Corrective Action Plans

Finding 1172997 (2025-002)

Material Weakness 2025

IN

Procurement, Suspension & Debarment § 200.1 § 200.214 § 200.303 § 200.317 § 200.318

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person(s) Responsible for Corrective Action: Mendy Shrout & Billy Boyette Contact Phone Number and Email Address(es): (765) 795-4664 / mshrout@cloverdale.k12.in.us & bboyette@cloverdale.k12.i...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person(s) Responsible for Corrective Action: Mendy Shrout & Billy Boyette Contact Phone Number and Email Address(es): (765) 795-4664 / mshrout@cloverdale.k12.in.us & bboyette@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement We will be updating the Policy 6325 for Micro purchases from $10,000.00 to $50,000.00. We are in policy review now. Suspension and Debarment All new vendors entered into the system are checked by the Corporation Treasurer through the Office of Inspector General search, printed and kept on file in the Corporation office. Further, all vendors used by the Food Service department have been updated to be current. Anticipated Completion Date: March 1, 2026

View Audit 386450

Finding 1172993 (2025-001)

Material Weakness 2025

Cloverdale Community School Corporation

IN

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

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person(s) Responsible for Corrective Action: Mendy Shrout & Billy Boyette Contact Phone Number and Email Address(es): (765) 795-4664 / mshrout@cloverdale.k12.in.us & bboyette@cloverdale.k12.in.us Views of Responsib...

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person(s) Responsible for Corrective Action: Mendy Shrout & Billy Boyette Contact Phone Number and Email Address(es): (765) 795-4664 / mshrout@cloverdale.k12.in.us & bboyette@cloverdale.k12.in.us Views of Responsible Officials: Option 1: We concur with the finding. Description of Corrective Action Plan: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Payroll distribution reports will be periodically reviewed and initialed by the Corporation Treasurer to assure employees paid are working in the cafeteria. Eligibility Cafeteria Managers will initially enter eligibility information into the POS (Harmony). The Food Service Director or Café Office Manager will sign off on the reports as records are entered. Reporting Food Service Director will provide the reports to the Corporation Treasurer or the Café Office Manager on a monthly basis for review. The reviewer will then initial the documents. Anticipated Completion Date: February 1, 2026

View Audit 386450

Finding 1172989 (2025-005)

Material Weakness 2025

Metropolitan School District of Decatur Township

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

FINDING 2025-005 Finding Subject: COVID-19 – Education Stabilization Fund – Special Test and Provision - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org View...

FINDING 2025-005 Finding Subject: COVID-19 – Education Stabilization Fund – Special Test and Provision - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Education Stabilization Fund grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

View Audit 386440

Finding 1172987 (2025-004)

Material Weakness 2025

Metropolitan School District of Decatur Township

IN

Equipment & Real Property Management § 200.303 § 200.313

FINDING 2025-004 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org Views of Responsi...

FINDING 2025-004 Finding Subject: COVID-19 – Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Education Stabilization Fund grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

View Audit 386440

Finding 1172985 (2025-003)

Material Weakness 2025

Metropolitan School District of Decatur Township

IN

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.1 § 200.208 § 200.303 § 200.332 § 200.339

FINDING 2025-003 Finding Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Offi...

FINDING 2025-003 Finding Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

View Audit 386440

Finding 1172983 (2025-002)

Material Weakness 2025

Metropolitan School District of Decatur Township

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.317 § 200.318 § 200.319 § 200.320

FINDING 2025-002 Finding Subject: Teacher and School Leader Incentive Grants – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of...

FINDING 2025-002 Finding Subject: Teacher and School Leader Incentive Grants – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

View Audit 386440

Finding 1172978 (2025-001)

Material Weakness 2025

Salvaging Teens at Risk, Inc. Dba North Texas Collegiate Academy

TX

Cash Management Reporting School Nutrition Programs

Background and Context: The District has a long-standing history of strong financial compliance and has not previously received audit findings related to internal controls or reporting. The error was isolated, not systemic, and was identified without evidence of intentional misreporting or ongoing r...

