1180848 (2025-001)

Material Weakness 2025

Pace University

NY

Equipment & Real Property Management § 200.313

Management is currently in the process of conducting a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero in accordance with 2 CFR sections 200.313(c) through (e). The inventory process will be reviewed by management to ensure timely, accu...

Management is currently in the process of conducting a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero in accordance with 2 CFR sections 200.313(c) through (e). The inventory process will be reviewed by management to ensure timely, accurate completion. Going forward, the University will tag all new assets acquired using federal funds. In addition, a revised policy has been established relating to an annual physical inventory of federally purchased equipment to facilitate compliance and increase related inventory controls. The revised policy includes, among other details, standard requirements for inventory tagging and related monitoring.

View Audit 392494

Finding 1180827 (2025-003)

Material Weakness 2025

La Roche University

PA

Student Financial Aid

Condition The Federal Pell Grant for one student out of 27 sampled was calculated incorrectly, and the student received excess aid. Corrective Action Plan La Roche University concurs with the finding. The Office of Financial Aid has implemented enhanced controls to ensure accurate Federal Pell Grant...

Condition The Federal Pell Grant for one student out of 27 sampled was calculated incorrectly, and the student received excess aid. Corrective Action Plan La Roche University concurs with the finding. The Office of Financial Aid has implemented enhanced controls to ensure accurate Federal Pell Grant calculations in accordance with Title IV regulations and U.S. Department of Education Pell Grant payment and disbursement guidance. Immediate Correction of Identified Error The affected student’s Pell Grant award was recalculated using the correct Scheduled Pell amount and enrollment intensity. The overaward was resolved in accordance with federal overpayment and reconciliation requirements, and the Common Origination and Disbursement (COD) system was updated accordingly. Pell Calculation Verification Control A mandatory secondary review process has been implemented for all Pell-eligible students prior to disbursement to prevent future occurrences noted in this finding. This control collectively mitigates the risk of recurrence and strengthen institutional compliance with federal eligibility and disbursement requirements. Name(s) of Contact Person(s) Responsible for Corrective Action • Lawrence Britton, Executive Director of Financial Aid • Ron Elmore, Associate Director of Financial Aid Anticipated Completion Date All corrective actions were implemented as of February 9, 2026.

View Audit 392486

Finding 1180826 (2025-002)

Material Weakness 2025

La Roche University

PA

Student Financial Aid HUD Housing Programs Matching / Level of Effort / Earmarking

Condition The federal aid disbursed resulted in a credit balance for one of the 25 students tested were not returned within 14 days of the date the credit balance occurred. Corrective Action Plan La Roche University concurs with the finding. The University’s procedures did not allow for timely payme...

Condition The federal aid disbursed resulted in a credit balance for one of the 25 students tested were not returned within 14 days of the date the credit balance occurred. Corrective Action Plan La Roche University concurs with the finding. The University’s procedures did not allow for timely payment of the funds to the student due to holidays that occurred. The Office of Student Accounts has implemented enhanced controls to ensure that credit balances are reviewed and issued refunds in a timely manner. Name(s) of Contact Person(s) Responsible for Corrective Action • Frank Corona, Controller • Dayna Tinkey, Director of Student Accounts Anticipated Completion Date All corrective actions were implemented as of February 12, 2026.

View Audit 392486

Finding 1180825 (2025-001)

Material Weakness 2025

La Roche University

PA

Student Financial Aid Reporting

Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with status changes in the sample of 25 students selected. Corrective Action Plan La Roche University concurs with the finding. The Office of the Registrar has implemented a new sta...

Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with status changes in the sample of 25 students selected. Corrective Action Plan La Roche University concurs with the finding. The Office of the Registrar has implemented a new standard operating procedure regarding the reporting of students who have notified us of their withdrawal from the University at the end of spring term/early summer. Identified Error: La Roche University reports enrollment through the National Student Clearinghouse (NSC), which then reports to NSLDS. Because summer is not a mandatory reporting period, if a student is not enrolled they are not coded as withdrawn until they do not return in the fall; only on the first of fall enrollment report would they be coded as withdrawn. This does not meet the reporting timeline to NSLDS if we know a student is not planning to return. This only presents as an issue with the length of time between the end of spring and start of fall term; this is not an issue between the end of fall and start of spring term. New Procedure: If a student submits a Withdrawal form at the end of spring term through the first week of August, we must manually report them as withdrawn in NSC, as we know their intention to not return. Any forms submitted beginning in mid to late August will be picked up on the first of fall enrollment report as withdrawn and still fall within the reporting timeline. Name(s) of Contact Person(s) Responsible for Corrective Action • Katie Elverson, Registrar Anticipated Completion Date Implementation begins in May 2026 and will continue being implemented in all summers going forward.

