Corrective Action Plans

Finding 1175480 (2025-003)

Material Weakness 2025

Knox College

IL

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

Identifying Number: 2025-003 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA: • The College has performed a risk assessment utilizing internal reso...

Identifying Number: 2025-003 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA: • The College has performed a risk assessment utilizing internal resources but has not fully integrated the information security program on the results of this assessment, nor has the College included all required elements of internal and external risks to the security, confidentiality or integrity of customer information. The College’s risk assessment is in the process of implementing an inventory of IT systems that process and store customer information and the compliance with information security elements related to multifactor authentication, access control, change management, logging and alerting and encryption. • The College has not identified, designed or implemented safeguards for all of the risks identified in the risk assessment. The safeguards do not include the identification of security events the detection and response capabilities to support incident response is still being developed. • The College has not been able to test safeguards because safeguards have not been fully designed or implemented in response to the risk assessment. • The College has not developed written policies and procedures to ensure that personnel are able to enact the information security program. There is a lack of evidence of leadership being required to report to the board or an appropriate supervisory council to ensure those charged with governance are informed on the current state of the information security program. Corrective Actions Taken or Planned: 1. Integration of Risk Assessment Results • Corrective Actions Taken or Planned: Complete a new risk assessment for our new information systems and fully integrate the results including safeguards into the College’s information security program. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 2. Provide Training for Written Policies and Procedures • Corrective Actions Taken or Planned: Distribute written policies and procedures to ensure personnel can enact the information security program. Provide training to all relevant staff. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 3. Testing of Safeguards • Corrective Actions Taken or Planned: Conduct regular testing of implemented safeguards to ensure effectiveness. Document results and make improvements as needed. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 4. Comprehensive Inventory of IT Systems • Corrective Actions Taken or Planned: Update and maintain our inventory of all IT systems that process and store customer information. Ensure compliance with multifactor authentication, access control, change management, logging, alerting, and encryption requirements. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: June 30, 2026 5. Governance and Reporting • Corrective Actions Taken or Planned: Establish a formal process requiring leadership to report on the state of the information security program to the Board of Trustees and include in our security policies. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: 6/30/2026 6. GLBA Policy Enhancement • Corrective Actions Taken or Planned: Review and revise the information security policy to ensure all GLBA-required elements are included, referencing current regulatory guidance. • Person Responsible: James Stevens, Chief Information Officer, jstevens@knox.edu • Anticipated Completion Date: 6/30/2026

View Audit 389269

Finding 1175475 (2025-002)

Material Weakness 2025

Knox College

IL

Student Financial Aid

Identifying Number: 2025-002 Finding: Disbursements to or on Behalf of Students (Credit Balances) The College did not pay the Title IV credit balances to the students directly within the required timeline noted above. Out of the 40 students tested, we noted 2 students (5%) whose credit balances were...

Identifying Number: 2025-002 Finding: Disbursements to or on Behalf of Students (Credit Balances) The College did not pay the Title IV credit balances to the students directly within the required timeline noted above. Out of the 40 students tested, we noted 2 students (5%) whose credit balances were not paid directly to the students within the required timeframe noted above. The incorrect timing did not have an effect on the total award given to students (timing only). The College did not have formally documented controls related to the process associated with disbursements to or on behalf of students (credit balances), which is required under Uniform Grant Guidance. Corrective Actions Taken or Planned: Knox College has implemented the following corrective measures to ensure compliance with federal credit balance requirements: 1. Automated Monitoring: A system-generated report (Aging Report) of all student credit balances is now produced twice per week from the Jenzabar J1 student information system. 2. Formal Workflow: The AVP of Student Financial Services (SFS) will review the Student Accounts Aging Report. Student Financial Services Advisors will review each of their student accounts that have a credit balance within 24 hours. If the student has a credit balance and has receive Title IV aid during the academic year, the advisor will review if the credit balance is derived by Title IV. A standardized credit balance processing schedule has been established, ensuring that credit balances are reviewed and released within 14 days of disbursement. Role Clarification: Responsibilities are now clearly defined: • SFS confirms refund eligibility. • Business Office processes refunds through Bill.com and posts to the student account. Staff Training: Relevant staff received training on: • Title IV credit balance requirements • Handling of student/parent authorizations • Timely return of unclaimed funds Documentation Controls: All credit balance disbursement and return transactions are documented and retained as part of the official audit record. Person Responsible: Leigh Brinson, Assistant Vice President of Student Financial Services, ltbrinson@knox.edu Anticipated Completion Date: November 10, 2025

View Audit 389269

Finding 1175470 (2025-001)

Material Weakness 2025

Knox College

IL

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

Identifying Number: 2025-001 Finding: Error in Reporting for National Student Loan Data System (NSLDS) The College did not properly report the student enrollment change for students who received federal student aid to the NSLDS. The College did not timely report three students’ Program-Level or Camp...

