Corrective Action Plans

Finding 1179079 (2025-004)

Material Weakness 2025

MI

Questioned Costs Material Weakness Reporting § 200.303

Condition: The City initially reported $30,000 of expenditures on the SEFA that related to activity not related to fiscal year 2025. Planned Corrective Action: The City will ensure that all future expenses under this program are in compliance with CDBG guidelines. Contact person responsible for corr...

Condition: The City initially reported $30,000 of expenditures on the SEFA that related to activity not related to fiscal year 2025. Planned Corrective Action: The City will ensure that all future expenses under this program are in compliance with CDBG guidelines. Contact person responsible for corrective action: Lisa Griggs Anticipated Completion Date: June 30, 2026

View Audit 391506

Finding 1179067 (2025-002)

Material Weakness 2025

Paoli Community School Corporation

IN

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

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Lisa Muth, Centralized School Lunch Treasurer and Courtney Brown, Corporation Treasurer Contact Phone Number and Email Address: 812-723-4717 and muthl@paoli.k12.in.u...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Lisa Muth, Centralized School Lunch Treasurer and Courtney Brown, Corporation Treasurer Contact Phone Number and Email Address: 812-723-4717 and muthl@paoli.k12.in.us or brownc@paoli.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Centralized School Lunch Treasurer will ensure that all vendors are not presently suspended or debarred or otherwise excluded from or ineligible for participation in the Child Nutrition Program. The Corporation Treasurer will ensure that all documentation required for vendors is on file. Anticipated Completion Date: February 2026 INDIANA

View Audit 391501

Finding 1179061 (2025-001)

Material Weakness 2025

Suffolk Redevelopment and Housing Authority

VA

HUD Housing Programs Questioned Costs

Corrective Action: The Housing Authority will implement a targeted Quality Control (QC) review process under the oversight of the Housing Operations Director to ensure utility allowances are calculated, documented, and applied in accordance with HUD requirements, the Authority's approved utility all...

Corrective Action: The Housing Authority will implement a targeted Quality Control (QC) review process under the oversight of the Housing Operations Director to ensure utility allowances are calculated, documented, and applied in accordance with HUD requirements, the Authority's approved utility allowance schedule, and HUD Form 52667. The QC process will ensure that the lower of the approved voucher bedroom size or the actual unit bedroom size is consistently applied. Implementation: • The Housing Operations Director will oversee selective QC reviews of key HCV transactions, including: o New admissions o Selected annual reexaminations o Selected interim reexaminations impacting rent or utility allowances o Selected Housing Assistance Payment (HAP) contracts prior to approval • Reviews will verify: o Correct bedroom size determination o Accurate utility allowance calculations o Proper system entry and supporting documentation maintained in the tenant file and HAP registry • Management will review and correct the tenant files identified in the audit sample and document revised calculations as needed. • A standardized utility allowance calculation worksheet will be required in tenant files. • Staff will receive refresher training on utility allowance calculation and documentation requirements. • Periodic internal monitoring will be conducted to ensure ongoing compliance.

View Audit 391500

Finding 1179060 (2025-001)

Material Weakness 2025

New Jersey Association on Correction and Morrow Holding Corporation

NJ

Questioned Costs HUD Housing Programs Reporting

Finding Description: Per the VOCA contract, the grantee is required to submit quarterly fiscal and programmatic reports by the 15th calendar day of the month following the end of the quarter to the State of NJ. Testing of the compliance requirement indicated that several reports were not submitted t...

Finding Description: Per the VOCA contract, the grantee is required to submit quarterly fiscal and programmatic reports by the 15th calendar day of the month following the end of the quarter to the State of NJ. Testing of the compliance requirement indicated that several reports were not submitted timely. Corrective Action and Method of Implementation: The Organization is currently in a transition phase and plans to reorganize job duties and adjust staffing within the Finance Department to support the preparation and timely submission of quarterly fiscal and programmatic reports. These delays resulted from postponed contract approvals by the contracting entity, as well as staff turnover, which affected the timely filing of complete and accurate reports. Name of Responsible Person: Diane Hobbs, Chief Financial Officer Anticipated Completion Date: June 2026

View Audit 391493

Finding 1179047 (2025-004)

Material Weakness 2025

Maine Maritime Academy

ME

Special Tests & Provisions Questioned Costs Student Financial Aid

Identifying Number: 2025-004 Finding: The Academy did not report student enrollment changes within the timeframe outlined by the Department of Education. Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid Corrective Actions Taken or Planned: ...