Background and Context: The District has a long-standing history of strong financial compliance and has not previously received audit findings related to internal controls or reporting. The error was isolated, not systemic, and was identified without evidence of intentional misreporting or ongoing risk. The District has implemented additional review steps as identified below to ensure continued accuracy in future submissions. Subject: Finding 2025-001: The finding indicates 2 errors were made in transferring data from the Daily Accuclaim Report to the Monthly Record of Meals Served at the East Campus resulting in an inaccurate request for reimbursement in the amount of approximately $55.00; these errors were made in 2 separate monthly reports during the 2025 fiscal year. Management response to FY 2025-001 Audit Findings The management of the Organization acknowledges the need for stronger internal controls in the administration of the Child Nutrition Meal Reimbursement Task Cluster. The agency implemented refresher training with the Administrative Assistant and the Campus Principal at the East Campus. Training was completed on November 18, 2025. Additionally, the agency has implemented stringent internal controls to ensure that all data regarding meal counts and reimbursement claims will be verified to ensure accuracy. It was noted that this weakness resulted in errors when the Administrative Assistant transferred data from the Daily Accuclaim to the Monthly Record of Meals Served. To prevent any errors in future claims, the following Standard Operating Procedure for all campuses was created: 1. The Administrative Assistant will tabulate meals served and enter daily totals on the Daily Accuclaim Report. The Campus Principal will provide a second count for daily totals and verify that the correct total was entered on the Daily Accuclaim Report. Both the Administrative Assistant and the Campus Principal will initial the Daily Accuclaim Report when verifications have been completed. 2. Data from the Daily Accuclaim Report will be transferred to the Monthly Record of Meals Served. Both the Administrative Assistant and the Campus Principal will verify that data has been correctly transferred and totaled accurately. Both the Administrative Assistant and the Campus Principal will initial the Monthly Record of Meals Served. 3. At the end of each month, Weekly Student Rosters, Daily Accuclaim Reports and the Monthly Record of Meals Served will be forwarded to the Director of Child Nutrition who will verify and initial all reports and enter data in TXUNPS for reimbursement. When all data for the month has been entered, a Summary Report will be printed and submitted to the Superintendent along with all documents for review and approval. Upon Superintendent written approval, the CNP Director will submit requests for reimbursement through TXUNPS. The agency will implement these Standard Operating Procedures beginning with the December 2025, Reimbursement Claim. It is believed that procedures requiring two personnel to review and sign off on all daily and monthly data and before final submission will ensure accuracy in Reimbursement Claims.

View Audit 386430

Finding 1172975 (2025-002)

Material Weakness 2025

Centerburg Local School District

OH

Procurement, Suspension & Debarment Subrecipient Monitoring

A SAM search of the Knox County Educational Service Center will be completed annually when the “request for approval for a Noncompetitive proposal when procuring personnel-based services from a high performing educational service center” application is filed. This is typically completed in February,...

A SAM search of the Knox County Educational Service Center will be completed annually when the “request for approval for a Noncompetitive proposal when procuring personnel-based services from a high performing educational service center” application is filed. This is typically completed in February, and the SAM search has been added to my notes to do at the same time.

View Audit 386420

Finding 1172973 (2025-002)

Material Weakness 2025

Des Moines Area Metropolitan Planning Organization

IA

Reporting Internal Control / Segregation of Duties

Management acknowledges the finding related to year-end receivables and payables. The adjustment noted is related to a limited number of invoices received after fiscal year-end for services performed prior to June 30. Management will continue to refine year-end closing procedures and coordinate with...

Management acknowledges the finding related to year-end receivables and payables. The adjustment noted is related to a limited number of invoices received after fiscal year-end for services performed prior to June 30. Management will continue to refine year-end closing procedures and coordinate with its accounting consultant and independent auditors to ensure receivables and payables are identified and recorded in the appropriate fiscal period.

View Audit 386417

Finding 1172972 (2025-001)

Material Weakness 2025

Des Moines Area Metropolitan Planning Organization

IA

Reporting Internal Control / Segregation of Duties

Management acknowledges the finding related to year-end receivables and payables. The adjustment noted is related to a limited number of invoices received after fiscal year-end for services performed prior to June 30. Management will continue to refine year-end closing procedures and coordinate with...

