Corrective Action Plans

Finding 1166335 (2025-002)

Material Weakness 2025

Brac Usa, Inc.

NY

Subrecipient Monitoring Reporting § 200.328

Views of Responsible Officials: In instances where Federal financial and programmatic reports were submitted after the due dates, delays were primarily driven by the time required to obtain and reconcile financial and programmatic data from subrecipients and to complete BRAC USA’s internal reviews a...

Views of Responsible Officials: In instances where Federal financial and programmatic reports were submitted after the due dates, delays were primarily driven by the time required to obtain and reconcile financial and programmatic data from subrecipients and to complete BRAC USA’s internal reviews and sampling procedures. While this resulted in late submissions, our priority was to ensure the completeness, accuracy, and integrity of reported information rather than compromising quality for timeliness. To strengthen compliance going forward, in any instance where BRAC USA anticipates a delay in submitting required Federal financial or programmatic reports, we will proactively communicate with donor or the pass-through entity in advance of the due date, explain the reasons for the delay (including any timing issues related to subrecipient data), and request written approval of a revised reporting deadline. This approach will help ensure transparency, maintain the donor’s ability to effectively monitor grant performance, and document mutual agreement on adjusted submission dates, while still allowing BRAC USA to complete the necessary review and reconciliation procedures to ensure accurate and reliable reporting. Planned Completion Date: December 31, 2025

View Audit 377413

Finding 1166334 (2025-001)

Material Weakness 2025

Brac Usa, Inc.

NY

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332

Views of Responsible Officials: In practice, BRAC USA has consistently evaluated subrecipient risk prior to issuing subawards by considering factors such as prior experience with similar awards, historical audit results, organizational capacity, and financial stability. However, we acknowledge that ...

Views of Responsible Officials: In practice, BRAC USA has consistently evaluated subrecipient risk prior to issuing subawards by considering factors such as prior experience with similar awards, historical audit results, organizational capacity, and financial stability. However, we acknowledge that these assessments were not formalized or consistently documented in a standardized format, as required by 2 CFR § 200.332(c). To address this gap, BRAC USA will develop and implement written procedures and a standardized subrecipient risk assessment tool to be completed and filed prior to issuing Federal subawards. The tool will capture required criteria, including prior audit results, prior performance under similar awards, financial stability indicators, internal control considerations, and any recent staffing or systems changes. These procedures will be incorporated into BRAC USA’s Fiscal Policies and Procedures Manual. The results of each risk assessment will be used to tailor the level and nature of ongoing subrecipient monitoring, and records will be maintained in the grant file to evidence compliance with 2 CFR § 200.332(c). Planned Completion Date: April 30, 2026

View Audit 377413

Finding 1166329 (2025-001)

Material Weakness 2025

Catholic Charities Archdiocese of New Orleans

LA

Reporting

The agency acknowledges the necessity of timely, accurate reporting to funders and stakeholders. The agency plans to implement electronic calendars and checklists which will be used to monitor and manage these deadlines to ensure they are met. We anticipate completion within the fiscal year, 2026.

View Audit 377411

Finding 1166321 (2025-004)

Material Weakness 2025

Bolivar-Richburg Central School District

NY

Cash Management Reporting

Bank Reconciliations, Interfund Balances Reconciliations and Balance Sheet Account Reconciliations. Year ended June 30, 2025. Auditors' Recommendation: We recommend that the District prepare bank reconcilations soon after the end of each month. As part of the reconcilation process the District's gen...