Identifying Number: 2025-001 Finding: Error in Reporting for National Student Loan Data System (NSLDS) The College did not properly report the student enrollment change for students who received federal student aid to the NSLDS. The College did not timely report three students’ Program-Level or Campus-Level enrollment status change to NSLDS. Out of the 25 students tested, we noted 3 students (12%) whose status change at the Program-Level and Campus-Level was not timely reported to NSLDS. The College did not have adequate controls related to the process of enrollment reporting, which is required under Uniform Grant Guidance. Corrective Actions Taken or Planned: Knox College will add a third report submission to the end of the term. This will ensure that we report any students that made end of term withdrawals within the time window we are required to report. Any students who withdraw between terms will be captured in the first report submitted after our two week census. Person Responsible: Patrick Hathaway, Registrar, phathaway@knox.edu Anticipated Completion Date: December 31, 2025

View Audit 389269

Finding 1175465 (2025-003)

Material Weakness 2025

Thaddeus Stevens College of Technology

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding 2025-003: Late Student Status Change Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: 34 CFR 668.32 requires that an organization reports student status changes within 60 days of graduation, withdrawal, or other roster status chan...

Finding 2025-003: Late Student Status Change Reporting Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: 34 CFR 668.32 requires that an organization reports student status changes within 60 days of graduation, withdrawal, or other roster status changes. Condition: The change in status for 4 of 40 students tested was not reported to the National Student Loan Data System (NSLDS) within 60 days of the change. Cause: Staffing changes during the year impacting the College’s internal control structure resulted in an administrative delay in reporting the changes to NSLDS. Effect: The effect of the condition described above was that the College was not in compliance with NSLDS reporting requirements. Repeat Finding: This is not a repeat finding. Questioned costs: There are no known questioned costs to report. Recommendation: We recommend that the College ensures sufficient staffing is available to report NSLDS requirements timely. View of Responsible Officials and Planned Corrective Action Corrective Action Plan: There is no disagreement with this audit finding. During the fall of 2024 the Registrar’s Office was downsized. This resulted in the delayed processing of the error report following the 10.25.2024 report. This resolution required contacting NSC for assistance in clearing two of the errors, which increased the processing time. Moving forward, the Registrar’s Office will continue to report to NSC on the predetermined schedule, process errors timely, and additionally, a quality control check will be implemented for the Financial Aid Office to compare NSLDS records following the NSC transmissions. Name(s) of the contact person(s) responsible for corrective action: Dr. Melissa Wisniewski, Dean of Enrollment Services at 717-391-7234. Planned completion date for corrective action plan: February 2026 If the Department of Education has questions regarding this plan, please call the Vice President of Finance and Administration, Mr. George Longridge at 717-391-6947.

View Audit 389259

Finding 1175461 (2025-002)

Material Weakness 2025

Thaddeus Stevens College of Technology

PA

Student Financial Aid Allowable Costs / Cost Principles Eligibility

Finding 2025-002: Student Financial Aid Cluster – Allowable Costs and Allowable Activities and Eligibility Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: The College is required to have controls in place to ensure students receive the proper amou...

Finding 2025-002: Student Financial Aid Cluster – Allowable Costs and Allowable Activities and Eligibility Federal Agency: U.S. Department of Education Program: Student Financial Assistance Cluster Criteria: The College is required to have controls in place to ensure students receive the proper amount of student financial assistance they are entitled to based on financial need. Condition: Our financial aid sample of 40 items tested yielded 31 students who received Direct Loan Funding. Of the 31 students who received Direct loan funding, we noted 1 instance where the student received the incorrect amount of Unsubsidized funding. Based on the students Student Aid Index, the student should have received $1,750 in Unsubsidized funding; however, they received $2,227 in Unsubsidized Direct Loan funding, resulting in an overpayment of Direct Loan funding of $477. Cause: The controls in place did not detect that the student had incorrectly been awarded assistance based on more than 30 credits when they actually had 25 credits. The additional 5 credits needed for the amount of the award were not earned until the following semester. Effect: Internal controls related to student financial assistance were not operating properly. Repeat Finding: This is not a repeat finding. Questioned costs: $477 Recommendation: We recommend Thaddeus develop systems that would detect credits posted but not earned to ensure proper student assistance is awarded. View of Responsible Officials and Planned Corrective Action: Management agrees. See separate Corrective Action Plan. Corrective Action Plan: There is no disagreement with the audit finding. After reviewing the policy for Grade-Level Advancement for Direct Loan Consideration, it was determined that the student referenced in the funding did not meet the qualifications needed to be considered a sophomore level student for the Fall 2024 semester. The student became eligible for the increased loan amount in the Spring 2025 semester. The $500 that was incorrectly awarded to the student for the Fall 2024 semester has been corrected and reallocated to Spring 2025. The Office of Financial Aid has created a procedure to check student loan amounts during fall and spring semester to ensure accuracy. Additionally, an Assistant Director of Financial Aid was hired in February 2025 to strengthen financial aid administration within the department. Name(s) of the contact person(s) responsible for corrective action: Melissa Wisniewski, Dean of Enrollment Services at 717-391-7234. Planned completion date for corrective action plan: January 2026. If the Department of Education has questions regarding this plan, please call the Vice President of Finance and Administration, George Longridge at 717-391-6947.

