Corrective Action Plans

Finding 1191951 (2025-006)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-006 Finding: The Department of Health did not have adequate internal controls over cash management for the Epidemiology and Laboratory Capacity for Infectious Diseases, the Immunization Cooperative Agreements and the WIC Special Supplemental Nutrition Program for Women, Infants,...

Finding Number: 2025-006 Finding: The Department of Health did not have adequate internal controls over cash management for the Epidemiology and Laboratory Capacity for Infectious Diseases, the Immunization Cooperative Agreements and the WIC Special Supplemental Nutrition Program for Women, Infants, and Children programs. Program: 10.557 – WIC Special Supplemental Nutrition Program for Women, Infants, and Children 93.268 – Immunization Cooperative Agreements 93.268 – COVID-19 Immunization Cooperative Agreements 93.323 – Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) 93.323 – COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Compliance Requirement: Cash Management Questioned Costs: $160,206 Status: Corrective action in progress Corrective Action: The Department is taking steps to strengthen internal controls over cash management and related system processes. During the audit period, the Department identified issues within the Grants Management System but were unable to implement system enhancements prior to the end of the audit period. The Department will continue to address these system issues to ensure compliance with federal requirements. Additionally, the Department will: • Review and strengthen controls over the accuracy and maintenance of accounting data used in cash draw calculations. • Improve review and monitoring procedures to ensure amounts used to support federal cash draws are accurate, complete, and supported by appropriate documentation. • Evaluate existing roles and responsibilities to ensure appropriate oversight, review, and segregation of duties related to cash management activities. The Department is reviewing the questioned costs identified by the auditors and will take appropriate action in accordance with federal requirements, which may include adjustments or repayment, as necessary. Prior Findings: The conditions noted in this finding were previously reported in findings 2024-036 and 2024-033. Completion Date: Estimated December 2026 Agency Contact: Jeff Arbuckle External Audit Manager (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

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Finding 1191936 (2025-019)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-019 Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to perform program monitoring for subrecipients of the Coronavirus State and Local Fiscal Recovery Funds. Program: 21.027 – COVID-19 Coronavirus State and Lo...

Finding Number: 2025-019 Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to perform program monitoring for subrecipients of the Coronavirus State and Local Fiscal Recovery Funds. Program: 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Subrecipient Monitoring Questioned Costs: $0 Status: Corrective action in progress Corrective Action: To ensure compliance with 2 CFR 200 the Coronavirus State and Local Fiscal Recovery Funds subrecipient monitoring requirements, the Local Government Division program staff will complete the following procedures: Infrastructure Program: • Require active subrecipients to submit a project status report with each reimbursement request before reviewing and approving the invoice for payment. State Broadband Office: • Obtain missing project status reports from subrecipients for the audit period. • Ensure all future invoice documents have a project status report submitted before approving payment, as required in the grantee agreements. Prior Findings: None Completion Date: Estimated April 2026 Agency Contact: Gena Allen, CFE Internal Control Officer (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 1191935 (2025-018)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-018 Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Coronavirus State and Local Fiscal Recovery Funds. Program: 21.027 – COVID-19 Coronavirus State and Loca...

Finding Number: 2025-018 Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Coronavirus State and Local Fiscal Recovery Funds. Program: 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Fund Compliance Requirement: Subrecipient Monitoring Questioned Costs: $0 Status: Corrective action complete Corrective Action: The Infrastructure Program requires risk assessments to be completed for new subawards only. The Department will not be making any additional subawards to subrecipients under the Coronavirus State and Local Fiscal Recovery Fund (SLFRF) award because all funds were obligated as of December 31, 2024. The risk assessment requirement is no longer applicable for SLFRF. Prior Findings: The conditions noted in this finding were previously reported in findings 2024-022, 2023-031, and 2022-021. Completion Date: June 2025 Agency Contact: Gena Allen, CFE Internal Control Officer (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 1191934 (2025-017)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-017 Finding: The Department of Commerce did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Coronavirus State and Local Fiscal Recovery Funds received required single audits, and that it appropriately followed ...

