Corrective Action Plans

Finding 1181872 (2025-001)

Material Weakness 2025

State System of Higher Education, Commonwealth of Pennsylvania

PA

Student Financial Aid Reporting Significant Deficiency § 200.303

Recommendation: The University should review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findin...

Recommendation: The University should review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Increased frequency of NSC Submissions. Completing the error files returned to NSC quickly within the first 1-4 days of receipt after sending the files back. • We met with another PASSHE school on 4/22/25 and they helped us to strategize ensuring we meet the 60-day window for withdrawals by individually updating the withdrawal information in NSC on a weekly basis using our withdrawal report to identify each student withdrawal between our regular submissions. (Because we met with them so late in the audit cycle, we were not able to correct course for FY25 in time.) • We have adjusted our degree verification timeline, ensuring that the large bulk of our degree verification submission to NSC is completed within 2 weeks of the end of the graduating semester, ensuring that the bulk of our graduating students are moved from NSC to NSLDS sooner. • We updated our change of major policy to ensure that students are not changing majors after the end of the drop/add period. Prohibiting mid-semester major changes for the current semester will greatly reduce the number of status change errors reflected in NSC. This cleaner approach ensures less risk of error or delay related to volume. This was formalized with KU Policy ACA-029, approved at Senate on 9/4/25. Name(s) of the contact person(s) responsible for corrective action: Ben Trout, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 393174

Finding 1181869 (2025-001)

Material Weakness 2025

Young at Heart Resources

MO

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.430

Finding Reference Number: 2025-001 Federal Agency: U.S. Department of Health and Human Services Program Name: Aging Cluster Assistance Listing Number: 93.044/93.045/93.053 Responsible Official: Penny Crawford, Chief Executive Officer; Kelsey Swinderman, Financial Manager Views of Responsible Individ...

Finding Reference Number: 2025-001 Federal Agency: U.S. Department of Health and Human Services Program Name: Aging Cluster Assistance Listing Number: 93.044/93.045/93.053 Responsible Official: Penny Crawford, Chief Executive Officer; Kelsey Swinderman, Financial Manager Views of Responsible Individuals: The Agency acknowledges the documentation deficiencies identified related to payroll and contract management. These issues were largely due to leadership transitions and changes in operational processes. The Agency has evaluated these gaps and is actively implementing corrective actions to strengthen internal controls and ensure compliance with Uniform Guidance requirements. Corrective Action Plan: Corrective actions currently in progress include: • Standardizing documentation requirements for all employee pay rates, including maintaining supporting documentation within personnel files • Implementing internal review procedures to ensure payroll changes align with Board-approved actions • Centralizing contract management and maintaining all executed service provider agreements in a secure, accessible location • Establishing documentation retention procedures to ensure all supporting records for federal award expenditures are complete and readily available for audit review The Agency is committed to fully resolving these issues and strengthening internal processes to ensure ongoing compliance and accountability. The Agency is implementing enhanced internal control procedures to ensure that all costs charged to federal awards are properly authorized, documented, and maintained in accordance with federal requirements. These improvements include the development of standardized processes for payroll documentation, contract management, and documentation retention. Internal review procedures are also being strengthened to ensure alignment between Board approvals and financial records. Anticipated Completion Date: June 30, 2026

View Audit 393170

Finding 1181866 (2025-005)

Material Weakness 2025

Housing Agency of the City of Beatrice, Nebraska

NE

HUD Housing Programs

Findings 2025-005- HOTMA I agree with the finding and corrective action has been taken by the Executive Director. Implementations HOTMA that were to begin July 1, 2025 were implemented. The Agency stopped enrolling families in the EID as of December 31, 2023. Transitioned to the new FORM HUD – 9886 ...