Bank Reconciliations, Interfund Balances Reconciliations and Balance Sheet Account Reconciliations. Year ended June 30, 2025. Auditors' Recommendation: We recommend that the District prepare bank reconcilations soon after the end of each month. As part of the reconcilation process the District's general ledger cash balances should be compared against the bank reconcilation, with any differences being immediately investigated. Once complete, the bank reconcilation should be reviewed by someone independent of the preparer. In addition, a worksheet should be developed which reconciles interfund balances on a monthly basis. Any differences in the reconcilation process should be immediately investigated. We recommend that asset and liability accounts be reconciled on a regular and routine basis. Further, reconcilations should be reviewed by management to ensure their accurate and timely completion. Districts's Response: The District will ensure that bank reconcilations are prepared in a timely manner and verify that balances within the general ledger cash accounts agree to the bank reconcilation, along with ensuring that interfund balances reconcile and that balance sheet asset and liabilities are reconciled to supporting documentation.

View Audit 377390

Finding 1166307 (2025-003)

Material Weakness 2025

Bolivar-Richburg Central School District

NY

Internal Control / Segregation of Duties

Adjusting Journal Entries and Required Disclosures to the 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 new pronouncement, the District should continue to review and accept both p...

Adjusting Journal Entries and Required Disclosures to the 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 new 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 School Business Administrator believes she has a thorough understanding of these financial statements and the ability to make informed judgements based on these financial statements.

View Audit 377390

Finding 1166293 (2025-001)

Material Weakness 2025

Maine School Administrative District No. 1

ME

Allowable Costs / Cost Principles Significant Deficiency § 200.303 § 200.430

Corrective Action Plan Finding Reference: 2025-001 – Allowable Activities/Allowable Costs Federal Program: CFDA 84.010 – Title I Fiscal Year Ended: June 30, 2025 Corrective Action Plan Condition The audit identified weaknesses in internal controls over payroll charges to Title I, creating a risk tha...

Corrective Action Plan Finding Reference: 2025-001 – Allowable Activities/Allowable Costs Federal Program: CFDA 84.010 – Title I Fiscal Year Ended: June 30, 2025 Corrective Action Plan Condition The audit identified weaknesses in internal controls over payroll charges to Title I, creating a risk that costs may be charged to the program in error. Root Cause Although program coding is built into the payroll system during employee setup, controls were not consistently documented or monitored, particularly for staff working across multiple funding sources and for private school Title I employees. A lack of secondary review allowed for one miscoding error and inconsistent position information between contracts and timesheets. Corrective Actions to Be Taken 1. Payroll Coding Review: Implement a second-level review process, led by the Business Manager, to verify all federal program payroll coding each pay period before submission. 2. Position Alignment: Require a monthly reconciliation of contracted positions against timesheet records to ensure consistency. 3. Private School Documentation: Effective immediately, require written wage documentation from private schools for all Title I-funded employees, with documents retained for audit purposes. 4. Update the written procedures related to federal and state funded payroll charges and provide refresher training for payroll and program staff by December 31, 2025. Responsible Officials - Business Manager – Oversight and monitoring of corrective actions - HR/Payroll Specialist – Implementation of payroll coding and reconciliation procedures - Title I Coordinator – Verification and retention of private school documentation Completion Date All corrective actions will be fully implemented by December 31, 2025. Monitoring and Sustainability The District will conduct quarterly internal reviews of Title I payroll activity, maintaining a monitoring log, requiring time and effort sheets and retaining documentation in the business office. Annual refresher training will be provided to ensure ongoing compliance with federal requirements. Views of Responsible Officials The District concurs that stronger documentation and monitoring are necessary. Program coding is established in the payroll system during employee setup, and controls exist to ensure proper allocation. The purpose of the timeclock system is to log hours. The issue arose due to insufficient secondary review rather than the absence of program coding. Immediate corrective measures have already been taken, and the District is committed to implementing the above actions to ensure full compliance with 2 CFR 200.303 and 2 CFR 200.430(g).

View Audit 377389

Finding 1166281 (2025-003)

Material Weakness 2025

Mount Diablo Unified School District

CA

Reporting § 200.19

The District will implement and formalize internal controls to ensure compliance with Title I, Part A graduation rate requirements related to the documentation of student removals from the four-year adjusted cohort. The District will revise and standardize procedures requiring official written docum...

