Corrective Action Plans

Finding 1173337 (2025-001)

Material Weakness 2025

MS

Cash Management HUD Housing Programs Material Weakness § 200.305

Corrective Action Plan: Upon assuming the role of Executive Director in July 2024, it became clear that rent reasonableness studies were not being conducted under the previous administration, as required. Recognizing the importance of compliance with HUD regulations, I initiated the implementation o...

Corrective Action Plan: Upon assuming the role of Executive Director in July 2024, it became clear that rent reasonableness studies were not being conducted under the previous administration, as required. Recognizing the importance of compliance with HUD regulations, I initiated the implementation of a rent reasonableness policy and process. To support this effort, we entered into a contract with MRI to provide us with the rent reasonableness software. Last year we supplied MRI with the necessary property addresses and zip codes to begin the analysis. Due to the complexity of the implementation and the volume of data required, the setup process took time. We are now actively incorporating rent reasonableness determinations into all tenant files during annual recertifications and interims. With nearly 700 families in our program, this is an ongoing process, but significant progress has been made. Our team is fully committed to ensuring full compliance with HUD regulations, and we continue to work diligently toward that goal. In addition, to ensure continued compliance and to maintain the integrity of our files, the HCV Supervisor will be conducting weekly audits. This internal quality control measure helps us identify and address any inconsistencies or issues in a timely manner.

View Audit 386927

Finding 1173336 (2025-003)

Material Weakness 2025

Nicolet Area Technical College District

WI

Special Tests & Provisions Student Financial Aid Reporting

Upon notification of the reporting error, the institution corrected the enrollment status effective date in both the National Student Clearinghouse (NSC) and NSLDS to reflect the student's actual withdrawal date of November 15, 2024. To prevent future reporting errors, the Registrar's Office will im...

Upon notification of the reporting error, the institution corrected the enrollment status effective date in both the National Student Clearinghouse (NSC) and NSLDS to reflect the student's actual withdrawal date of November 15, 2024. To prevent future reporting errors, the Registrar's Office will implement an additional procedural verification step in the enrollment status reporting process. This step will include a review of effective dates prior to submission to NSC and NSLDS. The Registrar will also ensure appropriate staff training and oversight as process documentation is developed and implemented in the new student information system.

View Audit 386921

Finding 1173332 (2025-002)

Material Weakness 2025

North Country Food Bank, Inc.

MN

Allowable Costs / Cost Principles § 200.442

Contact Person: Susie Novak Boelter, Executive Director Corrective Action Plan: The Food Bank will review their procedures for allocating expenses to grants to ensure only allowable expenses are charged to the grant. Completion Date: Immediately

View Audit 386915

Finding 1173328 (2025-005)

Material Weakness 2025

Harmony Area School District

PA

Internal Control / Segregation of Duties

Action Taken: Management agrees with the recommendations and will have the business manager compare the support for the amounts reported to the District’s books and records prior to submission. Further, management will implement a review process to confirm the accuracy of the amounts reported, as we...

Action Taken: Management agrees with the recommendations and will have the business manager compare the support for the amounts reported to the District’s books and records prior to submission. Further, management will implement a review process to confirm the accuracy of the amounts reported, as well as maintain the supporting information. Proposed Completion Date: March 31, 2026

View Audit 386901

Finding 1173327 (2025-004)

Material Weakness 2025

Harmony Area School District

PA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Action Taken: Management agrees with the recommendations. The management team involved with grants will work to modify and improve the current procedures and will implement the controls surrounding grant compliance, from the application process through final reporting. The team will also continue to...

Action Taken: Management agrees with the recommendations. The management team involved with grants will work to modify and improve the current procedures and will implement the controls surrounding grant compliance, from the application process through final reporting. The team will also continue to work to enhance our grant monitoring, including resuming management team meetings to keep everyone abreast of the status of grants. In addition, we will begin to gradually involve the new business office employee in grant reporting to improve on compliance with grant reporting requirements. Proposed Completion Date: June 30, 2026

View Audit 386901

Finding 1173326 (2025-003)

Material Weakness 2025

Harmony Area School District

PA

Reporting Subrecipient Monitoring

Action Taken: Management agrees with the recommendations and will contact the Pennsylvania Department of Education to inquire as to how to resubmit the annual report with correct amounts for 2023-24, agreeing the expenditures to the District’s books and records. In addition, the business manager wil...