Identifying Number: 2025-004 Finding: The Academy did not report student enrollment changes within the timeframe outlined by the Department of Education. Name of Contact Person: Alice Herrick, Director of Fiscal Operations; Ryan French, Director of Financial Aid Corrective Actions Taken or Planned: Root Causes Analysis: Upon internal review, several key factors contributing to this deficiency were identified: a. Clearinghouse Processing Gaps: Enrollment reporting at the Academy is managed through the National Student Clearinghouse (NSC), which transmits enrollment updates to the National Student Loan Data System (NSLDS). A review of discrepancies highlighted cases where: o Student withdrawals were not consistently updated within the mandated timeframe. b. Quality Control Mechanism: o There is currently no established process to cross-check NSC submission data with NSLDS and Student Information System (SIS) records to confirm that all changes were processed correctly. Corrective Measures: To address this deficiency, the Academy will implement the following corrective actions: a. Enhanced Collaboration & Process Review (Owner: FA/IT/Registrar, Deadline: April 30, 2025): o The Financial Aid Office will collaborate with the Registrar’s Office and IT to conduct a thorough review of the NSC reporting process. o IT will analyze report generation to determine if student records that should be included in NSC updates are being omitted due to system logic or timing of data extraction. b. Quality Control Implementation (Owner: FA/IT, Deadline: May 15, 2025): o A monthly QC report will be developed to identify students with the NSLDS status “Z – No Record Found” and verify that their enrollment data has been appropriately updated in NSLDS. o A secondary review of withdrawals, LOAs, and “no-shows” will be completed to confirm their enrollment status changes were transmitted correctly to NSLDS. c. Manual NSLDS Updates for Withdrawals (Owner: FA, Deadline: Immediate): o As a temporary solution, the Financial Aid Office will manually update student enrollment statuses in NSLDS following an R2T4 calculation. o This manual review will act as a safeguard to catch the majority of unreported status changes while a more automated verification process is developed. Future Process Improvements & Next Steps a. Automated Data Integrity Checks (Owner: IT, Deadline: June 30, 2025): o IT will determine whether a custom “NSLDS Status” flag can be implemented in the Academy’s SIS to help identify students whose records do not agree with NSLDS or the NSC report. b. Ongoing Compliance Monitoring (Owner: FA/IT/Registrar, Deadline: July 30, 2025): o Academy staff from the Registrar’s Office, Financial Aid, and IT will meet to discuss and document NSC reporting best practices – Internal Procedures, Operational Workflow, Compliance and QC Measures. o A bi-annual audit of enrollment reporting timeliness will be conducted to ensure continued compliance. Conclusion: Maine Maritime Academy is committed to ensuring compliance with U.S. Department of Education regulations and providing accurate and appropriate financial aid awards to students. The corrective actions outlined in this plan address the deficiencies identified in the Uniform Guidance audit and aim to prevent similar issues in the future. The corrective action above for student enrollment was underway during the fiscal year 2025 period under audit. We appreciate the audit findings and remain dedicated to continuous improvement in our financial aid procedures.

View Audit 391490

Finding 1179046 (2025-003)

Material Weakness 2025

Maywood-Melrose Park-Broadview School District 89

IL

Questioned Costs Cash Management Eligibility § 200.402

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2025 Corrective Action Plan Finding No.: 2025- 003 Condition: It was noted during the audit that ineligible expenditures were charged to the food service expen...

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2025 Corrective Action Plan Finding No.: 2025- 003 Condition: It was noted during the audit that ineligible expenditures were charged to the food service expenditure function. These expenditures were for a back-to-school picnic and consisted of backpacks with school supplies that were provided to students, as well as a lunch provided to new teachers and staff. These expenditures should not have been charged to the food service function in the District’s general ledger system. Plan: The district is reviewing all expenditures monthly to ensure all of them are recorded with the proper account code. Any changes needed will get a journal entry through the Proviso Treasurer’s Office. The district has also identified the main vendors from which picnic supplies are purchased and stopped charging expenditures from these vendors to food service account codes. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Scott Wold, Business Manager

View Audit 391489

Finding 1179036 (2025-001)

Material Weakness 2025

Pataula Charter Academy

GA

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Management will implement a process to ensure reserve deposits are made timely.