Findings 2025-005- HOTMA I agree with the finding and corrective action has been taken by the Executive Director. Implementations HOTMA that were to begin July 1, 2025 were implemented. The Agency stopped enrolling families in the EID as of December 31, 2023. Transitioned to the new FORM HUD – 9886 as of February 1, 2025. Applied HOTMA/102/104 income exclusions listed in 24 CFR5.609 (b) including new requirements for student financial assistance. Am working with Lisa Viles Services and they have helped the Beatrice Housing Agency update their administrative plan. It wasn’t approved by the Board until September 23rd, 2026. It is the Executive Director’s responsibility to implement and ensure timely adoption of policies.

View Audit 393156

Finding 1181865 (2025-004)

Material Weakness 2025

Housing Agency of the City of Beatrice, Nebraska

NE

HUD Housing Programs Subrecipient Monitoring Cash Management

Finding 2025-004- Allowable Activities I agree with the finding and corrective action will be taken by the Executive Director to correct the deficit balance. Benefits will be reviewed for employees of the Housing Agency. Management fees from the Prairie Heights and Prairie Village programs will also...

Finding 2025-004- Allowable Activities I agree with the finding and corrective action will be taken by the Executive Director to correct the deficit balance. Benefits will be reviewed for employees of the Housing Agency. Management fees from the Prairie Heights and Prairie Village programs will also be reviewed. Working with fee accountant on allocations.

View Audit 393156

Finding 1181861 (2025-002)

Material Weakness 2025

Springs Valley Community Schools Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.303 § 200.317 § 200.318 § 200.327

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the fi...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In the future, the Treasurer will check the SAM exclusion list prior to entering into a covered transaction with federal awarded funds. There will also be a documented, secondary review to ensure the suspension and debarment requirement has been checked. Anticipated Completion Date: 02/04/2026

View Audit 393146

Finding 1181858 (2025-001)

Material Weakness 2025

Contoocook Valley Regional School District

NH

School Nutrition Programs

The District has existing policies to address overdue meal charges: EFAA-Meal Charging and EFC-Free and Reduced-Price Lunch. Due to staff transitions over the last several years, these policies have not been adequately enforced. The following steps will be taken to correct this: • Central Office Ove...

The District has existing policies to address overdue meal charges: EFAA-Meal Charging and EFC-Free and Reduced-Price Lunch. Due to staff transitions over the last several years, these policies have not been adequately enforced. The following steps will be taken to correct this: • Central Office Oversight: The central office will take a more active role in ensuring policies are executed effectively. • Policy Review: Policies will be reviewed with all staff members responsible for their implementation. • Targeted Training: Comprehensive training will be provided to all involved personnel, specifically food service workers and building principals. • Compliance Monitoring: The central office will monitor adherence to these policies and provide ongoing support to staff. • Community Partnership: The District will increase coordination with non-profit charities to secure assistance for students in need. Additionally, current policies and practices will be reviewed and updated as necessary to ensure the desired outcomes are achieved.

View Audit 393142

Finding 1181855 (2025-002)

Material Weakness 2025

Housing Authority of Portage County

WI

Allowable Costs / Cost Principles Reporting

The Authority’s Board of Commissioners and management will continue to rely on the use of their outside auditors to prepare the schedule of expenditures of federal awards that were presented in accordance with generally accepted accounting principles. Management will assign a person within the Autho...

The Authority’s Board of Commissioners and management will continue to rely on the use of their outside auditors to prepare the schedule of expenditures of federal awards that were presented in accordance with generally accepted accounting principles. Management will assign a person within the Authority with the skills, knowledge and expertise to review and approve the schedule of expenditures of federal awards.

View Audit 393140

Finding 1181854 (2025-001)

Material Weakness 2025

Housing Authority of Portage County

WI

Internal Control / Segregation of Duties

The Authority’s Board of Commissioners and management will continue to rely on the use of their outside auditors to prepare draft financial statements that were presented in accordance with generally accepted accounting principles. Management will assign a person within the Authority with the skills...

The Authority’s Board of Commissioners and management will continue to rely on the use of their outside auditors to prepare draft financial statements that were presented in accordance with generally accepted accounting principles. Management will assign a person within the Authority with the skills, knowledge and expertise to review and approve the draft financial statements.