Action Taken: Management agrees with the recommendations and will contact the Pennsylvania Department of Education to inquire as to how to resubmit the annual report with correct amounts for 2023-24, agreeing the expenditures to the District’s books and records. In addition, the business manager will ensure the amounts reported for the upcoming annual report for fiscal year 2024-25 contain the correct expenditures and that the expenditures agree with the District’s books and records. Proposed Completion Date: March 31, 2026

View Audit 386901

Finding 1173325 (2025-002)

Material Weakness 2025

Harmony Area School District

PA

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

Action Taken: Management agrees with the recommendations. The unique situation with the COVID-19 funding, coupled with shifts in the business manager’s duties over the last few years and the staff retirement has resulted in grant report filings becoming a lower priority. The management team will wor...

Action Taken: Management agrees with the recommendations. The unique situation with the COVID-19 funding, coupled with shifts in the business manager’s duties over the last few years and the staff retirement has resulted in grant report filings becoming a lower priority. The management team will work together and will resume management team meetings to determine and monitor the duties for which each is responsible. Strides have been made in this regard, as the principals have become involved in Federal program training, budgeting, and scheduling. Although the aforementioned report submissions are delinquent and funding was suspended, some filings have been completed, and certain payments have been received and others are forthcoming. However, management will begin to gradually involve the new business office employee in grant reporting to improve on compliance with grant reporting requirements. Proposed Completion Date: June 30, 2026

View Audit 386901

Finding 1173320 (2025-001)

Material Weakness 2025

Art in Motion

IL

Procurement, Suspension & Debarment School Nutrition Programs § 200.318 § 200.319 § 200.320

The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthe...

The organization will revise and reinforce its procurement policies to ensure compliance with 2 CFR 200.318–200.320. Staff involved in procurement will receive training in federal procurement standards, including competitive bidding and documentation requirements. Internal controls will be strengthened to ensure consistent application of procedures and oversight. Anticipated Completion Date: January 31, 2026. Responsible Contact Person: Alfred D. Ivy, Director of Business Affairs & Operations.

View Audit 386895

Finding 1173317 (2025-001)

Material Weakness 2025

San Angelo Independent School District

TX

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2025-001 Special Tests and Provisions – Participation of Private School Children Finding Summary: The District failed to conduct timely consultations with private school officials regarding the implementation of the Stronger Connections Grant. Responsible Individuals: Dr. Farrah Gomez, Deput...

Finding 2025-001 Special Tests and Provisions – Participation of Private School Children Finding Summary: The District failed to conduct timely consultations with private school officials regarding the implementation of the Stronger Connections Grant. Responsible Individuals: Dr. Farrah Gomez, Deputy Superintendent of Academics and School Leadership Corrective Action Plan: The District will establish and implement written procedures to ensure annual consultation meetings with private school officials for all grants under the Title IV program. Additionally, the District will consult with TEA to determine next steps regarding the Stronger Connections Grant. Anticipated Completion Date: January 2026

View Audit 386886

Finding 1173316 (2025-001)

Material Weakness 2025

St. Monica's Home

NE

Allowable Costs / Cost Principles § 200.430

Significant Deficiency in Internal Controls over Compliance for Allowable Costs/Cost Principles Finding Summary: The Organization did not maintain documentation to support payroll timesheet approvals. Responsible Individuals: Danielle Smith, Executive Director Corrective Action Plan: Payroll procedu...

Significant Deficiency in Internal Controls over Compliance for Allowable Costs/Cost Principles Finding Summary: The Organization did not maintain documentation to support payroll timesheet approvals. Responsible Individuals: Danielle Smith, Executive Director Corrective Action Plan: Payroll procedures will be updated to incorporate this process and the Organization will maintain documentation of payroll timecard approval to support payroll amounts allocated to the federal award. Anticipated Completion Date: June 2026

View Audit 386880

Finding 1173315 (2025-003)

Material Weakness 2025

BLOOMINGDALE UTILITY DISTRICT OF SULLIVAN COUNTY

TN

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

The Utility will review and write a more detailed version of procurement policies to ensure complete and continuous compliance with the requirement in the Uniform Guidance

View Audit 386872

Finding 1173311 (2025-001)

Material Weakness 2025

Cerritos Community College District

CA

Subrecipient Monitoring Special Tests & Provisions Student Financial Aid

Views of Responsible Officials and Corrective Action Plan The District agrees with the finding and will implement procedures that will ensure Returns of Title IV funds are returned no later than 45 days after that date the College determines the student has withdrew.