Finding Number: 2025-017 Finding: The Department of Commerce did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Coronavirus State and Local Fiscal Recovery Funds received required single audits, and that it appropriately followed up on findings and issued management decisions. Program: 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Subrecipient Monitoring Questioned Costs: $0 Status: Corrective action complete Corrective Action: The Department partially agrees with the finding. The Department acknowledges that there were subrecipients who should have received management decision letters but were not identified during monitoring. Additional monitoring steps have been added to identify these entities. The Department concludes that the other deficiencies reported were not supported by requirements included in the Code of Federal Regulations (CFR) but were based on the State Auditor’s Office’s preferences. In October 2024, the Internal Controls Office (ICO) added a Management Analyst 5 dedicated to ensuring the requirements in 2 CFR 200.501 Audit Requirements are followed. The ICO also updated processes to ensure compliance with subrecipient monitoring requirements. The ICO maintains that key controls are in place and the Department materially complied with all compliance requirements regarding monitoring subrecipients’ single audit submissions. The ICO will continue to issue management decision letters as required and communicate subrecipients’ non-compliance issues to program management. Prior Findings: The conditions noted in this finding were previously reported in finding 2024-023. Completion Date: July 2025 Agency Contact: Gena Allen, CFE Internal Control Officer (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 1191933 (2025-016)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-016 Finding: The Department of Corrections improperly charged $222 to the Coronavirus State and Local Fiscal Recovery Funds program. Program: 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Activities Allowed or Unallowed and Allowable...

Finding Number: 2025-016 Finding: The Department of Corrections improperly charged $222 to the Coronavirus State and Local Fiscal Recovery Funds program. Program: 21.027 – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Questioned Costs: $222 Status: Corrective action complete Corrective Action: The Department concurs that the questioned costs identified by the auditors were charged to the grant due to an employee’s overpayment. The Department is committed to ensuring compliance with federal grant requirements. In response to this audit finding, the Department: • Provided education to local payroll liaisons to ensure the Automated Time & Labor Advanced Scheduling (ATLAS) system checklist and standard processes are followed. • Reviewed the logic around shift differential in ATLAS and determined that the cause of the shift differential errors identified in the audit was the result of shifts not assigned to employees’ schedules. • Worked with the vendor to provide a report identifying employees whose shifts in ATLAS show a discrepancy that may affect shift differential overtime logic. The Department will discuss any repayment of questioned costs through the normal audit resolution process with the U.S. Department of the Treasury. Prior Findings: None Completion Date: November 2025 Agency Contact: Sandra Morrison Comptroller (360) 480-4596 svmorrison@doc1.wa.gov

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Finding 1191856 (2025-015)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-015 Finding: The Housing Finance Commission did not have adequate internal controls over and did not comply with reporting requirements for the Homeowner Assistance Fund program. Program: 21.026 – COVID-19 Homeowner Assistance Fund Compliance Requirement: Reporting Questioned Co...

Finding Number: 2025-015 Finding: The Housing Finance Commission did not have adequate internal controls over and did not comply with reporting requirements for the Homeowner Assistance Fund program. Program: 21.026 – COVID-19 Homeowner Assistance Fund Compliance Requirement: Reporting Questioned Costs: $0 Status: Corrective action complete Corrective Action: To address the deficiencies identified by the auditors in prior years’ findings, the Commission has strengthened internal controls in completing annual performance reports for the Homeowner Assistance Fund program. The Commission has refined its management review process and updated procedures to require additional review and approval by Finance Division management prior to submitting the annual report. This will be evidenced with submission of the federal fiscal year 2026 report. Prior Findings: The conditions noted in this finding were previously reported in findings 2024-017 and 2023-025. Completion Date: November 2025 Agency Contact: Lucas Loranger Senior Finance Director (206) 464-7139 Lucas.Loranger@wshfc.org

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Finding 1191854 (2025-014)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-014 Finding: The Department of Transportation did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Highway Planning and Construction program. Program: 20.205 – Highway Planning and Construction Com...

Finding Number: 2025-014 Finding: The Department of Transportation did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Highway Planning and Construction program. Program: 20.205 – Highway Planning and Construction Compliance Requirement: Subrecipient Monitoring Questioned Costs: $0 Status: Corrective action complete Corrective Action: The Department is committed to ensuring its grant programs comply with federal regulations regarding subrecipient risk assessments. The responsibility for conducting risk assessments for subrecipients under the Federal Highway Administration grant programs primarily rests with the Department’s Regional Local Programs Engineers located in six regions across the state. The Department had plans to complete a risk assessment at each phase of a project; however, staff turnover contributed to the lack of consistency and timeliness in completing these assessments. The Department revised the risk assessment procedures in March 2022. As part of ongoing efforts and to help ensure consistency of the risk assessment process, the Department shared the audit findings and exceptions with regional staff and reminded them of the updated risk assessment program guidelines. The Department will continue to work with Regional Local Programs Engineers and regional management to ensure compliance with federal requirements. Prior Findings: The conditions noted in this finding were previously reported in findings 2024-012 and 2023-012. Completion Date: December 2025 Agency Contact: Jesse Daniels Audit Liaison (360) 705-7035 jesse.daniels@wsdot.wa.gov

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Finding 1191853 (2025-012)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-012 Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it profiled all claimants under the Unemployment Insurance program to identify people likely to need reemployment services and ensure repor...