View Audit 393140

Finding 1181849 (2025-001)

Material Weakness 2025

Allamakee County

IA

Internal Control / Segregation of Duties

Management is cognizant of this limitation and will implement additional procedures where possible.

View Audit 393136

Finding 1181848 (2025-001)

Material Weakness 2025

Centre College of Kentucky

KY

Student Financial Aid

Centre College has further evaluated its policies and procedures for student status change reporting. We are implementing an additional student enrollment reporting from our Registrar to NSC/NSLDS during our non-compulsory January term to ensure timely reporting of students who graduate or withdraw ...

Centre College has further evaluated its policies and procedures for student status change reporting. We are implementing an additional student enrollment reporting from our Registrar to NSC/NSLDS during our non-compulsory January term to ensure timely reporting of students who graduate or withdraw between our final fall and initial spring semester reports. We will also provide ongoing training for sustained compliane with applicable procedures and monitor the additional reporting cycle during implementation.

View Audit 393133

Finding 1181843 (2025-004)

Material Weakness 2025

Municipality of Cayey

PR

Subrecipient Monitoring Reporting Significant Deficiency § 200.302 § 200.328 § 200.329

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – ...

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Ronaldo Ortiz Velázquez, Mayor Contact Person: Mrs. Eunice Díaz, Finance and Budget Director Phone: (787)738-3211 Original Finding Number: 2025-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: During the testing of reports, the Quarterly Progress Reports of five (5) projects, corresponding to two (2) quarters of fiscal year 2024-2025, were evaluated. It was found that in two (2) projects, the quarterly reports did not match the accounting records or the project documentation. Therefore, for the purposes of this audit, the municipal accounting controls and procedures did not ensure that the reported information was accurate, up-to-date, and fully reconciled with the financial records. In light of the above, the reports will be reconciled with the accounting records, and the discrepancies found will be identified, documented, and adjusted in the system where the error originated, as appropriate. Furthermore, from this point forward, once the Quarterly Reports (QPR) are issued, a copy must be sent to the Program Accountant, the Finance Director, and myself for validation and reconciliation prior to official filing, thus preventing situations like this to occur. This process will form part of the internal control required to ensure that the reported information is accurate, current, complete, and consistent with the accounting records, in accordance with applicable federal requirements. Implementation Date: From March 2026. Full implementation is expected in fiscal year 2026-2027. Responsible Person: Mrs. Natasha Vázquez Federal Programs Director

View Audit 393130

Finding 1181841 (2025-003)

Material Weakness 2025

Municipality of Cayey

PR

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – ...

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Ronaldo Ortiz Velázquez, Mayor Contact Person: Mrs. Eunice Díaz, Finance and Budget Director Phone: (787)738-3211 Original Finding Number: 2025-003 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: As an internal control and prevention measure, the budget sent by the Agency will be verified with the percentages (%) established in the contract. If they do not match, ACUDEN will be asked to amend the budget. Also, as part of the corrective action plan, the municipality will be moving the location of its centers in search of better accessibility for participants and to be more aggressive in providing services and spending the allocations in full. Implementation Date: During fiscal year 2025-2026. Responsible Person: Mrs. Natasha Vázquez Federal Programs Director

View Audit 393130

Finding 1181839 (2025-003)

Material Weakness 2025

Lutheran Social Services of Central Ohio

OH

Material Weakness Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Condition: During the current year, the Organization did not apply the sliding fee scale discount to certain patient claims accurately. During our testing, we noted 13 instances of the sliding fee scale not being accurately applied to patient services out of the 40 transactions tested. Planned Corre...

