Corrective Action Plans

Finding 1161272 (2025-002)

Material Weakness 2025

MN

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – CFDA No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: No disagreement with t...

Student Financial Assistance Cluster – CFDA No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: No disagreement with the audit finding. Action taken in response to finding: The College will review our reporting procedures to ensure that students’ statuses re reported accurately to NSLDS, as required by regulations. Name of the contact person responsible for corrective action: Bethany Miller, Interim Registrar; Associate Provost & Chief Data Officer. Planned completion date for corrective action plan: December 20, 2025

View Audit 371195

Finding 1161269 (2025-001)

Material Weakness 2025

MacAlester College

MN

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency § 200.303

Student Financial Assistance Cluster – CFDA No. 84.063, 84.268 Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: No disagreement with the au...

Student Financial Assistance Cluster – CFDA No. 84.063, 84.268 Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: No disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office will maintain documentation of monthly communication between the External Programs Manager, the Financial Aid Director and the Director of Accounting, related to the monthly reconciliation of Federal Direct Loans, Federal Pell Grant. Federal SEOG and Federal Work Study programs. Name of the contact person responsible for corrective action: Jenae Schmidt, Director of Financial Aid Planned completion date for corrective action plan: September 30, 2025

View Audit 371195

Finding 1161266 (2025-001)

Material Weakness 2025

Milligan University

TN

Questioned Costs Student Financial Aid

Finding Reference Number: 2025-001 Return to Title IV Funds Summary of Finding: During the R2T4 calculation, all Title IV funds from the Direct Loan, Federal Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and FSEOG programs that were disbursed or able to be disbursed should have be inc...

Finding Reference Number: 2025-001 Return to Title IV Funds Summary of Finding: During the R2T4 calculation, all Title IV funds from the Direct Loan, Federal Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and FSEOG programs that were disbursed or able to be disbursed should have be included in determining the amount of earned Title IV funds. In performing the calculation for one student, the institution failed to include all applicable federal aid resulting in $220 of excess Pell grant funds being retained on the student’s behalf. The excess funds of $220 were returned to the DOE in July 2025. Entity’s Corrective Action Plan: The University recognizes the importance of accuracy when performing R2T4 calculations. In this particular situation, the employee who performed the calculation was new in the role and had not previously had responsibility for R2T4 calculations. The University has reassigned this responsibility and has provided education and training for the staff responsible for R2T4 calculations for 2025-26. In addition, the University is requiring a review of each calculation by another member of the financial aid staff with knowledge and training on how to perform the calculations. Anticipated Completion Date: September 1, 2025 Name and Title of Responsible Person: Gus Morgan, Interim Financial Aid Director and VP for Enrollment Services

View Audit 371188 Questioned Costs: $1

Finding 1161263 (2025-002)

Material Weakness 2025

Milligan University

TN

Questioned Costs Student Financial Aid HUD Housing Programs

Finding Reference Number: 2025-002 Working During Scheduled Class Time Summary of Finding: Students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from att...

Finding Reference Number: 2025-002 Working During Scheduled Class Time Summary of Finding: Students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community workstudy experience with exemptions being appropriately documented. The University had a few instances in which appropriate documentation for exemptions had not been obtained by the supervisors. The known error is $99 with extrapolation of the error across the population at $3,115. Entity’s Corrective Action Plan: The University understands the federal guidelines and provided reminders to all students and supervisors, via email, that students are not permitted to work during scheduled class times; the reminders were sent at the end of each pay period throughout the 2024-25 year. In August 2025, the University provided a required training session for all work study supervisors and reviewed the importance of compliance with this specific aspect of managing FWS as well as all other federal requirements governing the Federal Work Study Program. Supervisors and students continue to receive bi-monthly reminders of this policy. Supervisors are expected to monitor when their students are working and to know their students’ class schedules. They are expected to request documentation if clock-in times, or any period of their work shift, falls within a scheduled class time. Additionally, for 2025-26, the Human Resource Office is developing a review process to determine that appropriate documentation has been obtained if a student meets one of the eligible exemption criteria. Anticipated Completion Date: November 1, 2025 Name and Title of Responsible Person: Gus Morgan, Interim Financial Aid Director and VP for Enrollment Services and Rebecca Proffitt, Payroll and Student Employment Coordinator

View Audit 371188 Questioned Costs: $1

Finding 1161133 (2025-001)

Material Weakness 2025

Boys & Girls Club of Weber-Davis

UT

Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management

BOYS & GIRLS CLUBS OF WEBER-DAVIS CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2025 Finding: 2025-001 Name of contact person and title: Angie Pitt Completion date: October 2, 2025 Agency's response: Concur Management's Response: The Boys & Girls Clubs of Weber-Davis has not been required by th...