The District will implement and formalize internal controls to ensure compliance with Title I, Part A graduation rate requirements related to the documentation of student removals from the four-year adjusted cohort. The District will revise and standardize procedures requiring official written documentation to be obtained and maintained whenever a student is reported as having transferred out, including confirmation that the student enrolled in another school. A meeting will be held in the next few days with MDUSD staff responsible for enrollment, withdrawals, and CALPADS reporting will receive training on cohort rules, documentation requirements, and record retention expectations to ensure consistent application across all sites. The District will also establish periodic monitoring and internal review processes to verify that supporting documentation is maintained prior to removing students from the cohort and that records align with CALPADS data submissions. Responsible Person for Corrective Action Plan Christina Filios, Assistant Director: Educational Services Aurelia Buscemi, Director of Enrollment Services Melissa Brennan, DIrector of Student Services Implementation Date of Corrective Action Plan January 5, 2026 - Coordinator of Fiscal Compliance and Reporting will meet with District Administrators to provide Audit Finding and provide guidance on procedures and set expectations. The District will monitor this process during Fiscal Year 2025-26.

View Audit 377357

Finding 1166279 (2025-001)

Material Weakness 2025

Fulton Public School District

MO

School Nutrition Programs

The District will provide food service staff with additional training on the federal verification process and sampling requirements. The District will conduct an internal review, at least twice a year, of a sample of verifications to ensure it is meeting the verification requirements.

View Audit 377341

Finding 1166273 (2025-004)

Material Weakness 2025

Western Wyoming Community College

WY

Student Financial Aid § 200.208 § 200.339

Western Wyoming Community College experienced an unexpected turnover in the Director position and had a consultant from Dynamic Campus and an Interim Director of Financial Aid step in to help assist staff during this time. Due to lack of communication, reporting of a return of Title IV funds for the...

Western Wyoming Community College experienced an unexpected turnover in the Director position and had a consultant from Dynamic Campus and an Interim Director of Financial Aid step in to help assist staff during this time. Due to lack of communication, reporting of a return of Title IV funds for the one student found in the audit did not occur as it normally would. Corrective Action A new Director of Financial Aid has been hired and has worked with the Assistant Director of Financial Aid to train on the process of Return to Title IV and timely reporting. • Each day the total withdrawal list is checked to determine the students who are receiving federal aid and may need to have a Return of Title IV calculation performed. • The students who are determined to require a Return of Title IV calculation are then processed for the Return of Title IV funds. This process is completed by the Assistant Director or Director of Financial Aid. • Once the process is complete and funds have been adjusted appropriately the Assistant Director or Director of Financial immediately run the process to export the files and funds out to the Common Origination and Disbursement (COD). • The next day COD is checked to ensure no reject(s) of the file(s) have occurred. If there are errors/rejects of the file the issue is researched and fixed to be accepted by COD. This process will ensure the timely reporting and return of funds to the Department of Education. Anticipated Completion Date: October 24, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid

View Audit 377340

Finding 1166272 (2025-003)

Material Weakness 2025

Western Wyoming Community College

WY

Student Financial Aid Eligibility Period of Performance § 200.208 § 200.339

Western Wyoming Community College experienced a transition in leadership within the Financial Aid Office, resulting in a change in the Director of Financial Aid position. This transition caused disruptions in communication and process continuity between the Financial Aid, Registrar, and Institutiona...