Condition: During the current year, the Organization did not apply the sliding fee scale discount to certain patient claims accurately. During our testing, we noted 13 instances of the sliding fee scale not being accurately applied to patient services out of the 40 transactions tested. Planned Corrective Action: Management acknowledges the sliding fee scale discount should have been applied consistently and accurately and plan to improve the process going forward. Management corrected the patient accounts by applying the sliding fee scale discount. Contact person responsible for corrective action: Julie Fratianne, CFO Anticipated Completion Date: June 30, 2026

View Audit 393120

Finding 1181837 (2025-002)

Material Weakness 2025

Massachusetts Bay Community College

MA

Student Financial Aid Reporting

The College will be looking at making some business process changes to review files submitted to NSC (National Student Clearing House) and NSLDS (National Student Loan Data Service) monthly and perform monthly data reconciliation between responsible offices to ensure students are accurately reported...

The College will be looking at making some business process changes to review files submitted to NSC (National Student Clearing House) and NSLDS (National Student Loan Data Service) monthly and perform monthly data reconciliation between responsible offices to ensure students are accurately reported to ED/NSLDS. This new implementation will allow the College/Office to better verify each student’s enrollment status and visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan: The procedure was implemented starting with the Spring 2026 semester and has continued since. Contact Person: Alex Jean-Jacques, Director of Financial Aid Operations

View Audit 393116

Finding 1181832 (2025-001)

Material Weakness 2025

Miami Dade County District School Board

FL

Subrecipient Monitoring HUD Housing Programs

PLANNED CORRECTIVE ACTION: Miami-Dade County Public Schools (M-DCPS) adheres to Section 1003.23, Florida Statutes, as it pertains to withdrawal of all students enrolled in the District. Based on the DOE's Comprehensive Management Information System Automated Student Attendance Recordkeeping System H...

PLANNED CORRECTIVE ACTION: Miami-Dade County Public Schools (M-DCPS) adheres to Section 1003.23, Florida Statutes, as it pertains to withdrawal of all students enrolled in the District. Based on the DOE's Comprehensive Management Information System Automated Student Attendance Recordkeeping System Handbook: A withdrawal is official when one or more of the following occurs: 1. A parent or legal guardian notifies the school that the child is permanently leaving the school to enroll in another school or in home education. 2. A request for the student's school record is received from a public or private school, in- or out-of-state, in which the student is enrolled or plans to enroll. 3. The student has died. 4. The student transferred to a prison or juvenile facility. The following withdrawal procedures are in place for scenarios where a student needs to be removed from the cohort due to emigration: 1. The registering parent notifies the school, in person, that the student is withdrawing because of having to leave the country. 2. The registrar validates the individual requesting to withdraw the student is the registering parent/legal guardian. 3. The registrar goes to the Student Information screen and inputs Code W3B under the transaction code, and inputs in the School Location line, FLOR or out of Florida identifier. 4. The registrar complete the Notice of Withdrawal/Transfer screen in DSIS by inputting the New School Name, New School Address, (City, State, Country), and phone numbers in addition to the out of Florida identifier (FLOR). 5. The registrar prints the Notice of Withdrawal/Transfer screen and the registering parent signs and dates the document. 6. The registrar provides the registering parent with a copy of the signed Notice of Withdrawal/Transfer screen and keeps a copy of the documentation in the student's cumulative folder (CUM). Upon further review, the District examined the Every Student Succeeds Act High School Graduation Rate Non-Regulatory Guidance. The guidance indicates that for students who leave the country, documentation of withdrawal may include the parent's signed confirmation indicating the student is departing the United States. The District's current procedure requiring a parent or guardian signature on the PF15 aligns with this guidance and reflects the parent's formal acknowledgement that the student is leaving the country and no longer enrolled in the District. The District's withdrawal procedures strictly adhere to the Florida Department of Education (FDOE) Automated Student Attendance Recordkeeping System Handbook. Per State protocol, a withdrawal is deemed official when a parent or legal guardian notifies the school that the child is leaving to enroll in another school. M-DCPS considers the parent's signed acknowledgment at the point of withdrawal as official documentation of a change in status, rather than a mere statement of "intent". While the District followed established State recordkeeping protocols, we recognize the Auditor General's emphasis on the additional evidentiary requirements found in Title 20, Section 7801(25), United States Codes. To address the variance between State and Federal requirements, the District will consult with the Florida Department of Education to seek clarification and work toward reconciling State withdrawal codes with Federal graduation cohort documentation standards. ANTICIPATED COMPLETION DATE: 03/04/2027 RESPONSIBLE CONTACT PERSON: Ana M. Gutierrez

View Audit 393099

Finding 1181831 (2025-003)

Material Weakness 2025

Idaho State University

ID

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the University review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanatio...