BOYS & GIRLS CLUBS OF WEBER-DAVIS CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2025 Finding: 2025-001 Name of contact person and title: Angie Pitt Completion date: October 2, 2025 Agency's response: Concur Management's Response: The Boys & Girls Clubs of Weber-Davis has not been required by the grant facilitator to provide member income data. However, to ensure compliance with federal reporting requirements, we will begin requesting income information from our members. In addition, we will reach out to our partner schools to determine whether they can confirm which of our members participate in the free or reduced lunch program.

View Audit 371150

Finding 1161116 (2025-003)

Material Weakness 2025

High Street Homes Inc.

MD

Eligibility HUD Housing Programs

Recommendation: The Project should perform a review of all tenant files to ensure all tenant files are complete with required documentation. Planned Corrective Actions: High Street Homes, Inc. acknowledges the deficiency related to tenant eligibility documentation. Management recognizes the importan...

Recommendation: The Project should perform a review of all tenant files to ensure all tenant files are complete with required documentation. Planned Corrective Actions: High Street Homes, Inc. acknowledges the deficiency related to tenant eligibility documentation. Management recognizes the importance of maintaining complete tenant files to ensure compliance with HUD requirements. Corrective actions taken include: • Immediate review of all current tenant files to confirm lease agreements and all required HUD forms are properly executed and on file. • Establishment of a tenant file checklist to ensure all required documentation is obtained and reviewed prior to tenant move-in. • Implementation of supervisory review of tenant files to verify completeness before occupancy is finalized. • Staff training on HUD eligibility and documentation requirements to reinforce compliance. High Street Homes, Inc. is committed to ensuring full compliance with HUD tenant eligibility documentation requirements.

View Audit 371113

Finding 1161115 (2025-002)

Material Weakness 2025

High Street Homes Inc.

MD

Questioned Costs Allowable Costs / Cost Principles

Recommendation: The Project should review the HUD agreement and approved budget to obtain a better understanding of the type of costs that are allowable, and ensure they are only using HUD funds for allowable costs. Planned Corrective Actions: High Street Homes, Inc. concurs with this finding. The q...

Recommendation: The Project should review the HUD agreement and approved budget to obtain a better understanding of the type of costs that are allowable, and ensure they are only using HUD funds for allowable costs. Planned Corrective Actions: High Street Homes, Inc. concurs with this finding. The questioned costs resulted from staff unfamiliarity with the HUD agreement due to turnover in the Finance Department. Corrective measures taken include: • Reimbursement of the unallowable costs identified ($2,261) with non-federal funds. • Ongoing training for Finance staff regarding HUD cost principles, allowable costs, and budget compliance. • Regular review of expenditures by the Director of Finance to ensure costs are reasonable, necessary, and allowable under the HUD agreement. These corrective actions will strengthen compliance with HUD cost requirements and prevent future occurrences.

View Audit 371113 Questioned Costs: $1

Finding 1161102 (2025-003)

Material Weakness 2025

Lenoir-Rhyne University

NC

Cash Management Student Financial Aid

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition: The University had one instance during the year that were identified in which Title IV funds drawn were held in excess of the allowable time frame. Corrective Action Plan: Upon reviewing the situation that led to thi...