Western Wyoming Community College experienced a transition in leadership within the Financial Aid Office, resulting in a change in the Director of Financial Aid position. This transition caused disruptions in communication and process continuity between the Financial Aid, Registrar, and Institutional Effectiveness offices. As a result, inconsistencies were identified in the timing and accuracy of enrollment reporting to the National Student Clearinghouse (NSC) and the National Student Loan Data System (NSLDS). Corrective Action Plan 1. Leadership and Process Realignment a. A new Director of Financial Aid has been appointed and is collaborating with the Institutional Effectiveness Office and the Registrar to define clear processes and timelines for Records & Registration and Financial Aid operations. b. The Director of Financial Aid and Registrar will maintain continuous communication to ensure timely and accurate enrollment reporting and prompt correction of any identified discrepancies. c. The Director of Financial Aid and Registrar will work together to develop a Standard Operating Process (SOP) to ensure if any future attrition occurs in either department that anyone else in those departments will be able to step in and continue processing without interruption ensuring timely and accurate enrollment reporting continues. 2. Implementation of Controls for Third-Party Reporting a. Recognizing the benefits and responsibilities of using the National Student Clearinghouse (NSC) for enrollment reporting, the institution has implemented controls to verify the accuracy of data transmitted through this third-party servicer. b. The Assistant Director (or the Director of Financial Aid in the Assistant Director’s absence) will generate the Summary Return of Funds Report (ROFS) from Colleague each term and provide a copy to the Registrar for enrollment verification and reconciliation. 3. Quarterly Reconciliation and Internal Review a. The Financial Aid Office will conduct a quarterly comparison between Colleague and NSLDS records to ensure consistency of enrollment and status dates. b. Any discrepancies identified will be communicated to the Registrar for prompt resolution. c. Results of the quarterly reviews will be documented and used for internal compliance monitoring and training. 4. Updated End-of-Term Procedure To ensure ongoing accuracy and compliance, the following revised steps will be followed each term: a. The Director or Assistant Director of Financial Aid will run an All F Report after final grades are posted. b. The Director and Assistant Director of Financial Aid will jointly calculate Return to Title IV (R2T4) funds. c. The Return of Funds Report (ROFS) will be provided to the Registrar monthly to verify last date of attendance and withdrawal dates against Colleague records. d. The Registrar will verify subsequent semester enrollments and continuously monitor student enrollment, reporting any changes to Financial Aid leadership. e. The Registrar will submit end-of-term enrollment data to the National Student Clearinghouse as usual, and one week before the next term begins, will submit the end-of-term R2T4 list to prevent overwriting by subsequent semester reporting. 5. Training and Internal Audit Enhancement a. The Financial Aid and Registrar’s Offices will use findings from this audit to develop staff training on identifying and correcting data discrepancies during the quarterly reconciliation process. b. The Director of Financial Aid will review 80% of R2T4 files during each semester for accuracy in reporting and documentation. 6. Graduation Data Accuracy a. The Registrar’s Office utilizes the Update Academic Credentials File (UACF) in Colleague to batch post student degrees and certificates three times per year (end of spring, summer, and fall terms). b. It was determined that the automatic graduation date populates correctly only when students have a single program with no changes. For students with multiple programs or program changes, the graduation date must be entered manually to ensure accuracy. c. The Registrar will oversee the upload of graduates and verification of accurate credential dates, ensuring these dates are correctly reflected in NSC and the Director or Assistant Director of Financial Aid will make sure the dates are correctly reflected in the NSLDS system. d. The Registrar and Director of Financial Aid will conduct joint reviews to verify that all graduation and enrollment data are reported correctly. Anticipated Completion Date: June 30, 2026 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, and Kayla Miller, Registrar

View Audit 377340

Finding 1166270 (2025-002)

Material Weakness 2025

Western Wyoming Community College

WY

Student Financial Aid Cash Management Reporting § 200.208 § 200.339

Western Wyoming Community College experienced unexpected turnover in the Director of Financial Aid position, which impacted financial aid reporting and reconciliation processes. Due to access issues with federal systems required for conducting reconciliations and the departure of a consultant who di...