View Audit 386844

Finding 1173296 (2025-003)

Material Weakness 2025

City of Lawton

OK

Procurement, Suspension & Debarment § 200.318 § 200.326

The Organization concurs with the finding and is reviewing procurement policies to ensure adequate documentation is maintained.

View Audit 386837

Finding 1173293 (2025-002)

Material Weakness 2025

Senior Citizens Housing Development Corporation of Bell

FL

HUD Housing Programs Eligibility Reporting

FINDING No. 2025-002: Section 202 Supportive Housing for Elderly, ALN 14.157 Recommendation: The Project should implement procedures to ensure tenant eligibility is verified in a timely manner and tenant files are properly maintained. Action Taken: Staff training has been provided with additional HU...

FINDING No. 2025-002: Section 202 Supportive Housing for Elderly, ALN 14.157 Recommendation: The Project should implement procedures to ensure tenant eligibility is verified in a timely manner and tenant files are properly maintained. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO

View Audit 386834

Finding 1173292 (2025-001)

Material Weakness 2025

Senior Citizens Housing Development Corporation of Bell

FL

HUD Housing Programs Reporting

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Bell respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral ...

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Bell respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: July 1, 2024 through June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 202 Supportive Housing for Elderly, ALN 14.157 Recommendation: The Project should refund security deposits timely. Action Taken: Staff training has been provided and included in monthly reporting procedures. A system glitch caused the delay.

View Audit 386834

Finding 1173291 (2025-002)

Material Weakness 2025

Framingham State University

MA

Student Financial Aid

Corrective Action Plan: To prevent this issue from recurring, we have implemented an additional data validation step during the preparation of the Graduates Only Enrollment Submission. Specifically, we will now cross-check the "last date of attendance" field for all graduating students to ensure tha...

Corrective Action Plan: To prevent this issue from recurring, we have implemented an additional data validation step during the preparation of the Graduates Only Enrollment Submission. Specifically, we will now cross-check the "last date of attendance" field for all graduating students to ensure that it aligns with the official last day of the term, as defined by the academic calendar. In this case, the correct date should have been December 20, 2024; however, the file incorrectly populated the field with December 23, 2024. We are reviewing the logic in the data generation process to identify and correct the source of the discrepancy. Moving forward, the Registrar’s Office will confirm this date field prior to each submission to the Clearinghouse to ensure compliance with NSLDS requirements. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2025. Contact Person: Caitlin Laurie, Director of Financial Aid Mark Powers, Registrar

View Audit 386833

Finding 1173289 (2025-001)

Material Weakness 2025

Framingham State University

MA

Student Financial Aid Reporting

Corrective Action Plan: The individual did not have a social security number (“SSN”) on file in Banner. As a result, although the enrollment data was transmitted to the National Student Clearinghouse, the missing SSN went unnoticed until June 2025, when materials were being gathered for the audit. T...

Corrective Action Plan: The individual did not have a social security number (“SSN”) on file in Banner. As a result, although the enrollment data was transmitted to the National Student Clearinghouse, the missing SSN went unnoticed until June 2025, when materials were being gathered for the audit. The Director of Student Financial Aid was able to locate the student’s SSN in PowerFaids and provide it accordingly. We then manually updated the student’s Fall 2024 and Spring 2025 enrollment data in NSLDS to ensure their record was complete. To help prevent this type of issue in the future, both the Registrar and Director of Student Financial Aid have implemented a process that compares missing or potentially incorrect SSNs in Banner against the data in PowerFaids. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2025. Contact Person: Caitlin Laurie, Director of Financial Aid Mark Powers, Registrar

View Audit 386833

Finding 1173281 (2025-001)

Material Weakness 2025

Black Hills Community Economic Development, Inc.