View Audit 389259

Finding 1175445 (2025-002)

Material Weakness 2025

Round Rock Housing Authority

TX

HUD Housing Programs

During the time of the SEMAP submission the housing authority had an unexpected change of staff. This contributed to the agency overlooking the signing of the required board resolution to approve the SEMAP. To keep this from occurring again, RRHA will not submit the SEMAP certification to HUD until ...

During the time of the SEMAP submission the housing authority had an unexpected change of staff. This contributed to the agency overlooking the signing of the required board resolution to approve the SEMAP. To keep this from occurring again, RRHA will not submit the SEMAP certification to HUD until the resolution has been signed.

View Audit 389242

Finding 1175444 (2025-001)

Material Weakness 2025

Round Rock Housing Authority

TX

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

At the time of the most recent independent audit by Smith Marion conducted in December 2025, it was found that RRHA was not completing voucher re-inspections within the required timeframe when an inspection failed. Health and safety inspections are required to be reinspected within 48 hours, and oth...

At the time of the most recent independent audit by Smith Marion conducted in December 2025, it was found that RRHA was not completing voucher re-inspections within the required timeframe when an inspection failed. Health and safety inspections are required to be reinspected within 48 hours, and other inspections must be completed within 30 days. In the past RRHA only had one inspector on staff who tracked all inspections. Due to an increase in portability vouchers a second caseworker was hired in 2025. However, a new system was not created to track both caseworker’s inspections. This resulted in RRHA overlooking timelines and not completing inspections in a timely manner as required. Part of this was also related to miscommunication between the two case workers. To ensure inspections are completed as required by HUD regulation, in the future, each caseworker/inspector is now required to schedule a follow-up inspection appointment at the same time as the failed inspection report is created. Additionally, a separate shared spreadsheet has been created to track failed inspection and verify that each one is being completed within the required time. With these new steps in place we can indicate if a failed inspection needs a 24-hour and/or a 30- day re-inspection and if a follow-up inspection has been already scheduled. RRHA also increased the scheduled time/ days from once a week to two days a week for inspection since we now have two HCV employees/ inspectors available. Effective immediately the process for inspection has been updated and both HCV employees are completing inspections.

View Audit 389242

Finding 1175443 (2025-003)

Material Weakness 2025

City of Sand Springs

OK

Reporting Subrecipient Monitoring § 200.331 § 200.510

RE: Finding 2025-003 Misreporting of Pass-Through Grant Expenditures in Compliance Report In conjunction with our FY25 annual audit, please see the City's corrective action plan below: The City of Sand Springs will strengthen internal controls over federal grant reporting to ensure proper distinctio...