Western Wyoming Community College experienced unexpected turnover in the Director of Financial Aid position, which impacted financial aid reporting and reconciliation processes. Due to access issues with federal systems required for conducting reconciliations and the departure of a consultant who did not retain documentation for completed reconciliations, no reconciliations were available for review for the 2024/2025 Academic Year and 2025 Fiscal Year. Corrective Action Plan 1. Staffing and Training a. A new Director of Financial Aid has been hired and has completed training on the reconciliation process for both Pell Grants and Direct Loans in collaboration with the Assistant Director of Financial Aid. b. Cross-training has been implemented to ensure continuity of operations in the event of future staff turnover. 2. Establishment of Standard Operating Procedures (SOP) a. The Financial Aid Office has worked with the Business/Bursar’s Office to develop and document a Standard Operating Procedure (SOP) governing: • The drawdown of Title IV funds. • The reconciliation process for Pell and Direct Loan programs. b. The SOP outlines responsible parties, required documentation, and timelines for reconciliation and reporting. 3. Monthly Reconciliation Schedule a. A reconciliation schedule has been established requiring completion of Pell and Direct Loan reconciliations by the 15th of each month, or as soon thereafter as federal reports become available. b. Once reconciliations are confirmed as accurate and complete with the Business/Bursar’s Office, drawdowns of funds will occur on or near the 15th of each month, depending on calendar dates and federal system availability. 4. Compliance Alignment a. This process ensures timely and accurate reconciliation of Pell Grant and Direct Loan funding in accordance with 34 CFR 685.300(b)(5) and related federal cash management requirements. Anticipated Completion Date: November 15, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid, Assistant Director of Financial Aid, Business/Bursar’s Office

View Audit 377340

Finding 1166269 (2025-001)

Material Weakness 2025

Western Wyoming Community College

WY

Student Financial Aid Reporting § 200.208 § 200.339

Western Wyoming Community College experienced an unexpected turnover in the Director position which impacted the timeliness of reporting. Corrective Action A new Director of Financial Aid has been hired and has worked with the Assistant Director of Financial Aid to train on the process of reporting ...

Western Wyoming Community College experienced an unexpected turnover in the Director position which impacted the timeliness of reporting. Corrective Action A new Director of Financial Aid has been hired and has worked with the Assistant Director of Financial Aid to train on the process of reporting to COD within the 15 day period after disbursing federal aid. • Any available funds are disbursed each Monday throughout the semester, except for when a holiday falls on a Monday. Funds are then disbursed on the next working business day. • The process to export these disbursements to the Department of Education are performed the same day or the following day after the Business office has ran the transmittal process. This process is completed by the Assistant Director or Director of Financial Aid. • Once the process is complete and funds have been exported to the Department of Education through the Common Origination and Disbursement (COD) portal the Assistant Director or Director of Financial will to ensure no reject(s) of the file(s) have occurred. If there are errors/rejects of the file the issue is researched and fixed until accepted by COD. This process will ensure the timely reporting to the Department of Education. Anticipated Completion Date: October 24, 2025 Contact Persons: DeeAnna Archuleta, Director of Financial Aid

View Audit 377340

Finding 1166268 (2025-002)

Material Weakness 2025

ACADIANA OUTREACH CENTER, INC

LA

Special Tests & Provisions Procurement, Suspension & Debarment HUD Housing Programs

Home Investment Partnerships Program- American Rescue Plan Act (14.239) 2025-002 Special Tests and Provisions- Real Property Acquisitions and Relocation Assistance (URA) Recommendation: The Organization should obtain appraisals prior to the negotiations and/or purchase of real property when utilizin...

Home Investment Partnerships Program- American Rescue Plan Act (14.239) 2025-002 Special Tests and Provisions- Real Property Acquisitions and Relocation Assistance (URA) Recommendation: The Organization should obtain appraisals prior to the negotiations and/or purchase of real property when utilizing funds from local, state, or federal sources. Corrective Action Plan: Management was not aware of the appraisal requirement at the time the property was purchased. Upon becoming aware of the requirement, management promptly engaged a certified appraiser and obtained an appraisal of the acquired property, which substantiated that the fair market value exceeded the purchase price. To prevent recurrence, management will review and update its policies and procedures governing the acquisition of real property with public funds. Revised procedures will require that a certified appraisal be obtained prior to negotiations and purchase to ensure that the acquisition price does not exceed fair market value.