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition: The University had one instance during the year that were identified in which Title IV funds drawn were held in excess of the allowable time frame. Corrective Action Plan: Upon reviewing the situation that led to this error, it was a result of batches from the student accounts system not being posted to the accounting general ledger on a daily basis. To prevent this error from occurring in the future, the Director of Student Accounts will post batches daily going forward. Additionally, the Controller is cross trained on this function and will fill in when needed to post batches. Anticipated Completion Date: September 30, 2025

View Audit 371097

Finding 1161101 (2025-002)

Material Weakness 2025

Lenoir-Rhyne University

NC

Student Financial Aid Special Tests & Provisions Cash Management

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition: The University did not return credit balances to students within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Business Office, particularly in Studen...

Name of Responsible Individual: Alex Putzer, AVP of Business and Finance Condition: The University did not return credit balances to students within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Business Office, particularly in Student Accounts, during summer 2024 through fall 2024. The University recognizes that there needs to be better checks and balances in place to ensure all credit balances triggered by federal aid are properly refunded to students within the 14-day required period. Director of Student Accounts will more frequently post financial aid awards on student accounts, once a week at a minimum. The Business Office will monitor all refunds and process them twice weekly, with two different staff members cross-trained so that a week is never missed. The AVP of Business and Finance will review the status of all credit balances on Student accounts’ on a weekly basis throughout the year to ensure timely reimbursement. This was identified in the prior year audit, but unfortunately not fixed until well into the 2025 fiscal year. Anticipated Completion Date: May 31, 2025

View Audit 371097

Finding 1161097 (2025-001)

Material Weakness 2025

Lenoir-Rhyne University

NC

Student Financial Aid Reporting Special Tests & Provisions

Name of Responsible Individual: Jeni Wyatt, Assistant Provost for Undergraduate Education Condition: The University did not report students' status changes accurately and within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Registrar’...

Name of Responsible Individual: Jeni Wyatt, Assistant Provost for Undergraduate Education Condition: The University did not report students' status changes accurately and within the required timeframe. Corrective Action Plan: The University experienced significant turnover of staff in the Registrar’s Office in fiscal year 2024. This turnover unfortunately was the catalyst for untimely student status change submissions to the NSLDS. This was identified previously; however, the situation was not able to be rectified until well into the 2025 fiscal year. The University has hired new permanent staff, including an experienced registrar. This group has been working with the clearinghouse personnel to work out errors, and reporting is now being addressed in a timely manner. Anticipated Completion Date: September 30, 2025

View Audit 371097

Finding 1161092 (2025-001)

Material Weakness 2025

Mamou Elderly Housing Development Corp. Operating As Savoy Heights Apt

FL

HUD Housing Programs Reporting

Oversight Agency for Audit, Mamou Elderly Housing Corporation respectfully submits the following corrective action plan for the year ended March 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 3306...

Oversight Agency for Audit, Mamou Elderly Housing Corporation respectfully submits the following corrective action plan for the year ended March 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: April 1, 2024 through March 31, 2025 The finding from the March 31, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 207/223(F) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects the Elderly, ALN 14.155 Recommendation: Management should implement procedures to ensure that the correct amount is deposited into the replacement reserve account each month. Action Taken: Deposits are made to the replacement reserves on a monthly basis. A new checklist is being implemented to ensure the accuracy of the amounts and completeness of the transfers. If the Oversight Agency for Audit has questions regarding the plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO

View Audit 371084

Finding 1161072 (2025-001)

Material Weakness 2025

Laramie Square Housing

WY

HUD Housing Programs Cash Management

Action Taken: Management agrees and will make up the deficient deposit as soon as possible.

View Audit 371045

Finding 1160966 (2025-001)

Material Weakness 2025

North Greenville University

SC

Student Financial Aid Allowable Costs / Cost Principles Eligibility

Need Analysis Planned Corrective Action: 1. A revised internal procedure has been implemented, requiring a secondary review of all loan award allocations prior to disbursement to confirm compliance with federal regulations. 2. Staff members responsible for loan origination and packaging have been as...