View Audit 391470

Finding 1179035 (2025-001)

Material Weakness 2025

Affordable Residences in Chesterfield (rockwood Village Apartments)

VA

HUD Housing Programs Questioned Costs

Controls around fishing attacks have been implemented to ensure no inappropriate withdrawls are made from the reserve accounts.

View Audit 391469

Finding 1179034 (2025-001)

Material Weakness 2025

Richmond Urban Senior Housing (monarch Woods Apartments)

VA

HUD Housing Programs Questioned Costs

Controls around fishing attacks have been implemented to ensure no inappropriate withdrawls are made from the reserve accounts.

View Audit 391468

Finding 1179033 (2025-002)

Material Weakness 2025

Wayne Trace Local School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring

The District will implement procedures to ensure that Davis-Bacon language is included for future projects with contractors or subcontractors to work on projects in excess of $2,000 financed by federal assistance funds.

View Audit 391466

Finding 1179032 (2025-001)

Material Weakness 2025

Vermont State Colleges

VT

Questioned Costs Student Financial Aid § 200.303

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance (SFA) Cluster Assistance Listing Number: 84.007, 84.033, 84.268, 84.063 Award year: 2025 Corrective Action Plan The Colleges hired a new Chief Information Security Officer (CISO), who has beg...

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance (SFA) Cluster Assistance Listing Number: 84.007, 84.033, 84.268, 84.063 Award year: 2025 Corrective Action Plan The Colleges hired a new Chief Information Security Officer (CISO), who has begun overhauling the information security policies to reflect current practices. The CISO has also created a preliminary draft of a WISP that reflects the Colleges current policies and procedures. This WISP is expected to be completed and implemented during fiscal year 2026, pending board review and approval. Timeline for Implementation of Corrective Action Plan Immediately. Contact Person Sharron Scott, CFO

View Audit 391461

Finding 1179021 (2025-001)

Material Weakness 2025

Heading Home

NM

Questioned Costs Allowable Costs / Cost Principles Reporting

Heading Home management is in agreement with this finding. After years of turnover in key management positions steps have been taken to address staffing challenges and these positions have been successfully staffed with high-quality individuals who bring extensive knowledge and expertise to their ro...

Heading Home management is in agreement with this finding. After years of turnover in key management positions steps have been taken to address staffing challenges and these positions have been successfully staffed with high-quality individuals who bring extensive knowledge and expertise to their roles. These positions include a new Chief Executive Officer, Director of Operations, Chief Financial Officer, and Director of Human Resources. To address challenges in accounting and finance Heading Home had contracted with a local CPA firm specializing in nonprofit accounting and financial reporting to assist the CFO with daily accounting tasks, the monthly close, financial reporting to management and the board of directors, and to facilitate and ensure audits are completed timely each year. The new management group is committed to maintaining a skilled and competent team in key financial roles. Due to the backlog of billings at the opening of FY24, the quarterly reports for the first quarter were submitted late. With the new staff and assistance, these billings and quarterly reports were brought current as quickly as possible. They are now current and being submitted in a timely manner. Management’s corrective action plan was fully implemented by June 30, 2025, and anticipate that there will be no further issues. Personnel responsible for ensuring implementation include Connie Chavez, Chief Executive Officer, and Debbie Brickman, Chief Financial Officer.

View Audit 391445

Finding 1179019 (2025-002)

Material Weakness 2025

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enroll...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An Ellucian consultant provided us with customized process documentation for our new SIS (Ellucian Colleague) which is saved in a shared drive to ensure consistency in the process. The Interim Dean of Students / Financial Aid Director is currently completing the reporting with our Director of Institutional Research receiving the reports and verifying completeness through National Student Clearinghouse, ensuring that there is an internal control. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse & Ian Wilson Planned completion date for corrective action plan: Implemented

View Audit 391428

Finding 1179015 (2025-001)

Material Weakness 2025

Clatsop Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College return the funds related to unclaimed Title IV–funded checks that are older than 240 days. In addition, we recommend that the College review applicable requirements a...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College return the funds related to unclaimed Title IV–funded checks that are older than 240 days. In addition, we recommend that the College review applicable requirements and implement effective controls and procedures to monitor outstanding Title IV–funded checks throughout the year to ensure timely compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office provides a list monthly of the uncashed financial aid checks to the Financial Aid Office. The Financial Aid Office is contacting the students to remind them to cash their checks. The funds for the uncashed checks are returned to the College after 90 days and then returned to the source of the funding. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla and Layla Solar. Planned completion date for corrective action plan: Already implemented.