View Audit 377337

Finding 1166267 (2025-001)

Material Weakness 2025

ACADIANA OUTREACH CENTER, INC

LA

Special Tests & Provisions Procurement, Suspension & Debarment HUD Housing Programs

Home Investment Partnerships Program- American Rescue Plan Act (14.239) 2025-001 Special Tests and Provisions- Real Property Acquisitions and Relocation Assistance (URA) Recommendation: The Organization should obtain appraisals prior to the negotiations and/or purchase of real property when utilizin...

Home Investment Partnerships Program- American Rescue Plan Act (14.239) 2025-001 Special Tests and Provisions- Real Property Acquisitions and Relocation Assistance (URA) Recommendation: The Organization should obtain appraisals prior to the negotiations and/or purchase of real property when utilizing funds from local, state, or federal sources. Corrective Action Plan: Management was not aware of the appraisal requirement at the time the property was purchased. Upon becoming aware of the requirement, management promptly engaged a certified appraiser and obtained an appraisal of the acquired property, which substantiated that the fair market value exceeded the purchase price. To prevent recurrence, management will review and update its policies and procedures governing the acquisition of real property with public funds. Revised procedures will require that a certified appraisal be obtained prior to negotiations and purchase to ensure that the acquisition price does not exceed fair market value.

View Audit 377337

Finding 1166266 (2025-001)

Material Weakness 2025

Rockingham Nutrition and Meals on Wheels Program

NH

Matching / Level of Effort / Earmarking § 200.303

Planned Corrective Action: 1. Secure from DHHS written description of the local match required under our contract. 2. Based on confirmation of this requirement, create a separate tracking spreadsheet to monitor compliance as part of the DHHS quarterly reporting process. Planned Implementation Date o...

Planned Corrective Action: 1. Secure from DHHS written description of the local match required under our contract. 2. Based on confirmation of this requirement, create a separate tracking spreadsheet to monitor compliance as part of the DHHS quarterly reporting process. Planned Implementation Date of Corrective Action: June 30, 2026 Person Responsible for Corrective Action: Tim Diaz, Executive Director

View Audit 377335

Finding 1166263 (2025-003)

Material Weakness 2025

City Colleges of Chicago

IL

Subrecipient Monitoring Reporting § 200.303

Condition For one of the four reports tested for the Higher Education Institutional Aid Program, City Colleges did not timely submit a quarterly report to the Pass-Through Entity (PTE). A quarterly performance report was due on May 1, 2025 and submitted 14 days late on May 15, 2025. Cause Submission...

Condition For one of the four reports tested for the Higher Education Institutional Aid Program, City Colleges did not timely submit a quarterly report to the Pass-Through Entity (PTE). A quarterly performance report was due on May 1, 2025 and submitted 14 days late on May 15, 2025. Cause Submission delay was the result of miscommunication between PIs and the grantor. Corrective Action Taken or Planned The Institutional Resource Development (IRD) team will review all subaward grant contracts and work with the colleges to ensure that Tasks are entered into the Salesforce system to provide automatic two-week reminders to the PIs when performance reports are due to the pass-through entity (PTE). Contact Person: Lizz Gardner, Associate Vice Chancellor, Institutional Resource Development Anticipated Completion Date: January 31, 2026

View Audit 377334

Finding 1166262 (2025-001)

Material Weakness 2025

City Colleges of Chicago

IL

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

Condition During our testing over direct loan disbursement notifications, we found that for twenty out of twenty students tested, City Colleges could not provide evidence that notifications were sent within the required timeframe informing the student, or parent, that a credit will be made to the st...