View Audit 392486

Finding 1180821 (2025-002)

Material Weakness 2025

Stroudsburg Area School District

PA

Allowable Costs / Cost Principles Reporting § 200.510

Significant Deficiency 2025-002 (Internal Control Over Federal Award Reporting – ESSER III) Federal Program: Education Stabilization Fund - ARP-ESSER ALN: 84.425U Condition: Allowable ESSER III expenditures incurred during fiscal year 2023-24 were not identified or included on the Schedule of Expend...

Significant Deficiency 2025-002 (Internal Control Over Federal Award Reporting – ESSER III) Federal Program: Education Stabilization Fund - ARP-ESSER ALN: 84.425U Condition: Allowable ESSER III expenditures incurred during fiscal year 2023-24 were not identified or included on the Schedule of Expenditures of Federal Awards (SEFA) for that year. In addition, expenditures related to Federal Set-Aside awards were mistakenly included in the Final Expenditure Report for ESSER III, resulting from a misunderstanding of the structure of the federal awards. Recommendation: Strengthen internal controls Corrective Action: The District will provide targeted training to staff responsible for federal grant accounting to ensure a clear understanding of federal grant award structures, including the distinction between ESSER III and related Federal Set-Aside awards. This training will cover grant setup, expenditure coding, and reporting requirements. Person Responsible: Brenda VanBuskirk, Business Manager Proposed Completion Date: December 31, 2025

View Audit 392478

Finding 1180820 (2025-004)

Material Weakness 2025

Illinois State University

IL

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

Management Response: The University agrees with the finding. The identified issue was isolated and only impacted fall graduates. This issue was fully addressed when the university filed its fall 2025 enrollment reporting. The university has conducted an internal audit to identify students that were ...

Management Response: The University agrees with the finding. The identified issue was isolated and only impacted fall graduates. This issue was fully addressed when the university filed its fall 2025 enrollment reporting. The university has conducted an internal audit to identify students that were reported incorrectly and has manually updated files to ensure dates were properly reflected. At current state, internal monitoring and manual edits are made if discrepancies appear. The university has been in contact with PeopleSoft software related to the issue. Should the software issue not be resolved, the university plans to continue with manual edits to ensure proper reporting. Contact Person: Stacy Ramsey, University Registrar srramse@ilstu.edu Completion Date: December 2025

View Audit 392475

Finding 1180817 (2025-005)

Material Weakness 2025

Benton Community School Corporation

IN

Matching / Level of Effort / Earmarking § 200.207 § 200.303

Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Ot...

Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 23611-047-PN01, 22619-047-PN01, 22619-047-ARP, 23619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Significant Deficiency, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 22611-047-PN01, 22611-047-ARP, 23611-047-PN01, 22619-047-PN01, 22619-047-ARP, and 23619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $27,189, $5,074, $26,124, $1,171, $453, and $1,929, respectively. There were not sufficient non-public school expenditures incurred to meet the non-public proportionate share requirement for any of the six grants. The non-public school expenditures fell short of the minimum requirement by $11,679, $3,176, $16,405, $1,171, $4, and $1,929, respectively. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The cooperative has developed a written procedure for documenting expenditures related to the proportionate share earmarking requirement at the School Corporation level to address this issue going forward. The School Corporation will maintain the proper documentation to support the Non-Public Proportionate Share earmarking requirement and validate the earmarking requirement is met at the end of the grant’s period of performance or once fully expended. Responsible Party and Timeline for Completion: The corrective action plan has been put into place for the 2025-26 school year. Tracy Albertson, Director of Finance, and Sarah Claton, Director of Cooperative School Services, will oversee the corrective action plan.

View Audit 392466

Finding 1180811 (2025-004)

Material Weakness 2025

Benton Community School Corporation

IN

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.309 § 200.461

Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal ...

Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Period of Performance compliance requirements. Context: During fiscal year 2023-24, the School Corporation was a member of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01 and 22619-047-ARP grant awards, two exceptions were identified in the sample of five transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the two identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. This issue was isolated to fiscal year 2024. No costs incurred outside of the period of performance were identified in fiscal year 2025. Views of Responsible Officials and Corrective Action Plan: Management disagrees with part of the finding. The term “obligate” can be interpreted in various ways within our context. While we have a purchase order that was completed by September 30, we do agree that we changed vendors after September 30 and paid the non-public school directly. We agree with the finding that direct payment to a non-public school is not allowable. The purchase order is an internal written commitment to acquire the items/supplies, but it is not a binding written agreement to acquire “property” when we are purchasing supplies until it is provided to the vendor. The purchase order is authorization and approval to purchase the items/supplies. Once the purchase order is provided to the vendor, it is committed and is the binding written agreement. The invoice is an order to pay the obligation. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Sarah Claton, Cooperative School Services director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the cooperative on an ongoing basis.

View Audit 392466

Corrective Action Plans

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