View Audit 391428

Finding 1179011 (2025-001)

Material Weakness 2025

Community Health and Wellness Center of Greater Torrington, Inc.

CT

Procurement, Suspension & Debarment

Recommendation The Center should establish a system of internal controls to review vendors in accordance with the Uniform Guidance requirements for suspension and debarment. These procedures should be reviewed with the appropriate staff to ensure compliance with requirements Action Taken Community H...

Recommendation The Center should establish a system of internal controls to review vendors in accordance with the Uniform Guidance requirements for suspension and debarment. These procedures should be reviewed with the appropriate staff to ensure compliance with requirements Action Taken Community Health and Wellness Center has a contract management process in place to review contracts, vendors and employees in accordance with Uniform Guidance requirements for suspension and debarment. The following action will be taken: 1. We will review the list of vendors and contractors quarterly to ensure the list is updated with active contractors or vendors. 2. We will include Disbarment checks on an annual basis or more frequently as new contracts are executed, on the Sam.Gov portal for all contractors and vendors so as not to miss any contracts that are supported with federal dollars. Having this process will also alleviate challenges and barriers of administrative oversight of having to carve out federal contracts and create greater efficiencies. 3. We will maintain the documentation of all the annual disbursement checks. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Joanne Borduas, CEO at (860) 387-0425

View Audit 391422

Finding 1179008 (2025-005)

Material Weakness 2025

Howard Community College

MD

Special Tests & Provisions Questioned Costs Student Financial Aid § 200.303

U.S. Department of Education 2025-005: Special Tests and Provisions - NSLDS Enrollment Reporting Student Financial Aid Cluster -Assistance Listing No. 84.063, 84.268 Condition: Enrollment status changes were either not reported to NSLDS within 60 days or did not match the College's records for a por...

U.S. Department of Education 2025-005: Special Tests and Provisions - NSLDS Enrollment Reporting Student Financial Aid Cluster -Assistance Listing No. 84.063, 84.268 Condition: Enrollment status changes were either not reported to NSLDS within 60 days or did not match the College's records for a portion of the sampled students. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding : There is no disagreement with the audit finding. The Institution acknowledges that while reporting was completed within a timely manner by HCC, NSC did not update within the time allotted to be compliant. HCC remains committed to continuous improvement and compliance. Action taken in response to finding: As noted in the prior year's response, the College committed to full implementation of corrective actions by June 30, 2026, aligned with the conclusion of the 2025-2026 academic year. The institution is currently and actively working on the corrective action plan previously submitted. Actions underway or in progress include: Formal clarification of interdepartmental roles and responsibilities, establishing the Records, Registration and Veteran's Affairs (RRVA) as the primary enrollment reporting authority, with defined review and compliance support from Financial Aid Services. Enhanced reconciliation and quality control procedures, including routine cross-checks between RRVA and Financial Aid Services records prior to each enrollment reporting submission. Standardized review protocols for program-level enrollment changes, including graduates, withdrawals, and subsequent reenrollments in different academic programs. Ongoing monitoring and documentation of NSC errors and warning reports, with timely resolution and escalation when discrepancies appear to originate outside of the College's student information systems. Targeted training for RRVA and Financial Aid staff on enrollment reporting regulations, NSLDS requirements, and audit-risk mitigation. The College believes these actions, coupled with existing reporting practices, sufficiently address the concerns raised and will further strengthen enrollment reporting accuracy and documentation. Full implementation of the corrective action plan remains on schedule for completion by June 30, 2026, as originally committed. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Director and Jessica Peterson, Registrar Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Education has questions regarding this plan, please call Detra Hooper, Financial Aid Servies Director at 443-518-4776.