Management acknowledges the finding related to year-end receivables and payables. The adjustment noted is related to a limited number of invoices received after fiscal year-end for services performed prior to June 30. Management will continue to refine year-end closing procedures and coordinate with its accounting consultant and independent auditors to ensure receivables and payables are identified and recorded in the appropriate fiscal period.

View Audit 386417

Finding 1172971 (2025-001)

Material Weakness 2025

Edadvance

CT

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting

FINDING 2025-001 – Significant Deficiency in Internal Control over Compliance Description of Finding: The State Funding Agency audited the Child Nutrition program and found that the school food authority (SFA) was charged an indirect cost rate less than provided for in the indirect cost rate agreeme...

FINDING 2025-001 – Significant Deficiency in Internal Control over Compliance Description of Finding: The State Funding Agency audited the Child Nutrition program and found that the school food authority (SFA) was charged an indirect cost rate less than provided for in the indirect cost rate agreement and there was no document explaining how the difference would be handled with the nonprofit school food service account. They also identified that food expenses were included in the direct cost base. Food is considered a distorted fund and is not to be included in the direct cost base. Statement of Concurrence or Nonconcurrence: The Agency agrees with this finding during the Audit period and has made the necessary corrections. Corrective Action: The Organization has implemented procedures outlining how discrepancies will be managed. These procedures will be shared with relevant personnel, and training sessions will be conducted to ensure full compliance. Additionally, we have recalculated the indirect costs for FY2025, excluding the food expenses from the direct cost base. This recalculated amount was reflected in the revised financial reporting. Name of Contact Person: Richard Carmelich, Chief Operations Officer Projected Completion Date: June 30, 2025 QUESTIONED COSTS 1. There was $41,868 in questioned costs as a result of the 2025-001 audit finding. The Organization agreed that the cost was unallowable and revised the financial reporting to the satisfaction of the auditing State agency.

View Audit 386411

Finding 1172967 (2025-001)

Material Weakness 2025

Gordon-Rushville Public Schools

NE

Reporting Internal Control / Segregation of Duties

The District understands the inherent risks associated with lack of segregation of accounting functions. The District requires monthly reporting to the Board of Education and the District Superintendent to ensure transactions are recorded, and potential errors and irregularities are identified on a ...

The District understands the inherent risks associated with lack of segregation of accounting functions. The District requires monthly reporting to the Board of Education and the District Superintendent to ensure transactions are recorded, and potential errors and irregularities are identified on a timely basis. The District has implemented procedures to limit the existence of, and mitigate risks associated with, nonsegregated accounting functions. The District has assessed the benefits and costs associated with additional requirements necessary to assure proper segregation of duties and has determined that cost would outweigh any benefits received.

View Audit 386409

Finding 1172956 (2025-001)

Material Weakness 2025

Essex North Supervisory Union

VT

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Material Weakness § 200.303

November 21, 2025 CORRECTIVE ACTION PLAN (Concerning Finding 2025-001) Contact person responsible for corrective action: Jennifer Lawcewicz, Superintendent Corrective Action: The Essex North Supervisory Union will take the following actions to address finding 2025-001- Activities Allowed and Allowab...

November 21, 2025 CORRECTIVE ACTION PLAN (Concerning Finding 2025-001) Contact person responsible for corrective action: Jennifer Lawcewicz, Superintendent Corrective Action: The Essex North Supervisory Union will take the following actions to address finding 2025-001- Activities Allowed and Allowable Costs: 1. Essex North Supervisory Union has created a purchasing and procurement procedure manual with detailed procedures. 2. The business manager and superintendent have shared this document with all employees that are involved in purchasing. 3. The business manager and the superintendent will have regular meetings with the principal and grants manager to ensure that all procedures are being followed. 4. All invoices will continue to be reviewed by the business manager or the superintendent. 5. Purchase Orders will be issued prior to invoice when applicable. Anticipate completion date: Currently in place and happening

View Audit 386363

Finding 1172940 (2025-001)

Material Weakness 2025

Rocky Mountain Institute

CO

Procurement, Suspension & Debarment

RMI will address the identified finding by implementing updated procedures and policies. Under RMI’s revised signature authority policy and legal cover sheet procedures, any independent contractor agreement or contract services agreement must include a ten-digit ComplyAdvantage reference number on t...