Need Analysis Planned Corrective Action: 1. A revised internal procedure has been implemented, requiring a secondary review of all loan award allocations prior to disbursement to confirm compliance with federal regulations. 2. Staff members responsible for loan origination and packaging have been assigned refresher training on federal loan awarding requirements, with specific emphasis on annual and aggregate loan limits and the prioritization of subsidized eligibility. 3. System-level reports have been created to identify potential discrepancies in loan allocation, which will be reviewed monthly by the Financial Aid Office. Ongoing Monitoring: The Director of Financial Aid will oversee the monitoring process each term to ensure compliance with 34 CFR 685.203, and 34 CFR 685.301 requirements. Any discrepancies identified will be corrected immediately and documented as part of the institution’s internal compliance log. North Greenville University believes these corrective measures address the issue identified and will prevent recurrence of similar errors. Person Responsible for Corrective Action Plan: Cindi Patterson, Director of Financial Aid Anticipated Date of Completion: October 1, 2025

View Audit 371000

Finding 1160962 (2025-003)

Material Weakness 2025

Vernon Senior Citizens Housing Development Corp. Operating As Sunshine Center Apartments

FL

HUD Housing Programs

FINDING No. 2025-003: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: Management should implement procedures to ensure proper adherence to Section 8 program administration by remitting the utility reimbursement to the ten...

FINDING No. 2025-003: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: Management should implement procedures to ensure proper adherence to Section 8 program administration by remitting the utility reimbursement to the tenant each month, and the Project should implement procedures to ensure that all initial and ongoing tenant eligibility documentation is obtained timely and maintained in tenant files as required by HUD. Action Taken: Management involved with remitting the utility reimbursements has been notified and will ensure timely implementation moving forward. If the audit Oversight Agency for Audit has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO

View Audit 370993

Finding 1160961 (2025-002)

Material Weakness 2025

Vernon Senior Citizens Housing Development Corp. Operating As Sunshine Center Apartments

FL

HUD Housing Programs

FINDING No. 2025-002: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should comply with HUD regulations for executing the rent change timely upon approval of the rent schedule. Action Taken: Management involv...

FINDING No. 2025-002: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should comply with HUD regulations for executing the rent change timely upon approval of the rent schedule. Action Taken: Management involved with implementing the rent increase has been notified and will ensure timely implementation moving forward.

View Audit 370993

Finding 1160960 (2025-001)

Material Weakness 2025

Vernon Senior Citizens Housing Development Corp. Operating As Sunshine Center Apartments

FL

HUD Housing Programs

Oversight Agency for Audit, Vernon Senior Citizens Housing Development Corporation, operating as Sunshine Center Apartments, respectfully submits the following corrective action plan for the year ended March 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., ...

Oversight Agency for Audit, Vernon Senior Citizens Housing Development Corporation, operating as Sunshine Center Apartments, respectfully submits the following corrective action plan for the year ended March 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: April 1, 2024 through March 31, 2025 The findings from the March 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: Management should keep track of the balance in the residual receipts account available for offsetting Section 8 HAP payments. Also, management should ensure timely submission of payment requests through the contract administrator upon discovery of residual receipts available for recapture. Action Taken: Property accountants will notify the Community Managers and Regional Managers of any residual receipt excess funds monthly to ensure proper and timely payment requests. Management will submit the excess funding in September of 2025 to rectify the current situation.

View Audit 370993

Finding 1160957 (2025-001)

Material Weakness 2025

Anderson University and Subsidiary

SC

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

Need Analysis Corrective Action Plan: The Office of Financial Aid & Scholarships (OFAS) will do the following: • Correct the procedures for data entry in Workday. • Revise internal procedures to review loan awards prior to disbursement. • Explore/implement system checks in Workday to flag potential ...

Need Analysis Corrective Action Plan: The Office of Financial Aid & Scholarships (OFAS) will do the following: • Correct the procedures for data entry in Workday. • Revise internal procedures to review loan awards prior to disbursement. • Explore/implement system checks in Workday to flag potential over-awards. • Conduct random reviews of aid packages to ensure compliance. • Document system changes and over-award resolution. Person Responsible for Corrective Action Plan: Mike Sapienza, Senior VP for Enrollment Services Anticipated Date of Completion: May 31, 2026

View Audit 370986 Questioned Costs: $1

Finding 1160909 (2025-003)

Material Weakness 2025

El Redentor Apartments, Inc. (el Redentor Apts)

LA

Questioned Costs

MANAGEMENT AGREEMS WITH THE FINDING. THE FUNDS WILL BE REIMBURSED.