Student Financial Assistance Cluster – Assistance Listing No. 84.033 Recommendation: We recommend the University review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is prepared to return the FY25 FWS Unspent portion of the 7% Community Service required spending (7% of Final FWS Funding of $742,211 = $51,954.77 (rounded to $51,955) [Community Service spending requirement] minus $25,061 (FWS funds spent in community service as reported on FISAP) = $26,894 (Unspent portion of 7% to be returned to ED). Since the pandemic year, ISU’s off-campus (community service) participation has been dwindling and overall FWS participation has suffered since many students and employers are opting to be involved in the University’s Career Path Internship (CPI) program over FWS. Due to the struggles in recent years to meet the 7% Community Service requirement, ISU has been applying for a waiver of the Community Service requirement but thus far our waiver requests have been denied. The Financial Aid Office is reviewing current processes related to tracking FWS Community Service spending and partnering with the Career Center to proactively identify off-campus participants and looking at ways to cooperate with the University’s CPI program participants who are FWS-eligible and who are working in Community Service activities and plan to expand on-campus FWS Community Service opportunities to meet the minimum 7% community service requirement. Name(s) of the contact person(s) responsible for corrective action: James Martin, Director of Financial Aid and Katheryn Wareing, Senior Accountant for Financial Aid/FWS Administrator Planned completion date for corrective action plan: 08/24/2026

View Audit 393093

Finding 1181828 (2025-002)

Material Weakness 2025

Idaho State University

ID

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

Student Financial Assistance Cluster – Assistance Listing No. 84.033, 84.268, 84.063 & 84.007 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement wit...

Student Financial Assistance Cluster – Assistance Listing No. 84.033, 84.268, 84.063 & 84.007 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for 2024-004 Finding’s Recurrence: Related to case identified where a corrected Last Date of Attendance (Effective Date in Banner System on SFAWDRL input by the Financial Aid Office for a fully online student during the Unofficial Withdrawal [post term] Return of Title IV processing) was not carried over to Status Date in Banner maintained by the Registrar’s Office and to NSC/NSLDS so that all are reporting the accurate Last Date of Attendance, the University found that corrected dates during the semester aligned and were being reported to NSC/NSLDS in a timely manner, but that corrected dates after end of term were not being transmitted to NSC and NSLDS. Related to case identified of not reporting Graduated status to NSLDS in a timely manner: Typically, it takes approximately 2–3 weeks after commencement to clear degree audits and begin awarding degrees, as commencement occurs before final grades are released. The Graduate-only upload to NSC was completed on May 21, 2025.However, due to limitations with the National Student Clearinghouse (NSC) system, which does not accept multiple awards being posted simultaneously, we received an error report affecting approximately 60% of our graduates. Records included in this report must be corrected manually, which is a time-consuming process. We actively work to correct these records as quickly as possible within our current human resource limitations. The corrected error file related to the 2025-002 finding was uploaded to NSC on July 11, 2025, and sent to NSLDS on 7/12/2025. Action taken in response to finding: The University reviewed its procedures and implemented steps in our Unofficial Withdrawal [post term] Return of Title IV business process to include an email communication plan between the Financial Aid staff and the Office of the Registrar along with documentation sharing and added review steps to ensure the post-term corrected Last Date of Attendance is updated in all affected institutional and federal systems in a timely manner. The Office of the Registrar will correct errors returned from NSC within four weeks of receiving the file. To ensure this task is completed in a timely manner, we will allocate additional human resources as needed. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar, and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 08/06/2025