Condition During our testing over direct loan disbursement notifications, we found that for twenty out of twenty students tested, City Colleges could not provide evidence that notifications were sent within the required timeframe informing the student, or parent, that a credit will be made to the student’s account for a direct loan disbursement. While City Colleges demonstrated that its system was configured to automatically send notification letters and confirmed that notifications were issued, City Colleges could not provide documentation showing the specific date each notification was sent in relation to the loan disbursement. Cause City Colleges’ system is designed to record the date notifications are sent to students; however, it does not retain a copy of the actual notification content that was transmitted. Corrective Action Taken or Planned City Colleges’ IT team, in collaboration with a consultant, will configure the system to bring all Direct Loan communication letters into the Financial Aid (FA) Status pages. Integrating these letters directly into the FA Status page will ensure they are easily accessible for FA staff. As part of this enhancement, City Colleges will be able to view a timestamp indicating when each communication was sent to the student, as well as view the information required to be communicated by 34 CFR 668.165. Contact Person: Leticia Garcia, District Director of Student Financial Aid Anticipated Completion Date: December 13, 2025

View Audit 377334

Finding 1166261 (2025-002)

Material Weakness 2025

City Colleges of Chicago

IL

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Condition For one out of forty students tested, City Colleges properly recalculated a return of Title IV funds for a student but did not subsequently adjust the student's account to perform the return or notify the student of the adjusted award amount. Cause The lack of return of Title IV funds was ...

Condition For one out of forty students tested, City Colleges properly recalculated a return of Title IV funds for a student but did not subsequently adjust the student's account to perform the return or notify the student of the adjusted award amount. Cause The lack of return of Title IV funds was an oversight due to human error. Corrective Action Taken or Planned To strengthen internal controls, the District Office assigned an analyst to conduct a review of a random selection of files across all seven colleges scheduled for audit to help identify any discrepancies early and ensure compliance. All R2T4 specialists will receive yearly refresher trainings on R2T4 procedures and controls. Contact Person: Leticia Garcia, District Director of Student Financial Aid Anticipated Completion Date: December 13, 2025

View Audit 377334

Finding 1166260 (2025-001)

Material Weakness 2025

Tongue River Valley Joint Powers Board

WY

Matching / Level of Effort / Earmarking

2025-001 Loan Reserve Requirement Non-Compliance The Chairman of the Tongue River Valley Joint Powers Board will continue to work with USDA-RD to address this issue. The Board and the USDA have received a purchase agreement from Montana Dakota Utilities Co. for the purchase of the Tongue River Gas s...

2025-001 Loan Reserve Requirement Non-Compliance The Chairman of the Tongue River Valley Joint Powers Board will continue to work with USDA-RD to address this issue. The Board and the USDA have received a purchase agreement from Montana Dakota Utilities Co. for the purchase of the Tongue River Gas system. The sale is pending approval for the Wyoming Public Service Commission.

View Audit 377329

Finding 1166259 (2025-002)

Material Weakness 2025

New River Health Association, Inc.

WV

Procurement, Suspension & Debarment HUD Housing Programs Reporting

Management agrees with the auditors' recommendations. In the upcoming year it is expected that new accounting leadership and Grant Management will work together to ensure the accuracy of the UDS Report. Organization contact persons responsible for corrective action: Michele Sarrett, Chief Financial ...

Management agrees with the auditors' recommendations. In the upcoming year it is expected that new accounting leadership and Grant Management will work together to ensure the accuracy of the UDS Report. Organization contact persons responsible for corrective action: Michele Sarrett, Chief Financial Officer. Anticipated completion date: 2/15/26

View Audit 377319

Finding 1166256 (2025-002)

Material Weakness 2025

Fremont County School District #1

WY

Special Tests & Provisions Subrecipient Monitoring

Name of Contact Person Travis Sweeney, SFO Business Manager Corrective Action For future projects of this nature that are funded with federal dollars the District will implement a written procedure to ensure weekly certified payrolls are obtained, reviewed, and documented prior to payment approval. ...