Finding Number: 2025-012 Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it profiled all claimants under the Unemployment Insurance program to identify people likely to need reemployment services and ensure reports are reviewed before submission to the federal government. Program: 17.225 – Unemployment Insurance Compliance Requirement: Special Tests and Provisions – UI Reemployment Programs: Worker Profiling and Reemployment Services (WPRS) and Reemployment Services and Eligibility Assessments Questioned Costs: $0 Status: Corrective action in progress Corrective Action: In response to the finding and recommendations, the Department has taken the following actions: • In December 2025, reviewed the design of the Unemployment Tax and Benefits (UTAB) calculation and risk profile score and performed testing on its accuracy. • In January 2026: o Implemented additional internal controls to ensure claimants are profiled and prioritized for reemployment services based on their risk of exhausting unemployment benefits, in accordance with federal requirements. o Provided additional guidance to staff to ensure quarterly Employment and Training Administration (ETA) reports are completed accurately and submitted timely in accordance with ETA procedures. o Implemented a process to improve oversight in the reporting procedures to include adequate review and approval before submission to the grantor, and the proper retention of filed reports. The Department continues work to fully staff the unit and is working with the federal grantor and state partners regarding training and guidance on new accounting and reporting system changes. The Department partially concurs with the recommendation to reconcile the UTAB and Reemployment Appointment Scheduler (RAS) interface. There is currently a process in place to notify the RAS team if a record fails at the time of data transmission between UTAB and RAS. The Department is working on prioritizing resources to review the processes to verify that the complete UTAB exit file was successfully received by RAS. This work is anticipated to be completed in June 2026. Prior Findings: The conditions noted in this finding were previously reported in findings 2024-009 and 2023-010. Completion Date: Estimated June 2026 Agency Contact: Joshua Summers External Audit Manager (360) 529-6718 Joshua.Summers@esd.wa.gov

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Finding 1191852 (2025-011)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-011 Finding: The Employment Security Department did not have adequate internal controls over the 2208A reporting requirements for the Unemployment Insurance program. Program: 17.225 – Unemployment Insurance Compliance Requirement: Reporting Questioned Costs: $0 Status: Correctiv...

Finding Number: 2025-011 Finding: The Employment Security Department did not have adequate internal controls over the 2208A reporting requirements for the Unemployment Insurance program. Program: 17.225 – Unemployment Insurance Compliance Requirement: Reporting Questioned Costs: $0 Status: Corrective action complete Corrective Action: The Department notified our federal grantor when we became aware of the issue and submitted corrected reports for the periods in question. To improve internal controls, the Department: • Updated internal processes for reviewing reports and retaining all supporting documentation. • Implemented a new process to run a cumulative report to provide additional backup and to detect variances throughout the fiscal year. Prior Findings: None Completion Date: December 2025 Agency Contact: Joshua Summers External Audit Manager (360) 529-6718 Joshua.Summers@esd.wa.gov

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Finding 1191849 (2025-009)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-009 Finding: The Department of Social and Health Services did not have adequate internal controls over financial reporting for the Summer Electronic Benefits Transfer Program for Children. Program: 10.646 – Summer Electronic Benefits Transfer Program for Children Compliance Requ...

Finding Number: 2025-009 Finding: The Department of Social and Health Services did not have adequate internal controls over financial reporting for the Summer Electronic Benefits Transfer Program for Children. Program: 10.646 – Summer Electronic Benefits Transfer Program for Children Compliance Requirement: Reporting Questioned Costs: $0 Status: Corrective action in progress Corrective Action: The Department concurs with the finding. For the two reports that the auditors determined lacked secondary review and approval, the Department maintains that both instances were anomalies that occurred during a staffing transition within the Division of Finance and Financial Resources. The reports were complete, accurate, and submitted timely. To strengthen internal controls over financial reporting, the Department will: • Update federal reporting procedures to designate a backup reviewer and approver. • Communicate the expectations in the updated procedures and provide training to the designated backup reviewer and approver. Prior Findings: None Completion Date: Estimated April 2026 Agency Contact: Richard Meyer External Audit Compliance Manager Richard.Meyer@dshs.wa.gov

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Finding 1191848 (2025-008)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-008 Finding: The Department of Social and Health Services did not have adequate internal controls to ensure payments were allowable and made only to eligible beneficiaries for the Summer Electronic Benefits Transfer Program for Children. Program: 10.646 – Summer Electronic Benef...