SD

Reporting

Finding No. 2025-001: Financial Statement and Schedule of Expenditures of Federal Awards (SEFA) Preparation Responsible Individuals: Fran White, Executive Director Corrective Action Plan: The Organization has accepted the risk associated with the finding regarding the preparation of the financial st...

Finding No. 2025-001: Financial Statement and Schedule of Expenditures of Federal Awards (SEFA) Preparation Responsible Individuals: Fran White, Executive Director Corrective Action Plan: The Organization has accepted the risk associated with the finding regarding the preparation of the financial statements and will continue to have the independent auditor prepare the annual financial statements. Additionally, the Organization will prepare the credit loss calculation going forward. Anticipated Completion Date: Ongoing

View Audit 386815

Finding 1173275 (2025-003)

Material Weakness 2025

Southwestern Adventist University

TX

Student Financial Aid Eligibility

Corrective Action: See above corrective action plan for 2025-002. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance; Jason Kowarsch, Registrar

View Audit 386786

Finding 1173274 (2025-002)

Material Weakness 2025

Southwestern Adventist University

TX

Student Financial Aid Eligibility Special Tests & Provisions

Corrective Action: To prevent future occurrences of PELL and Direct Loans award findings identifying students not enrolled, withdrawn, and over-awarded aid. • Staff Training o Additional training sessions will be conducted for Student Finance staff to enhance understanding of awarding rules and syst...

Corrective Action: To prevent future occurrences of PELL and Direct Loans award findings identifying students not enrolled, withdrawn, and over-awarded aid. • Staff Training o Additional training sessions will be conducted for Student Finance staff to enhance understanding of awarding rules and system functionality. o Training will focus on identifying and correcting over-awarding scenarios before disbursement. • System Monitoring o Regular audits of the Ellucian System will be performed to ensure continued accuracy in aid calculations and refund processing. • Policy Enforcement o A formal policy will be adopted requiring aid disbursement only after census verification. o Exception will be documented and reviewed by the Vice President of Financial Administration. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance; Jason Kowarsch, Registrar Completion Date: To be completed by March 1, 2026

View Audit 386786

Finding 1173272 (2025-001)

Material Weakness 2025

Southwestern Adventist University

TX

Student Financial Aid Special Tests & Provisions Reporting

The 2023-24 Single Audit identified 12 delinquent NSLDS reports for the 2023-24 academic year, with delays ranging from 180 to 459 days. The 2024-25 Single Audit showed improvement, with only 5 of 9 reports filed late for the 2024-25 academic year, and delays reduced to 80-155 days. Corrective Actio...

The 2023-24 Single Audit identified 12 delinquent NSLDS reports for the 2023-24 academic year, with delays ranging from 180 to 459 days. The 2024-25 Single Audit showed improvement, with only 5 of 9 reports filed late for the 2024-25 academic year, and delays reduced to 80-155 days. Corrective Action: To prevent future occurrences of missed NSLDS reporting, the following steps have been implemented: • Cleanup of Past Delinquencies o All outstanding 2024-25 reports have been reviewed and submitted by October 3, 2025. o A reconciliation audit will be conducted to ensure all NSLDS records match institutional data. • Process Improvement o Implemented a centralized calendar with automated reminders for NSLDS reporting deadlines. o Established monthly reconciliation between internal Student Information System and NSLDS data. • Staffing and Training o The registrar is the primary reporting coordinator to the National Student Clearinghouse, with support from both Student Financial Services and ITS. o A standard operating procedure (SOP) has been documented to guide future reporting efforts. • Management Oversight o The Vice President for Academic Administration and ITS must also ensure that all these processes and departments are working to ensure the student data is being reported correctly and on-time. We are confident that these measures will address the issue of failure to report to the NSC and ensure full compliance with NSLDS reporting requirements in the future. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance; Jason Kowarsch, Registrar Completion Date: October 3, 2025

View Audit 386786

Finding 1173270 (2025-002)

Material Weakness 2025

Wyalusing Area School District

PA

Internal Control / Segregation of Duties

Adjusting Journal Entries, Required Disclosures and Draft Financial Statements - Year ended June 30, 2025 Auditor’s Recommendation: Although auditors may continue to provide such assistance both now and in the future, under this pronouncement, the District should continue to review and accept both p...