View Audit 391418

Finding 1178984 (2025-002)

Material Weakness 2025

Case Western Reserve University

OH

Procurement, Suspension & Debarment Questioned Costs Allowable Costs / Cost Principles § 200.324

The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. Dur...

The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. During the audit period, it was identified that 4 sampled transactions exceeding the University’s simplified acquisition threshold of $50,000 lacked documented evidence of an independent cost or price analysis prior to March 31, 2025. In April 2025, the University remediated this policy and procedure. No exceptions were identified during the remediation period, and the finding is considered remediated. In April 2025, to address this finding and strengthen compliance, the University initiated the following corrective actions. First, the University worked with leadership to update its procurement policy to increase the simplified acquisition threshold to $250,000, aligning with federal guidelines. This change ensures that the University’s procurement processes are more consistent with federal standards. Second, a new requirement was implemented, mandating that a price analysis form be completed and retained for each procurement transaction exceeding the simplified acquisition threshold. This form documents the University’s independent price analysis. Third, the University provided targeted training to procurement staff and relevant stakeholders to ensure understanding and adherence to the updated policy and the new price analysis requirement. The training emphasized the importance of maintaining contemporaneous documentation in procurement files. Finally, the University implemented enhanced internal controls to ensure that all procurement transactions exceeding the simplified acquisition threshold are reviewed and approved by designated leadership, with documented evidence of a price analysis retained in the procurement files. Primary responsibility for implementing and monitoring this corrective action plan rests with Beth Connelly, Senior Director of Procurement Operations, 216-368-6332.

View Audit 391411

Finding 1178960 (2025-001)

Material Weakness 2025

Case Western Reserve University

OH

Cash Management Questioned Costs § 200.302

The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302 (b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properl...

The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302 (b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properly supported and authorized prior to submission. During the audit period, at least one drawdown was approved, one day retroactively, after submission but prior to receipt of funds. This occurred prior to the remediation period. No exceptions were identified in the remediation period, and the finding is considered remediated. The instance arose during a leadership transition with the Office of Research Administration. Since that time, the entire drawdown process, review and approval has been clarified under new leadership, and additional oversight has been implemented to ensure approvals are documented prior to submission. As part of the drawdown process review, the University developed a standardized drawdown template, which streamlines how the Federal award expense information is gathered, compared to approve budgeted amounts and reviewed for approval. The template documents the preparer, the approver and the dates of both for the respective drawdown. The Office of Research Administration received training on the use of the template in January and February 2026 and implementation is planned for February 2026. Primary responsibility for implementing the correction action plan for this finding rests with Angela Tagliaferri, Assistant Vice President of Post-Award Services and Financial Compliance, 216-368-6269.

View Audit 391411

Finding 1177975 (2025-001)

Material Weakness 2025

Housing and Redevelopment Authority of Wadena

MN

Internal Control / Segregation of Duties

2025-001 – Lack of Segregation of Duties Corrective Action Planned: Due to the Authority’s size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organiz...

2025-001 – Lack of Segregation of Duties Corrective Action Planned: Due to the Authority’s size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing

View Audit 391407

Finding 1177974 (2025-002)

Material Weakness 2025

Tomah Area School District

WI

Procurement, Suspension & Debarment

Procurement and Suspension & Debarment for IDEA Cluster Recommendation: The District should follow their established procurement policies and implement a policy to review vendors for suspension and debarment Explanation of disagreement with audit finding: There is no disagreement with the audit find...

Procurement and Suspension & Debarment for IDEA Cluster Recommendation: The District should follow their established procurement policies and implement a policy to review vendors for suspension and debarment Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will review and modify their policies and procedures that are followed when entering into procurement transactions and ensure that it maintains adequate documentation. Name of the contact person responsible for corrective action: Michelle M. Clark, Business Manager. Planned completion date for corrective action plan: June 30, 2026.

View Audit 391406

Finding 1177965 (2025-001)

Material Weakness 2025

County of Alpine

CA

Procurement, Suspension & Debarment Eligibility § 200.212 § 200.318

The County's current procedure requires documented acknowledgement that the vendor was verfied to not be suspended, debarred, or otherwise excluded prior to entering covered transactions. Effective February 25, 2026, the County's procedure will require documented verfication that vendors are not sus...