RE: Finding 2025-003 Misreporting of Pass-Through Grant Expenditures in Compliance Report In conjunction with our FY25 annual audit, please see the City's corrective action plan below: The City of Sand Springs will strengthen internal controls over federal grant reporting to ensure proper distinction between direct federal awards and federal pass-through grants, in accordance with Uniform Guidance and SLFRF requirements. Specifically, the City will implement the following corrective actions: Separate Tracking of Direct vs. Pass-Through Funds o The Finance Department will revise grant accounting procedures to clearly segregate expenditures related to: Direct SLFRF (ARPA) awards administered by the City, and Federal pass-through grants administered by external entities, including OWRB. o Separate project codes and/or accounting identifiers will be maintained to prevent commingling of expenditures. Revision of SLFRF Reporting Procedures o Written procedures for preparation and review of the SLFRF Compliance Report will be updated to explicitly state that: Only expenditures related to direct federal awards are to be reported by the City, and Expenditures related to pass-through grants are excluded and reported by the pass-through entity. o A documented review step will be added to verify that reported expenditures align with the funding source prior to submission. Staff Training and Awareness o Finance staff involved in grant accounting and reporting will receive targeted training on: Uniform Guidance requirements (2 CFR 200), The distinction between direct federal awards and pass-through grants, and Proper SEFA and SLFRF reporting responsibilities. o Training will be documented and incorporated into onboarding materials for future staff. Coordination with Pass-Through Entity (OWRB) o The City will coordinate with OWRB to confirm: The sequence of fund utilization (pass-through vs. direct ARPA funds), and Roles and responsibilities for federal expenditure reporting. Expected completion date: Procedures will be implemented for the fiscal year ending June 30, 2026, and applied during interim processing and year-end close. Party Responsible: Finance Director and Finance Staff, in coordination with applicable Department Heads and Project Managers. Contact Information: Arlena Barnes 918-246-2646 arlena.barnes@sandspringsok.gov

View Audit 389227

Finding 1175442 (2025-002)

Material Weakness 2025

City of Sand Springs

OK

Reporting Significant Deficiency

RE: Finding 2025-002 Capital Assets Additions/Cutoff Errors In conjunction with our FY25 annual audit, please see the City's corrective action plan below: The City of Sand Springs will implement enhanced internal controls and review procedures concerning capital asset additions to ensure invoices an...

RE: Finding 2025-002 Capital Assets Additions/Cutoff Errors In conjunction with our FY25 annual audit, please see the City's corrective action plan below: The City of Sand Springs will implement enhanced internal controls and review procedures concerning capital asset additions to ensure invoices and applications for payment are accurately processed and recorded in the proper fiscal year. Specific corrective actions will include: Formalized Cutoff Review Process o Establish a documented year-end cutoff checklist for capital projects. o Require verification of invoice dates, application-for-payment periods, and substantial completion dates prior to posting. o Ensure all invoices and applications for payment are reviewed for proper fiscal year classification before approval. Improved Review of Applications for Payment o Require secondary review and approval of all applications for payment related to capital projects. o Implement a control to ensure cancelled or corrected applications for payment are clearly documented and removed from processing prior to payment. o Maintain supporting documentation evidencing review and approval. Encumbrance and Fiscal Year Posting Controls o Strengthen procedures for tracking encumbrances at year-end, including reconciliation between open encumbrances, invoices received, and capital asset postings. o Require supervisory review of all capital asset additions posted during the year-end close process to confirm proper fiscal year posting. Training and Accountability o Provide targeted training to finance and project management staff on fiscal year cutoff requirements and capital asset accounting. o Clearly define roles and responsibilities for invoice review, posting, and approval to reduce reliance on informal manual adjustments. Expected completion date: Procedures will be implemented for the fiscal year ending June 30, 2026, and applied during interim processing and year-end close. Party Responsible: Finance Director and Finance Staff, in coordination with applicable Department Heads and Project Managers. Contact Information: Arlena Barnes 918-246-2646 arlena.barnes@sandspringsok.gov

View Audit 389227

Finding 1175441 (2025-001)

Material Weakness 2025

City of Sand Springs

OK

Procurement, Suspension & Debarment HUD Housing Programs Internal Control / Segregation of Duties

Finding 2025-001 Corrective Action Plan Condition: Various departments received invoices for goods purchased or services performed prior to receiving appropriate approvals per the City's purchasing policies. In conjunction with our fiscal year 2025 annual audit, please see the City's corrective acti...

Finding 2025-001 Corrective Action Plan Condition: Various departments received invoices for goods purchased or services performed prior to receiving appropriate approvals per the City's purchasing policies. In conjunction with our fiscal year 2025 annual audit, please see the City's corrective action plan below: Staff authorized to submit and approve requisitions will be subject to further training on the City's purchasing process and procedures. Together with additional training, and new software tools, this process is expected to be improved. Expected completion date: 6/30/2026 Party Responsible: Arlena Barnes, Finance Director Contact Information: 918-246-2646 | arlena.barnes@sandspringsok.gov

View Audit 389227

Finding 1175440 (2025-001)

Material Weakness 2025

Milwaukee Institute of Art and Design, Inc.

WI

Reporting Special Tests & Provisions Student Financial Aid

Finding 2025-001 Condition Management implemented controls that specifically addressed some of the circumstances surrounding prior year finding 2024-001. Management's review of the enrollment reporting did not timely report certain student Campus-Level and Program-Level data elements. Student record...