RMI will address the identified finding by implementing updated procedures and policies. Under RMI’s revised signature authority policy and legal cover sheet procedures, any independent contractor agreement or contract services agreement must include a ten-digit ComplyAdvantage reference number on the legal cover sheet before the draft agreement can be fully executed. The ComplyAdvantage reference number will be provided by the Procurement Team if the contractor passes the ComplyAdvantage suspension and debarment screening with no issues or concerns. If the contractor does not pass the ComplyAdvantage screening, no reference number will be provided by the Procurement Team on the legal cover sheet, and the request will be rejected by the Legal Team. If a request is rejected, the contracting process is terminated, as RMI’s updated procedures prohibits execution of agreements without a ComplyAdvantage reference number. To initiate the ComplyAdvantage screening process, the RMI program team contact (i.e. a program operations lead/manager, project manager, etc.) must submit a request to the Procurement Team, who will then conduct the ComplyAdvantage screening of the contractor prior to contract execution. The ComplyAdvantage screening is a documented step in RMI’s procurement process checklist. ComplyAdvantage is a leading database for watchlists, anti-money laundering (AML), countering the financing of terrorism (CFT), sanctions, and other risk indicators. ComplyAdvantage screening meets the requirements of 2 CFR 180 and includes verification against the Excluded Parties List System (EPLS) for suspension and debarment. Contact person for corrective action: Anna Itenberg, Senior Legal Director Anticipated Completion Date: October 31, 2025

View Audit 386332

Finding 1172939 (2025-002)

Material Weakness 2025

Midwest Central Community Unit School District No. 191

IL

Internal Control / Segregation of Duties Cash Management Reporting § 200.303

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (business manager) compares the meal counts in the claim to the SDS daily meal ...

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (business manager) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Todd Hellrigel, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.

View Audit 386322

Finding 1172932 (2025-001)

Material Weakness 2025

CONVERSE COUNTY AIRPORT

WY

Subrecipient Monitoring Internal Control / Segregation of Duties

ALTHOUGH THE ACCOUNTING STAFF IS TOO SMALL TO PROVIDE FOR ADEQUATE SEGREGATION OF DUTIES, THERE ARE EFFECTIVE COMPENSATING CONTROLS IN PLACE. PHYSICAL CONTROL OF DOCUMENTS AND CONTROL OF CHECK SIGNATURE AUTHORITY ARE TWO EXAMPLES OF MEASURES USED TO COMPENSATE FOR THE SEGREGATION ISSUE. VOUCHERS ALL...

ALTHOUGH THE ACCOUNTING STAFF IS TOO SMALL TO PROVIDE FOR ADEQUATE SEGREGATION OF DUTIES, THERE ARE EFFECTIVE COMPENSATING CONTROLS IN PLACE. PHYSICAL CONTROL OF DOCUMENTS AND CONTROL OF CHECK SIGNATURE AUTHORITY ARE TWO EXAMPLES OF MEASURES USED TO COMPENSATE FOR THE SEGREGATION ISSUE. VOUCHERS ALL REQUIRE MANAGEMENT APPROVAL, AS WELL AS INVOICES PROCESSED FOR PAYMENT. ON A MONTHLY BASIS, EXPENDITURES ARE REVIEWED BY THE BOARD AND AIRPORT MANAGER, AND BANK STATEMENTS ARE RECONCILED AND REVIEWED. THESE CONTROLS PROVIDE ADEQUATE AND EFFECTIVE SAFEGUARDS TO COMPENSATE FOR THE LACK OF SEGREGATION OF RESPONSIBILITIES IN THE ACCOUNTING DEPARTMENT. STEVE GOOD, AIRPORT MANAGER, IS ABLE TO PROVIDE INFORMATION ON THE STATUS OF THIS CORRECTIVE ACTION.