View Audit 393093

Finding 1181812 (2025-001)

Material Weakness 2025

Idaho State University

ID

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University reviewed its procedures and reporting processes and added calendar reminders to run queries around our census day each term (since the case identified in the audit was due to a timing issue of a student’s aid period revision and when our automated Exit counseling processes are turned on) to find students who were missed by our automated processes for the adding of EXIT tracking requirement and ensuring timely notifications to the students. Name(s) of the contact person(s) responsible for corrective action James Martin, Director of Financial Aid and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 8/12/2025

View Audit 393093

Finding 1181806 (2025-004)

Material Weakness 2025

University of Rio Grande

OH

Student Financial Aid

Finding Number: 2025-004 Condition: The University did not provide notifications to certain students related to Pell grants. Planned Corrective Action: During the implementation of Anthology Student, the University did not receive sufficient system configuration support or training from Anthology to...

Finding Number: 2025-004 Condition: The University did not provide notifications to certain students related to Pell grants. Planned Corrective Action: During the implementation of Anthology Student, the University did not receive sufficient system configuration support or training from Anthology to properly establish automated Financial Aid Offer and Title IV notification workflows. As a result, the institution did not have the required functionality in place to automatically notify students of their Pell Grant eligibility, scheduled disbursement amounts, and the timing of those disbursements as required under 34 CFR 668.165(a). This lack of configuration and training created gaps in communication and ultimately led to instances in which students did not receive timely notifications before Pell Grant funds were disbursed. Once the University identified these deficiencies, immediate corrective measures were implemented to ensure short-term compliance. Beginning in May 2025, the Financial Aid Office instituted a formal manual notification process. Staff now generate Packaging Status and Disbursement reports on a weekly basis, and these reports are reviewed and acted upon at least bi-weekly to ensure that all upcoming disbursements are captured. Individualized Title IV and Pell Grant notifications are sent to students prior to the crediting of funds. To strengthen internal controls, a secondary review was added so that another staff member verifies that all required notifications have been issued before any Title IV disbursement occurs. These interim procedures and safeguards will remain in effect until the automated notification workflow is fully configured, tested, and implemented. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Corrective Action is currently implemented, starting May 2025

View Audit 393092

Finding 1181805 (2025-003)

Material Weakness 2025

University of Rio Grande

OH

Student Financial Aid

Finding Number: 2025-003 Condition: The University did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The primary cause of this issue was the significant lack of training and support provided during the implementation of Anthology Student. Similar to th...

Finding Number: 2025-003 Condition: The University did not have controls in place to ensure appropriate reporting to COD. Planned Corrective Action: The primary cause of this issue was the significant lack of training and support provided during the implementation of Anthology Student. Similar to the challenges experienced with Return to Title IV (R2T4) processing, University staff did not receive adequate instruction on how to perform Title IV reconciliations within the system or how to extract the data needed to compare internal records with COD. This lack of foundational training made it extremely difficult for staff to understand required reconciliation procedures, identify discrepancies, or troubleshoot system-related issues. In addition, the technical limitations of Anthology Student significantly hindered the University’s ability to perform timely and accurate reconciliations. Anthology Student does not provide a comprehensive or efficient reporting tool that allows users to pull Title IV awarding and disbursement data in a format that aligns with COD records. Staff must manually compile information from multiple system screens and reports, a process that takes several hours and still does not produce a clean, fully reconcilable output. Discussions with other Anthology client institutions confirmed that they are experiencing similar challenges with timely reconciliations due to the system’s reporting limitations. Compounding these reporting challenges, the batch transmission functionality between Anthology Student and COD has been unreliable. Files routinely fail or become “stuck” during transmission, but Anthology offers limited visibility into batch processing status. Until February 2026, the University relied on a system report to identify failed or stalled batches; however, an Anthology system update removed this report and the capability altogether. Without access to this tool, staff have had little ability to monitor or verify successful COD transmission, further complicating reconciliation efforts. Another contributing factor is staffing capacity. The Financial Aid Office has limited personnel, and the extensive time required to manually pull data, consolidate reports, and investigate discrepancies has made it challenging to dedicate the uninterrupted hours required for reconciliation—especially without adequate system training or tools. The University is taking the following steps to address this finding: 1. Scheduled Reconciliation Intervals: Calendar reminders and dedicated appointment blocks will be established every 30–60 days to ensure staff have protected time to complete Title IV reconciliations. 2. Staff Training and Support: The Financial Aid Office will continue working with Anthology Support to obtain the training necessary to understand where and how to locate all required Title IV data within the system. We will also pursue additional training and documentation from Ellucian/Anthology on proper reconciliation procedures. 3. Enhanced Manual Oversight: Until system reliability improves, staff will continue performing manual reviews of Title IV disbursements, adjustments, and COD submissions to confirm accuracy and identify unresolved transmission issues. These actions will remain in place until Anthology Student provides reliable reporting capabilities and complete, consistent training, enabling the University to perform reconciliations accurately and on time. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Scheduled reconciliation intervals were implemented beginning with the Spring 2026 semester on February 19, 2026. Staff training and the pursuit of additional system support will continue on an ongoing basis as part of the University’s continuous improvement efforts.