Finding 2025-001 Condition Management implemented controls that specifically addressed some of the circumstances surrounding prior year finding 2024-001. Management's review of the enrollment reporting did not timely report certain student Campus-Level and Program-Level data elements. Student records within the NSLDS was identified with non-timely Campus-Level and Program-Level data elements. Corrective Action Plan Corrective Action Planned: Management agrees with the finding. To resolve this issue, when a student formally withdraws or is academically dismissed in summer, the student information will be manually added to the next National Student Clearinghouse (NSC) upload file, submitted once a month, and marked as “Withdrawn” with an effective status date of the withdrawn date of determination. This complies with NSC processes detailed here: https://help.studentclearinghouse.org/compliancecentral/knowledge-base/enrollment-reporting-for-summer-and-other-non-required-terms/. Name of Contact Person Responsible for Corrective Action: Mark Fetherston, Vice President for Enrollment Management Anticipated Completion Date: Process and procedures will be updated in February 2026, with first implementation in May 2026 (as part of the Summer 2026 submission process).

View Audit 389221

Finding 1175419 (2025-001)

Material Weakness 2025

City of Reno

NV

Subrecipient Monitoring Reporting Significant Deficiency

Federal program: Community Development Block Grants/Entitlement Special Purpose Grants Cluster (CFDA #14.218). Condition/context: During testing, auditors were provided with documentation that indicated the City did not file a PR29-CDBG Cash on Hand Quarterly report by the specified due date. Of the...

Federal program: Community Development Block Grants/Entitlement Special Purpose Grants Cluster (CFDA #14.218). Condition/context: During testing, auditors were provided with documentation that indicated the City did not file a PR29-CDBG Cash on Hand Quarterly report by the specified due date. Of the four (4) reports available for testing, two (2) were randomly selected and it was noted that one (1) was not filed by the due date. Corrective action: The City will establish and maintain deadlines and monitor the timely submission of all required reports under the CDBG program, including the PR29 quarterly report. The tracking system will include key due dates, responsible staff and confirmation of submission to ensure accountability and consistency. Procedures will also be established and implemented to ensure continuity of reporting in the event of staff turnover. Implementation date: Implemented and in effect immediately. Contact person: Elaine Wiseman, (775)334-2578, wisemane@reno.gov

View Audit 389174

Finding 1175414 (2025-001)

Material Weakness 2025

Chestnut Health Systems, INC

IL

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.320

United States Department of Health and Human Services 2025-001 Procurement – Assistance Listing No. 93.279 Condition: The Organization did not maintain sufficient documentation to support the procurement method utilized prior to engaging a contracted service provider. Recommendation: We recommend th...

United States Department of Health and Human Services 2025-001 Procurement – Assistance Listing No. 93.279 Condition: The Organization did not maintain sufficient documentation to support the procurement method utilized prior to engaging a contracted service provider. Recommendation: We recommend the Organization consistently follow its established policies and procedures related to the maintaining of necessary documentation to support the method of procurement utilized. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Given the infrequency of spend in excess of the Simplified Acquisition Threshold, Chestnut will take a targeted approach in the corrective action. An initial first step in correction action has been taken and completed 2/18 including educating and informing Chestnut Health Systems Audit Committee and Chestnut Executive Leadership of lack of documentation supporting the procurement process. The Executive Leadership team and assigned grant leadership will be provided with the current Chestnut Procurement policy, reinforcing the requirements at each respective level of spend. For those programs with anticipated vendor spend in excess of the Simplified Acquisition Threshold, targeted working sessions will occur with respective program leadership and the Executive Leadership team to reinforce expectations, review template tools that can be leveraged during the process, and to remedy any gaps in understanding the policy and execution of the policy. Name(s) of the contact person(s) responsible for corrective action: Melissa Woodbury, CFO. Planned completion date for corrective action plan: By June 1, 2026 If there are any questions regarding this plan, please call Melissa Woodbury, CFO, at 309-820-3572.

View Audit 389155

Finding 1175413 (2025-001)

Material Weakness 2025

The Peregrine Fund, Inc.

ID

Subrecipient Monitoring § 200.332

Views of Responsible Officials: The Organization's procedure manual will be updated to include procedures that align with 2 CFR 200.332. These procedures will include the documentation of risk assessment for each subrecipient, and establish monitoring activities that are responsive to the level of r...

Views of Responsible Officials: The Organization's procedure manual will be updated to include procedures that align with 2 CFR 200.332. These procedures will include the documentation of risk assessment for each subrecipient, and establish monitoring activities that are responsive to the level of risk.