The County's current procedure requires documented acknowledgement that the vendor was verfied to not be suspended, debarred, or otherwise excluded prior to entering covered transactions. Effective February 25, 2026, the County's procedure will require documented verfication that vendors are not suspended, debarred, or otherwise excluded prior to entering into covered transactions and retain such documnetation within the procurement file, in accordance with CFR 200.212 and 200.318(h), 2 CFR 180.300, and 48 CFR 52.209-6.

View Audit 391401

Finding 1177958 (2025-002)

Material Weakness 2025

Anne Arundel County Board of Education

MD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

2025-002 Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: None Award Perio...

2025-002 Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: None Award Period: 7/1/2024 – 6/30/2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: CLA recommends that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The recommendation was included in the FY2024 Single Audit Corrective Action Plan and the following course of action was described therein; The Purchasing Office had processes in place to ensure debarment status was checked before contract award. Both the contract checklist and the Qualifications Affidavit in the solicitation template contained debarment status language to ensure the necessary checks took place. Despite these processes, a contract for curriculum materials was not checked for debarment status before contract award. The cause of that oversight seems to be the different procurement processes used in instructional materials procurements. The contract was not competitively awarded, so they did not require a qualifications affidavit, which would have ensured the debarment status was checked. In this instance, a checklist was not included in the contract file as required, which would have also triggered a debarment check. In response, the Purchasing Office is adding a third layer of oversight - requiring that a revised contract affidavit is completed for every contract award. Language was added to the current contract affidavit that contains an affirmation by the contractor that they are not suspended or debarred by any government entity – local, state, and federal. To summarize, the Purchasing Office will engage one of the three processes listed below to ensure timely debarment checks are conducted on every contract, regardless of funding source. 1) Contract Checklist 2) Qualifications Affidavit 3) Contract Affidavit Contracts chosen in this FY25 sample all predate the implementation of the FY24 corrective action plan as they spanned multiple years. Debarment checks were performed for some of the contracts sampled, but the date of the printout was not legible for the audit team to review. The purchasing team will ensure that dates are legible. AACPS will continue with the process described above to ensure timely debarment checks are conducted. Name(s) of the contact person(s) responsible for corrective action: Mary Jo Childs, Director of Purchasing Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 391387

Finding 1177957 (2025-002)

Material Weakness 2025

Robeson County Housing Authority

NC

HUD Housing Programs

MTW Income Verification and Rent Calculation Explanation of Condition: The Authority operates under HUD-approved MTW waivers, including three-year certifications. In the finding identified, Enterprise Income Verification (EIV) was not utilized during a Year 1 MTW income calculation, resulting in und...

MTW Income Verification and Rent Calculation Explanation of Condition: The Authority operates under HUD-approved MTW waivers, including three-year certifications. In the finding identified, Enterprise Income Verification (EIV) was not utilized during a Year 1 MTW income calculation, resulting in underreported income and an incorrect rent determination that carried forward into the second year of the MTW cycle. Corrective Actions Taken and Planned: To strengthen compliance with HUD occupancy requirements and MTW oversight standards, the Authority has implemented the following corrective actions:  The Authority has developed and implemented a formal Standard Operating Procedure (SOP) for MTW Income Verification and Rent Calculations, which requires: o Mandatory EIV review in accordance with HUD’s verification hierarchy o Documentation of EIV review in each tenant file o Supervisory review and approval of all MTW rent calculations  An internal quality control and audit review process has been established to periodically review rent calculations and certifications for accuracy and compliance.  The recertification process has been restructured so that MTW and annual recertifications are conducted primarily during April and May, allowing staff to focus on accurate income verification and calculations without competing operational demands.  Occupancy staff have received refresher training on MTW requirements, EIV usage, and HUD income verification standards.  The Authority plans to utilize MTW flexibility to implement a Standard Deduction, which will reduce calculation complexity, improve consistency, and minimize the likelihood of future errors. The Authority believes these corrective actions align with HUD monitoring expectations, strengthen internal controls, and demonstrate ongoing commitment to MTW compliance.

View Audit 391377

Finding 1177956 (2025-001)

Material Weakness 2025

Morehouse College

GA

Student Financial Aid Eligibility

Corrective Action Plan Finding No. 2025-001 – Eligibility (Federal Work Study Program) Federal Program: Student Financial Assistance Cluster – Federal Work Study (ALN 84.033) Federal Agency: U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Finding Summary During testing of stu...