View Audit 386317

Finding 1172929 (2025-010)

Material Weakness 2025

Randall University

OK

Student Financial Aid Reporting

FINDING 2025-010– FISAP Accuracy Program Name: Federal Work Study ALN and Program Expenditures: 84.033 ($-0-) Award Number: P033A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University did not award Federal Work Study funds during the 24-25 acad...

FINDING 2025-010– FISAP Accuracy Program Name: Federal Work Study ALN and Program Expenditures: 84.033 ($-0-) Award Number: P033A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University did not award Federal Work Study funds during the 24-25 academic year. However, the FISAP reports that students participating in the Federal Work Study Program earned $26,232. An administrative allowance of $1,312 was also claimed. Total Federal Work Study funds per the FISAP totaled $27,544. Corrective Action Plan: Management will work with the third-party servicer to ensure the figures and amounts reported on the FISAP are accurate. An independent review of the FISAP will be completed by the CFO before the FISAP is filed. Anticipated Completion Date: The University anticipates the corrective action being completed by October 1, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172928 (2025-009)

Material Weakness 2025

Randall University

OK

Student Financial Aid

FINDING 2025-009– R2T4 Calculation Program Name: Federal Direct Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($487,504) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Condition Found: R2T4s were not calculated...

FINDING 2025-009– R2T4 Calculation Program Name: Federal Direct Loan Program Federal Pell Grant Program ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($487,504) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Condition Found: R2T4s were not calculated during for the award year ending June 30, 2025. During the compliance testing, it was determined that an R2T4 should have been calculated for two of the seventeen students selected for testing. Corrective Action Plan: Management agrees that the R2T4s were not completed. For the first student, the Student Financial Director determined that while the Federal Pell Grant funds were posted to the student’s account, the funds were never requested from the Department of Education. $1,616 was of aid was removed from the student’s account and only $2,081 will be requested from the Department of Education. For the second student, $1,652 of Subsidized Federal Direct Loan funds were returned to the Department of Education in December 2025. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172926 (2025-008)

Material Weakness 2025

Randall University

OK

Eligibility Student Financial Aid

FINDING 2025-008 – Pell Grant Calculation Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $1,849 Condition Found: The amount of Pell grant awarded was calculated inc...

FINDING 2025-008 – Pell Grant Calculation Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $1,849 Condition Found: The amount of Pell grant awarded was calculated incorrectly for one of the eleven students who received Pell grant funds in our sample. The student received $1,849 of Federal Pell Grant funds that the student was ineligible to receive. Corrective Action Plan: The Student Financial Aid Director is working with the third-party administrator to the return $1,849 to the Department of Education. The Student Financial Aid Director and third-party administrator will work together to verify a student’s enrollment status before disbursing aid. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172925 (2025-007)

Material Weakness 2025

Randall University

OK

Student Financial Aid

FINDING 2025-007 – COD Disbursement Dates Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The Common Origination and Disbursement System (“COD”)...

FINDING 2025-007 – COD Disbursement Dates Program Name: Federal Pell Grant Program ALN and Program Expenditures: 84.063 ($509,088) Award Number: P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The Common Origination and Disbursement System (“COD”) disbursement date did not agree with the disbursement date on the students’ accounts for one of the seventeen students in our compliance testing sample. Corrective Action Plan: The Student Financial Aid Director correct the date the aid was posted to the student account in December 2025. Procedures will be improved to ensure that the disbursements date per COD and the student account agree. Anticipated Completion Date: The corrective action was completed in December 2025. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172924 (2025-006)

Material Weakness 2025

Randall University

OK

Eligibility Student Financial Aid Matching / Level of Effort / Earmarking

FINDING 2025-006 – Federal Direct Loan Eligibility Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Feder...