Name of Contact Person Travis Sweeney, SFO Business Manager Corrective Action For future projects of this nature that are funded with federal dollars the District will implement a written procedure to ensure weekly certified payrolls are obtained, reviewed, and documented prior to payment approval. The District will communicate these requirements to contractors and maintain a monitoring log going forward. Proposed Completion Date Fiscal year ended June 30, 2026

View Audit 377280

Finding 1166253 (2025-001)

Material Weakness 2025

Fremont County School District #1

WY

Subrecipient Monitoring Reporting

Name of Contact Person Travis Sweeney, SFO Business Manager Corrective Action In the future all supporting documentation will be retained by Business Office personnel and kept in the audit file. Proposed Completion Date Fiscal year ended June 30, 2026

View Audit 377280

Finding 1166247 (2025-003)

Material Weakness 2025

Ludington Area School District

MI

Procurement, Suspension & Debarment Eligibility

Management agrees with the finding identified and is in process of implementing the recommendation. The District will implement procedures to ensure all vendors paid with Federal awards are reviewed for suspension and debarment prior to payment and that evidence of the review is documented and maint...

Management agrees with the finding identified and is in process of implementing the recommendation. The District will implement procedures to ensure all vendors paid with Federal awards are reviewed for suspension and debarment prior to payment and that evidence of the review is documented and maintained in the proper files. It will be the responsibility of the Director of Business Services and accounts payable personnel to impelement these procedures.

View Audit 377274

Finding 1166242 (2025-001)

Material Weakness 2025

Shepherd Public School District

MI

Allowable Costs / Cost Principles § 200.402

Following the district's normal grant process with ESSER III was very difficult. ESSER III was a three-year grant. This made the process of reviewing, monitoring and amending extremely difficult. Using a normal year-to-year grant process, with carryover and a new application each year, the district ...

Following the district's normal grant process with ESSER III was very difficult. ESSER III was a three-year grant. This made the process of reviewing, monitoring and amending extremely difficult. Using a normal year-to-year grant process, with carryover and a new application each year, the district could have avoided the issues that led up to this finding. That being said, the district will implement a process that allows for improved planning for expenditures and an improved monitoring of the approved budget. Through proper planning, the "last-minute" spending would be avoidable. In addition to improving the planning process, the district has implemented monthly meetings between the Director of Business Services and the Federal Programs Director. The focus of these meetings will be to complete a monthly review of planned expenses, recorded expenses, the general ledger budget within our accounting system and the budget approved in Nexsys. This monthly review, will allow the district to ensure that expenditures are classified and recorded properly. This also allows for spending to align with the approved budgets for all federal grants. This process is in addition to the approval process that is in place within the district's accounting sysem, Munis. All expenses are approved by building administrators, central office, the Business Director and then, finally, the Shepherd Board of Education as the final approval. The planned monthly meeting process for the monthly review of our federal grants will have the most impact on continued improvement of the district's internal control process.

View Audit 377272

Finding 1166240 (2025-001)

Material Weakness 2025

Good Shepherd Real Estate Holding, LLC D/b/a the Good Shepherd

OH

HUD Housing Programs

Condition: The Corporation deposited prior year surplus cash 297 days after the deadline stated in the Real Estate Assessment Center’s Summary of Financial Reporting and Auditing Guidance for HUD (FRAG Guide) under Section 2.8. Planned Corrective Action: Management acknowledges noncompliance in the ...

Condition: The Corporation deposited prior year surplus cash 297 days after the deadline stated in the Real Estate Assessment Center’s Summary of Financial Reporting and Auditing Guidance for HUD (FRAG Guide) under Section 2.8. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management deposited the surplus cash amount of $18,011 into residual receipts on July 22, 2025. Contact person responsible for corrective action: Julie Fratlanne, CFO Anticipated completion Date: 7/22/2025

View Audit 377271

Corrective Action Plans

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