Corrective Action Plan Finding No. 2025-001 – Eligibility (Federal Work Study Program) Federal Program: Student Financial Assistance Cluster – Federal Work Study (ALN 84.033) Federal Agency: U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Finding Summary During testing of student eligibility, auditors identified one instance in which a student’s Cost of Attendance (COA) was increased by $2,810 due to participation in the Federal Work Study (FWS) program. Federal regulations do not permit an institution to increase COA solely to accommodate FWS eligibility. Although the adjustment did not result in the student receiving aid exceeding financial need, the adjustment occurred due to a misunderstanding of guidance related to the FWS program. Corrective Action Plan Management agrees with the finding. To address the finding and ensure compliance with federal regulations governing the Federal Work Study program, the Office of Financial Aid will implement the following corrective actions: 1. Policy Clarification and Documentation The Office of Financial Aid will revise its internal awarding policies and procedures to clearly state that the standard practice of awarding Federal Work Study funds must fit within the student established Cost of Attendance (COA). Additionally, the revised policy will explicitly include flexibility to increase the Cost of Attendance only because of approved Special Circumstance appeals, consistent with federal guidance and institutional professional judgment policies. Federal Student Aid Handbook: Application and Verification Guide: Chapter 5 – Special Cases 2. Award Adjustment Procedures When a student’s aid package exceeds need due to the addition of FWS, staff will take the following steps: • Reduction of loan awards, when applicable, to allow FWS funding to be added within the student’s financial need limits.A Loan Adjustment Form will be required for all downward adjustments to loan awards to ensure documentation and transparency. These procedures will ensure that aid adjustments remain compliant with federal need-analysis requirements. Implementation Timeline • Policy updates and procedural documentation: Within 60 days • Process implementation: Beginning with the 2026-2027 academic year packaging cycle

View Audit 391374

Finding 1177953 (2025-001)

Material Weakness 2025

John Wood Community College Dist No. 539

IL

Student Financial Aid

Corrective Action Plan for Current Year Findings 2025-001 Special Tests & Provisions – Return of Title IV Funds This Corrective Action Plan has been established by the Financial Aid and Registrar’s Offices to resolve findings related to Return of Title IV (R2T4) calculation errors. The goal of this ...

Corrective Action Plan for Current Year Findings 2025-001 Special Tests & Provisions – Return of Title IV Funds This Corrective Action Plan has been established by the Financial Aid and Registrar’s Offices to resolve findings related to Return of Title IV (R2T4) calculation errors. The goal of this plan is to ensure 100% data integrity through enhanced system logic, multi-tier manual verification, and cross-departmental reconciliation. Identify and Analyze Errors: The institution conducted a root-case analysis of the identified findings and determined the following: R2T4 Transposition Errors: For five (5) student records, the "Date of School’s Determination" (DOD) and the "Date of Withdrawal/Last Date of Engagement" (LDE) were inadvertently switched during manual entry into the COD system. Corrective Standard: The Withdrawal Date must be verified as the actual Last Date of Engagement (LDE), while the Date of Determination must remain the Banner-stamped withdrawal date. Develop and Implement Data Verification Processes: To prevent recurrence, the following "intrusive checks and balances" system has been implemented: Multi-Tier R2T4 Review (Financial Aid) - A four-point verification process is now mandatory for all Pro-rata calculations: a. Preparation: Financial Aid Specialist calculates the return based on Banner data. b. Validation: Financial Aid Coordinator validates the LDE and DOD against the academic record. c. Confirmation: Financial Aid Manager reviews and confirms previous calculations based on LDE and Banner data. d. Final Oversight: The Director of Financial Aid performs the final verification check before and after the data is committed to the Common Origination and Disbursement (COD) system. e. Standardization: All calculations must include employee initials and date within the Pro-rata Calculation Form, based on the 4-point verification process above, to ensure internal record reconciliation. Person(s) Responsible: Christine Genenbacher-Leinbach, Director of Financial Aid Brittany McKeown, Head of Enrollment, Registrar, Financial Aid Services Timing for Implementation: Currently implemented, as well as a retroactive check of prior R2T4 submissions, starting September 1, 2025. New verification tiers are active as of the current term to ensure immediate compliance without further incidents.

View Audit 391360

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