Adjusting Journal Entries, Required Disclosures and Draft Financial Statements - Year ended June 30, 2025 Auditor’s Recommendation: Although auditors may continue to provide such assistance both now and in the future, under this pronouncement, the District should continue to review and accept both proposed adjusting journal entries and footnote disclosures, along with the draft financial statements. School District’s Response: The District has received, reviewed and accepted all journal entries, footnote disclosures and draft financial statements proposed for the current year audit and will continue to review similar information in future years. Further, the District believes it has a thorough understanding of these financial statements and the ability to make informed judgments based on these financial statements. Lastly, the District considers such assistance provided by the auditors to be the most cost effective in preparing such information

View Audit 386783

Finding 1173250 (2025-001)

Material Weakness 2025

College of Eastern Idaho

ID

Student Financial Aid

Finding 2025-001 Incorrect NSLDS Reporting: The examination disclosed 1 student, out of 25 student files tested, in which NSLDS was not updated within the 60-daytimeframe of their status change. The student graduated on May 9, 2025 but the status change was not certified until September 5, 2025. Cor...

Finding 2025-001 Incorrect NSLDS Reporting: The examination disclosed 1 student, out of 25 student files tested, in which NSLDS was not updated within the 60-daytimeframe of their status change. The student graduated on May 9, 2025 but the status change was not certified until September 5, 2025. Corrective Action Plan The College of Eastern Idaho Financial Aid Office and Registrar Office acknowledges the NSLDS reporting finding. Our corrective action plan will strengthen oversight procedures to ensure all student enrollment status changes are reported accurately and within the required 60-day timeframe. The Registrar's Office will implement a formalized reporting schedule with National Student Clearinghouse (NSC), to address enrollment changes occurring during non-standard reporting periods such as summer terms. In addition, the Registrar's Office will designate and train a second staff member authorized to report enrollment information to NSC as needed to ensure continuity and timely reporting. Person(s) Responsible: Raquel Cuevas, Tiffany Cleverly Timing for Implementation: Immediate 01.01.2026

View Audit 386746

Finding 1173247 (2025-001)

Material Weakness 2025

Eastern Connecticut Area Agency on Aging, Inc.

CT

Reporting

Finding 2025-001 Reporting Requirements Description of Finding Per the corresponding grant agreements with State of Connecticut Department of Aging and Disability Services, various financial reporting requirements on programs include monthly, quarterly and annual fiscal year-end expenditure reports....

Finding 2025-001 Reporting Requirements Description of Finding Per the corresponding grant agreements with State of Connecticut Department of Aging and Disability Services, various financial reporting requirements on programs include monthly, quarterly and annual fiscal year-end expenditure reports. The Agency did not submit October 2024, January 2025, May 2025 and September 2025 monthly expenditure reports by the prescribed deadline (i.e. 15 days after month end) or the FY 2025 annual expenditures report by the prescribed deadline (i.e. 45 days after fiscal year-end). In addition, the Agency did not submit the second or fourth quarter expenditure reports by the prescribed deadline (i.e. 15 days after month end). Statement of Concurrence Management concurs with this finding. Corrective Action While management was aware of the reporting requirements, supporting information from the Agency’s grantees is not always available to submit actual expenditure data by the prescribed deadlines. We will add additional controls to monitor the deadlines of various reporting requirements as well as request formal extensions and retain for audit purposes when necessary. Name of Contact Person Alison Dvorak, Executive Director Projected Completion Date The implemented control described above will be in operation for all future audit periods.

View Audit 386742

Finding 1173242 (2025-001)

Material Weakness 2025

Roger Williams University

RI

Student Financial Aid Reporting Special Tests & Provisions

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Criteria or Specific Requirement Unless it expects to submit its next updated enrollment report to the Secretar...

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Criteria or Specific Requirement Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended (CFR 685.309(b)(2)(i)). Condition Found Three students out of the 16 selected for status change testing had their status change reported to the National Student Loan Data System (“NSLDS”) outside of the maximum 60-day window. Changes were reported 5 days later than the requirement of 60 days. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University intends to report status changes within the 60-day requirement going forward. Names of Contact Person Responsible for Correction Action: Gloria Arcia, Ed.D., Executive Vice President for Finance and Administration / Chief Financial Officer Anticipated Completion Date: October 2, 2025

View Audit 386736

Corrective Action Plans

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