FINDING 2025-006 – Federal Direct Loan Eligibility Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Federal Direct Loans awarded was incorrect for four of the ten students in our sample that received Federal Direct Loans. In addition, the two of the students was eligible for additional Federal Direct Loan funds. Corrective Action Plan: For the first student, the student was eligible to receive $5,500 of subsidized funds, but only $4,500 was requested. The University gave the student an additional $1,000 of institutional funds to cover the difference in the amount the student was eligible to receive and the amount requested from the Department of Education in December 2025. For the second student, the COD correctly shows the that $5,500 of subsidized aid was disbursed to the student. However, only $4,500 of subsidized loan funds were posted to the student’s account. An institutional scholarship of $1,000 was posted to the student account in December 2025. For the third student, $484 of subsidized loan funds were returned to the Department of Education in December 2025. For the fourth student, the Director of Financial Aid will work with third party administrator to reclassify the subsidized loan funds as unsubsidized loan funds. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172923 (2025-005)

Material Weakness 2025

Randall University

OK

Student Financial Aid Matching / Level of Effort / Earmarking

FINDING 2025-005– NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment sta...

FINDING 2025-005– NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment status changes were reported to the National Student Loan Database System (“NSLDS”) timely for nine of the seventeen students selected for testing. Corrective Action Plan: A new Student Financial Aid Director was hired in July 2025. The Student Financial Aid Director and Registrar will work together to determine and report student enrollment status changes within the required timeframe to NSLDS. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172922 (2025-004)

Material Weakness 2025

Randall University

OK

Student Financial Aid

FINDING 2025-004– Reporting/Internal Control Over the SEFA Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) 84.007 ($ 5,400) Award Number: P268K253315 P063...

FINDING 2025-004– Reporting/Internal Control Over the SEFA Program Name: Federal Direct Student Loan Program Federal Pell Grant Program Federal Supplemental Educational Opportunity Grant ALN and Program Expenditures: 84.268 ($866,312) 84.063 ($509,088) 84.007 ($ 5,400) Award Number: P268K253315 P063P243115 P007A243421 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: Undetermined Condition Found: The University lacked policies and procedures to reconcile the SEFA data to the financial statements or other supporting documentation. The University was on the HCM2 method of payment and could not provide of the listing by student of the aid requested. During the audit, we were unable to reconcile the Amount Due from the Government on the Financial Statement to the amount due per the financial aid records. In addition, aid was posted to student accounts and never requested from the government for five of the seventeen students in our sample. Corrective Action Plan: The bursar, business office staff, and financial aid staff will work together to review and reconcile Title IV posted to the student accounts to the amounts requested from the Department of Education. When discrepancies are found, the University staff will investigate and determine if the student was eligible for aid and request additional funds as necessary. See the possible effect section for the resolution of the students in this finding. Anticipated Completion Date: The University anticipates the corrective action being completed by June 30, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

View Audit 386308

Finding 1172919 (2025-003)

Material Weakness 2025

Randall University

OK

Student Financial Aid Subrecipient Monitoring Cash Management

84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit...

84.063 ($509,088) Award Number: P268K253315 P063P243315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: The University was placed on the Heightened Cash Monitoring Method 2 (“HCM2”) for disbursing aid in May 2023. In the current fiscal year, a Title IV Credit Balance was held for more than 14 days for one of the seventeen students in our sample. Corrective Action Plan: There is no longer a credit balance on the account of the student in question. If time allows, the business office will review student accounts to determine if any additional credit balances should be refunded. Procedures should be improved to ensure the University is following the HCM2 regulations. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

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Finding 1172917 (2025-002)

Material Weakness 2025

Randall University

OK

Student Financial Aid Matching / Level of Effort / Earmarking

FINDING 2025-002 – Exit Interview Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients...

FINDING 2025-002 – Exit Interview Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients in our sample did not complete or were not sent exit interview instructions to complete within thirty days of the student ceasing to be enrolled in the University at least half-time. Corrective Action Plan: A new Financial Aid Director was hired in July 2025. The Financial Aid Director will review the students in question to determine if exit instructions were sent after the thirty-day time period. If an exit interview has not already been sent, the Financial Aid will mail exit interview instructions to the students’ home address. In addition, the Director of Financial Aid will work with the third-party administrator to determine which entity is responsible for sending exit interview information to students. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000

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Corrective Action Plans

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