View Audit 370975 Questioned Costs: $1

Finding 1160908 (2025-002)

Material Weakness 2025

El Redentor Apartments, Inc. (el Redentor Apts)

LA

Questioned Costs HUD Housing Programs

MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT HAS SUBMITTED THE FORMS FOR HUD'S APPROVLA.

View Audit 370975 Questioned Costs: $1

Finding 1160907 (2025-001)

Material Weakness 2025

El Redentor Apartments, Inc. (el Redentor Apts)

LA

MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT IS WORKING WITH HUD TO RESOLVE PAST DUE DEPOSITS. MANAGEMENT WILL ENSURE THAT THE REPLACEMENT RESERVE DEPOSITS ARE MADE ONE A TIMELY BASIS IN THE FUTURE.

View Audit 370975

Finding 1160906 (2025-002)

Material Weakness 2025

El Redentor Apartments Ii, Inc. (el Redentor Apts, Ii)

LA

Questioned Costs HUD Housing Programs

MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT HAS SUBMITTED THE FORMS FOR HUD'S APPROVAL

View Audit 370974 Questioned Costs: $1

Finding 1160905 (2025-001)

Material Weakness 2025

El Redentor Apartments Ii, Inc. (el Redentor Apts, Ii)

LA

MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT IS WORKING WITH HUD TO RESOLVE PAST DUE DEPOSITS. MANAGEMENT WILL ENSURE THAT THE REPLACEMENT RESERVE DEPOSITS ARE MADE ON A TIMELY BASIS IN THE FUTURE.

View Audit 370974

Finding 1160902 (2025-007)

Material Weakness 2025

Low Rent Housing Agency of Grinnell, Iowa

IA

Special Tests & Provisions HUD Housing Programs Material Weakness

Finding 2025-007: Utility Allowance Housing Choice Voucher, 14.871 Material Weakness/Noncompliance Special Test and Provisions Repeat Finding 2024-005 I agree with this finding. MRI Happy Software completed their Utility Allowance Survey and was submitted to the GLRHA on September 4, 2025. These doc...

Finding 2025-007: Utility Allowance Housing Choice Voucher, 14.871 Material Weakness/Noncompliance Special Test and Provisions Repeat Finding 2024-005 I agree with this finding. MRI Happy Software completed their Utility Allowance Survey and was submitted to the GLRHA on September 4, 2025. These documents are currently under review. Estimated date of completion on or before December 31, 2025.

View Audit 370968

Finding 1160901 (2025-006)

Material Weakness 2025

Low Rent Housing Agency of Grinnell, Iowa

IA

HUD Housing Programs Special Tests & Provisions Material Weakness

Finding 2025-006: HQS Quality Control Inspections Housing Choice Voucher, 14.871 Material Weakness/Noncompliance Special Test and Provisions Repeat Finding 2024-004 I agree with this finding. A system is now in place and the first round of HQS Inspections were already completed for the 2025-2026 aud...

Finding 2025-006: HQS Quality Control Inspections Housing Choice Voucher, 14.871 Material Weakness/Noncompliance Special Test and Provisions Repeat Finding 2024-004 I agree with this finding. A system is now in place and the first round of HQS Inspections were already completed for the 2025-2026 audit timeframe. - Completed

View Audit 370968

Finding 1160900 (2025-005)

Material Weakness 2025

Low Rent Housing Agency of Grinnell, Iowa

IA

HUD Housing Programs Special Tests & Provisions Material Weakness

Finding 2025-005: HUD Depository Agreement Housing Choice Voucher Program 14.871 Material Weakness/Noncompliance – Special Tests and Provisions I agree with this finding. Due to unforeseen circumstances a new financial institute will sign a new GDA. Once this is complete documentation for HUD funds ...

Finding 2025-005: HUD Depository Agreement Housing Choice Voucher Program 14.871 Material Weakness/Noncompliance – Special Tests and Provisions I agree with this finding. Due to unforeseen circumstances a new financial institute will sign a new GDA. Once this is complete documentation for HUD funds to be deposited into the account will be completed and all other accounts will be closed. Estimated date of completion – December 31, 2025.

View Audit 370968

Corrective Action Plans

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