View Audit 389127

Finding 1175411 (2025-002)

Material Weakness 2025

Guilford College

NC

Special Tests & Provisions Student Financial Aid Significant Deficiency

Audit Period: June 30, 2025 The findings from the June 30, 2025 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONS COSTS – MAJOR FEDERAL AWARD PROGRAM AUDIT 2025-002 –...

Audit Period: June 30, 2025 The findings from the June 30, 2025 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONS COSTS – MAJOR FEDERAL AWARD PROGRAM AUDIT 2025-002 – U.S. Department of Education, SFA Cluster, Special Tests and Provisions - Return of Title IV Refunds (Significant Deficiency) Condition: From a population of 74 students that officially or unofficially withdrew during the term, we tested nine students and noted that four students required refund calculations. From the fall 2024 semester calculations we noted that the College did not deduct Thanksgiving break of nine days, November 23, 2024 through December 1, 2024, from the total days in the semester. Criteria: The total number of calendar days in a payment period or period of enrollment includes all days within the period that a student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period (34 CFR Section 668.22(f)(2)(i)). Cause: Controls to ensure proper calculation of Title IV refunds did not function as related to the condition above. Effect: Calculations were incorrect for the three students tested that officially or unofficially withdrew during the fall 2024 term resulting in an incorrect amount of funds returned to the student and the Department of Education. Repeat Finding from a Prior Year: No Recommendation: We recommend the College implement procedures for accurate preparation and calculation of Title IV refunds. Management Response: The college is in agreement with the recommendation to implement procedures for accurate preparation and calculation of Title IV funds. If the Federal Audit Clearinghouse has questions regarding this plan, please call Danielle Pfaff, Controller, at 1-336-316-2140 or dpfaff@guilford.edu

View Audit 389123

Finding 1175410 (2025-003)

Material Weakness 2025

City of Union City School District

NJ

Procurement, Suspension & Debarment

The District review and either nullify or accept and authorize with a resolution of the board of education: 1) a subrecipient grant agreement for Clean School Bus Program grant with Van-Con, Inc., a for profit entity; and 2) the procurement, contract award, and purchase of electric school buses from...

The District review and either nullify or accept and authorize with a resolution of the board of education: 1) a subrecipient grant agreement for Clean School Bus Program grant with Van-Con, Inc., a for profit entity; and 2) the procurement, contract award, and purchase of electric school buses from Van-Con, Inc. using such Clean School Program grant funds. If a contract is awarded with grant funds, such contract be properly encumbered in the District’s financial reporting system.

View Audit 389118

Finding 1175409 (2025-001)

Material Weakness 2025

Pasadena Area Community College District

CA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

The Office of Financial Aid is currently strengthening the Return to Title IV (R2T4) process by formalizing written procedures and integrating industry best practices. As part of this effort, we are implementing a quality control system whereby a second team member reviews each file to ensure the ac...

The Office of Financial Aid is currently strengthening the Return to Title IV (R2T4) process by formalizing written procedures and integrating industry best practices. As part of this effort, we are implementing a quality control system whereby a second team member reviews each file to ensure the accuracy of calculations, the completion of necessary pullbacks or billings, and timely communication with students. Additionally, we are enhancing our Title IV reconciliation process to serve as an added layer of oversight, verifying that award data in our student information system (Banner) aligns with records in the Common Origination and Disbursement (COD) system.

View Audit 389117

Finding 1175403 (2025-007)

Material Weakness 2025

Norwich University

VT

Procurement, Suspension & Debarment Reporting Internal Control / Segregation of Duties

The University did not have an internal control procedure designed to compare vendors and employees against the SAM database to ensure they were not suspended or disbarred. The University is implementing a quarterly review process to compare both employees and vendors against the SAM database. Respo...

The University did not have an internal control procedure designed to compare vendors and employees against the SAM database to ensure they were not suspended or disbarred. The University is implementing a quarterly review process to compare both employees and vendors against the SAM database. Responsible party: Susannah Naylor, Controller; snaylor1@norwich.edu Anticipated Completion Date: May 31, 2026

View Audit 389114

Finding 1175388 (2025-006)

Material Weakness 2025

Norwich University

VT

Student Financial Aid Reporting

The errors noted in the finding resulted from a missing step in the reconciliation process. The Registrar’s office relied on an error report from NSC to help identify any issues that might be noted in the student files. The findings noted, reinforced that this process alone was not sufficient to cap...