View Audit 393092

Finding 1181803 (2025-002)

Material Weakness 2025

University of Rio Grande

OH

Student Financial Aid

Finding Number: 2025-002 Condition: The University did not return all Title IV funds in a timely manner to the Department of Education for certain students who withdrew during the year. Planned Corrective Action: The primary underlying cause of this issues was the significant lack of training, guida...

Finding Number: 2025-002 Condition: The University did not return all Title IV funds in a timely manner to the Department of Education for certain students who withdrew during the year. Planned Corrective Action: The primary underlying cause of this issues was the significant lack of training, guidance, and onboarding support provided by Anthology during the implementation of the Anthology Student system. Prior to golive, the University was unable to fully test the Title IV awarding, disbursing, and adjustment processes because file transmissions to COD (Common Origination and Disbursement) can only be executed using live data. This limitation prevented staff from validating system behavior in a testing environment and further hindered the understanding of the required processes, procedures, and communication workflows between Anthology Student and COD. As a result, staff lacked critical knowledge needed to ensure Title IV transactions—including those tied to Return to Title IV (R2T4) calculations—were correctly generated and transmitted. Corrective action has already been implemented. The Financial Aid Office now manually reviews and verifies all Title IV awarding, disbursement, and adjustment transactions—including those related to R2T4—to ensure successful submission to COD. Once the R2T4 calculation has been completed in COD, the Financial Aid Advisor manually updates the student’s account in Anthology Student. The Business Office then posts the corresponding adjustment to the student ledger. After the Business Office posts the Title IV activity, the Financial Aid Advisor manually processes the related adjustments and disbursements through COD to ensure the timely return and/or disbursement of funds associated with the R2T4 calculation. These manual oversight procedures will remain in place until the University receives additional and adequate training from Anthology that ensures consistent and reliable electronic transmission between Anthology Student and COD. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Corrective Action Plan was implemented in February 2025

View Audit 393092

Finding 1181801 (2025-001)

Material Weakness 2025

University of Rio Grande

OH

Student Financial Aid

Finding Number: 2025-001 Condition: The University of Rio Grande did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: The Director of Financial Aid and the Registrar will establish a formal communication and notification proce...