The errors noted in the finding resulted from a missing step in the reconciliation process. The Registrar’s office relied on an error report from NSC to help identify any issues that might be noted in the student files. The findings noted, reinforced that this process alone was not sufficient to capture all errors. To ensure that these types of errors do not recur, subsequently, the registrar’s office team has initiated an additional monthly reconciliation between the NSLDS and internal student management system. This reconciliation will show any status variance or date mismatches. Any variances noted will be updated in the NSC/NSLDS system. This process was implemented in December 2024 when the issue was found as part of the 2024 audit. The 2025 finding relates to an individual who withdrew from the University prior to December 2024 with the new procedures in place. Responsible party: Sarah Harris, Director, Office of Financial Aid; (802) 485-2679 Anticipated Completion Date: December 2024

View Audit 389114

Finding 1175386 (2025-001)

Material Weakness 2025

Portales Municipal School District

NM

Subrecipient Monitoring Reporting § 200.512

To ensure future compliance with Federal Audit Clearinghouse (FAC) deadlines, the Portales Municipal School District will implement the following milestones: • Milestone 1: Establish an internal compliance calendar that triggers a primary alert 30 days prior to the federal deadline (March 31) and a ...

To ensure future compliance with Federal Audit Clearinghouse (FAC) deadlines, the Portales Municipal School District will implement the following milestones: • Milestone 1: Establish an internal compliance calendar that triggers a primary alert 30 days prior to the federal deadline (March 31) and a secondary alert immediately upon the release of the audit report by the New Mexico State Auditor. • Milestone 2: Formalize a coordination protocol between the Finance Department and the external audit firm to ensure the Data Collection Form (DCF) is drafted and ready for certification within 15 days of the state report release. • Milestone 3: Conduct a final review and electronic submission of the report and DCF to the FAC no later than 30 days post-release, ensuring all filings are finalized well before the absolute nine-month deadline. Responsible party(ies) for corrective action(s): Director of Finance Corrective action(s) timeline: January 31, 2026

View Audit 389100

Finding 1175381 (2025-002)

Material Weakness 2025

Independent School District No. 728

MN

Procurement, Suspension & Debarment Eligibility Significant Deficiency

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2025-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding ...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER – FEDERAL ALN 84.027 AND 84.173 2025-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 requires Independent School District No. 728 (the District) to establish and maintain effective internal control over compliance with requirements applicable to its federal program expenditures, including suspension and debarment requirements. Our testing indicated the District did not have sufficient controls in place within its special education cluster federal programs to assure it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds, prior to purchasing over $25,000 of goods or services from the vendor. Corrective Action Plan Actions Planned – The District will review policies and procedures relating to suspension and debarment for special education cluster federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding prior to expending federal funds with such vendors. Official Responsible – The District’s Director of Finance, Joseph Primus. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Director of Finance will monitor the implementation of these corrective actions to ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website prior to expending federal funds with such vendors.

View Audit 389098

Finding 1175379 (2025-002)

Material Weakness 2025

University of Mobile, Inc.

AL

Student Financial Aid Subrecipient Monitoring Eligibility

Condition: A student added an additional course after the summer term census date, however, the Financial Aid Office did not adjust the student’s corresponding Pell Grant eligibility. As a result, the Pell Grant award was not recalculated to include the additional course. Criteria: The University’s ...

Condition: A student added an additional course after the summer term census date, however, the Financial Aid Office did not adjust the student’s corresponding Pell Grant eligibility. As a result, the Pell Grant award was not recalculated to include the additional course. Criteria: The University’s monitoring controls for post-census date enrollment changes were not consistently applied. Although the University’s normal process includes reviewing and adjusting aid when students add/drop classes after the census date, this case was not identified due to human oversight for post-census date schedule changes. Cause: Per 34 CFR 690.80(b)(2)(ii), the University must adjust Federal Pell Grant awards if a student’s enrollment status changes and the change occurs within the University’s established recalculation (census) policies. Additionally, internal University policy states that Pell Grant awards will be adjusted when students add/drop courses after the census date if those courses are applicable toward the student’s degree or certificate requirements and occur within the eligible recalculation period. Effect: Because the student’s enrollment increase was not identified and processed, the student did not receive the full amount of Pell Grant awards they were entitled to. This resulted in a $924 underpayment to the student. Context: This issue was identified during audit testing of Pell Grant awards for the 2024–2025 year. The University reviewed the case and agreed that the student should have received an additional $924. The University believes the error to be an isolated incident rather than a systemic process failure; however, it indicates that post-census monitoring controls may not be fully effective in all cases. Recommendation: The University should establish a formal process to monitor when students add/drop courses after the term census date to ensure financial aid is accurately adjusted and reflected in a timely manner. This process should include periodic reviews or automated reports that identify enrollment changes impacting grant eligibility and additional procedures to verify that corresponding adjustments are made to student accounts. Strengthening this process will help ensure compliance with federal regulations and prevent underpayments or overpayments of student aid. View of Responsible Officials and Planned Corrective Action: The University has recognized the failure to adjust the student's enrollment status and recalculate the Pell Grant award in a timely manner that resulted in an underpayment of $924. To prevent similar issues in the future, the Financial Aid Office will implement a formal process to monitor students who add/drop courses after the census date, including generating reports to flag enrollment changes that impact Pell Grant eligibility and reviewing these cases to ensure adjustments are made promptly.

View Audit 389096

Finding 1175378 (2025-001)

Material Weakness 2025

University of Mobile, Inc.

AL

Eligibility Matching / Level of Effort / Earmarking

Condition: There was an incorrect cost of attendance amount used to calculate a parent PLUS loan for 1 out 40 students tested. Criteria: According to the U.S. Department of Education, an institution must use cost of attendance minus other financial aid received to calculate the amount of PLUS loans ...

Condition: There was an incorrect cost of attendance amount used to calculate a parent PLUS loan for 1 out 40 students tested. Criteria: According to the U.S. Department of Education, an institution must use cost of attendance minus other financial aid received to calculate the amount of PLUS loans that students are eligible to receive. Cause: The University utilizes a paper worksheet to manually calculate a student’s eligibility for PLUS loans. Due to a manual entry error, the cost of attendance was recorded as $1,000 less than the correct amount. As a result, the student was eligible to borrow more funds than initially indicated. Effect: As a result of the manual calculation error on the loan worksheet, the student was informed of a lower borrowing limit than they were actually eligible for. This discrepancy contributed to the student receiving less financial aid than anticipated. Additionally, the error highlights a risk in the manual calculation process, which could result in similar miscalculations for other students if not addressed. Context: The University determines PLUS loan eligibility using a manually prepared worksheet rather than an automated system calculation. Financial aid staff record the cost of attendance and other aid amounts on this form to compute the eligible PLUS loan amount. During audit testing, it was noted that an error occurred in recording the cost of attendance, resulting in an incorrect calculation of the student’s PLUS loan eligibility. Recommendation: The University should implement controls to prevent, or detect and correct, manual calculation errors in determining PLUS loan eligibility. This may include transitioning to an automated system-based calculation, improving the secondary review process for all manually prepared worksheets, or incorporating validation checks for key data. Implementing these controls will help ensure accuracy in loan determinations and compliance with federal awarding requirements. View of Responsible Officials and Planned Corrective Action: Thank you for the opportunity to report on enhancements the University has made to resource our students and maintain the highest standards of accounting. While we are pleased that the audit indicated significant progress, the following are additional steps we are taking to ensure even greater accuracy and compliance: 1. An improved review process for all manually calculated loan worksheets to verify the accuracy of key inputs, including the cost of attendance and other aid amounts and 2. The University is also exploring options to automate the loan calculation process within its financial aid management system to reduce the risk of manual errors.

View Audit 389096

Finding 1175367 (2025-001)

Material Weakness 2025

Golden Thread Housing, Inc.

IA

Internal Control / Segregation of Duties Reporting

The Project has limited resources and additional controls are not financially feasible through the hiring of additional staff. The Project is a small entity and the lack of segregation of duties is common among entities with minimal employees and should be recognized as such. The Project will contin...

The Project has limited resources and additional controls are not financially feasible through the hiring of additional staff. The Project is a small entity and the lack of segregation of duties is common among entities with minimal employees and should be recognized as such. The Project will continue to evaluate the cost versus benefit of correcting the deficiency.

View Audit 389093

Finding 1175365 (2025-006)

Material Weakness 2025

University of New Mexico

NM

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.430

Management Response: The University agrees with this recommendation and will modify the procedures associated with the review of subsequent payroll and fringe adjustments to ensure that in addition to reversing in total that the adjustments also reverse at the index-account level. These new procedur...

Management Response: The University agrees with this recommendation and will modify the procedures associated with the review of subsequent payroll and fringe adjustments to ensure that in addition to reversing in total that the adjustments also reverse at the index-account level. These new procedures will be implemented by February 27, 2026, and will be overseen by the Deputy Controller.

View Audit 389089

Corrective Action Plans

Filters