Finding Number: 2025-001 Condition: The University of Rio Grande did not report student status changes accurately for certain students who withdrew during the year. Planned Corrective Action: The Director of Financial Aid and the Registrar will establish a formal communication and notification process to review enrollment statuses and status changes for all students who begin attendance each semester. Recurring meetings and calendar reminders will be scheduled every 30 days to ensure this review is conducted consistently and collaboratively. The University is also in the process of updating its student withdrawal process from a paper/PDF form to a fully electronic submission process. This new system will automatically notify all pertinent departments when a student initiates a withdrawal, ensuring timely communication and reducing the likelihood of missed or delayed reporting. Implementing this electronic workflow will further strengthen internal controls and directly support the corrective action plan. The Director of Financial Aid will receive direct access to the National Student Clearinghouse and will be enrolled in automated email alerts to support timely and accurate reporting of all enrollment changes. In the event the Director of Financial Aid is unavailable for the scheduled 30-day review, a designated member of the Financial Aid Office will participate in the review to ensure the process is completed without interruption. Contact person responsible for corrective action: Chad Curley, Director of Financial Aid Anticipated Completion Date: Corrective action implemented on 2/13/2026. The electronic withdrawal process is set to be implemented by end of May 2026.

View Audit 393092

Finding 1181796 (2025-001)

Material Weakness 2025

Palo Alto History Museum

CA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

The Organization is currently updating its Accounting Policies and Procedures. The revised policies will include a provision requiring that, if federal awards subject to Uniform Guidance (2 CFR Part 200) are received, all required federal financial reports will be independently reviewed and approved...

The Organization is currently updating its Accounting Policies and Procedures. The revised policies will include a provision requiring that, if federal awards subject to Uniform Guidance (2 CFR Part 200) are received, all required federal financial reports will be independently reviewed and approved prior to submission. The Board Treasurer will perform the review, or the Finance Committee Chair if the Treasurer is unavailable. Documentation of the review will be retained with the related reports.

View Audit 393079

Finding 1181795 (2025-001)

Material Weakness 2025

North Fayette Valley Community School District

IA

Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN February 10, 2026 To: U.S. Department of Agriculture North Fayette Valley Community School District respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Hacker, Nelson & Co., CPAs 12...

CORRECTIVE ACTION PLAN February 10, 2026 To: U.S. Department of Agriculture North Fayette Valley Community School District respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Hacker, Nelson & Co., CPAs 123 W. Water Street Decorah, IA 52101 Audit period: Year ended June 30, 2025. The finding from the June 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDING - FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Agriculture: Child Nutrition Cluster: Federal Assistance Listing Number 10.553: School Breakfast Program Federal Assistance Listing Number 10.555: National School Lunch Program Internal control deficiency: See Finding 2025-001 Recommendation: The District should review the operating procedures of the District offices to obtain the maximum internal control possible under the circumstances utilizing currently available staff. While we do recognize that the District is not large enough to permit a segregation of duties for effective internal controls, we believe it is important the Board be aware that this condition does exist. Action Taken: Management is cognizant of this limitation and will implement additional procedures where possible. Anticipated Date of Completion: June 30, 2026.

View Audit 393077

Finding 1181793 (2025-001)

Material Weakness 2025

Roseman University of Health Sciences

NV

Special Tests & Provisions Student Financial Aid Eligibility

Finding: 2025-001: Special Tests and Provisions – Eligibility – Significant Deficiency in Internal Control over Compliance Corrective Action Plan – The University conducted a review of affected students and identified 19 additional students with enrollment intensity that was incorrectly calculated. ...

Finding: 2025-001: Special Tests and Provisions – Eligibility – Significant Deficiency in Internal Control over Compliance Corrective Action Plan – The University conducted a review of affected students and identified 19 additional students with enrollment intensity that was incorrectly calculated. The University has returned a total of $2,448 to the Pell Grant program and has written off the corresponding balances on the affected students’ ledgers. In January 2025, the University fully implemented a new, integrated Student Information and Financial Aid System that automates enrollment intensity calculations based on real-time data from the Registrar’s Office. This eliminates manual entry and ensures Pell Grant disbursements are automatically and accurately calculated. There is no option to manually change the Pell enrollment intensity or award amount in the new system. The Financial Aid staff involved in Pell packaging and processing have been retrained on enrollment intensity calculations and system functionality. Contact Person Responsible for Corrective Action: Sally Mickelson, Director of Financial Aid Completion Date: November 13,2025

View Audit 393075

Corrective Action Plans

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