Finding Number: 2025-008 Finding: The Department of Social and Health Services did not have adequate internal controls to ensure payments were allowable and made only to eligible beneficiaries for the Summer Electronic Benefits Transfer Program for Children. Program: 10.646 – Summer Electronic Benefits Transfer Program for Children Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Eligibility Questioned Costs: $55,454 Status: Corrective action in progress Corrective Action: The Department concurs with the finding. The improper payments identified by the auditors resulted from the challenges of a new program in its first year of implementation. Errors occurred when users from the Department and the Office of Superintendent of Public Instruction migrated data onto new templates and inadvertently included ineligible students and inaccurate dates of birth. The Department agrees that thorough data validation prior to issuance of benefits would have better identified systemic issues related to age and enrollment. Upon discovery, the Department promptly removed ineligible issuances to limit the state’s liability. The Department does not process overpayments on spent benefits based on 7 CFR 292.27(c)(2): “To the maximum extent practicable, Summer EBT agencies should limit claims against households to situations where there is evidence that the household knowingly obtained benefits through fraudulent activities.” In addition, the approved state plan with the federal grantor included a provision that the Department will not process overpayments for improper benefits unless there is evidence of fraud. By April 2026, the Department’s Community Services Division (CSD) will: • Implement a review process to verify age of applicants and address questionable data before submission to the contractor. • Amend the contract with the contractor to include specific reporting requirements for duplicate issuances and identification of ineligible participants. By July 2026, the Department’s CSD will: • Implement a mandatory data reconciliation process in which the contractor must provide full participant datasets, including dates of birth and eligibility status, to the CSD for review and approval prior to benefit issuance. • Request the contractor to complete an enhancement to its eligibility determination system to automatically flag participants under age one or over age 22 for further review. • Request the Electronic Benefits Transfer vendor to create a standard monthly report to show expenditures and expired benefits by client. If the grantor contacts the Department regarding the questioned costs identified in this finding, the Department will consult with the grantor to determine whether repayment is required. Prior Findings: None Completion Date: Estimated July 2026 Agency Contact: Richard Meyer External Audit Compliance Manager Richard.Meyer@dshs.wa.gov

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Finding 1191845 (2025-007)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Finding Number: 2025-007 Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with requirements to ensure it communicated federal award identification elements to subrecipients of the Child and Adult Care Food Program. Program: 1...

Finding Number: 2025-007 Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with requirements to ensure it communicated federal award identification elements to subrecipients of the Child and Adult Care Food Program. Program: 10.558 – Child and Adult Care Food Program Compliance Requirement: Subrecipient Monitoring Questioned Costs: $0 Status: Corrective action complete Corrective Action: In response to the prior year’s finding, the Office had updated procedures for distributing federal award information and requirements to all subrecipients of the Child and Adult Care Food Program to ensure compliance with federal requirements. To further strengthen internal controls to address the exceptions identified during the audit, the Office has made additional procedural updates to address situations where new program operators and sponsors renew outside of the typical renewal cycle. Prior Findings: The conditions noted in this finding were previously reported in findings 2024-004 and 2023-003. Completion Date: January 2026 Agency Contact: Chaundi Barbosa Director, CACFP (360) 725-0411 chaundi.barbosa@k12.wa.us

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Finding 1191842 (2025-001)

Material Weakness 2025

Youth Network Council

IL

During the year a new timesheet template was created. There were a couple of instances during the initial implementation of this new spreadsheet where timesheets did not agree to the template. We believe that this inconsistency has since been addressed.

View Audit 395687

Finding 1191840 (2025-001)

Material Weakness 2025

Town of Easton (the Easton Utilities Commission)

MD

Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend the Commission continue with the policies and procedures now established and require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with...

Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend the Commission continue with the policies and procedures now established and require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In April 2024, the Commission established a policy requiring documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Easton Utilities immediately began checking new vendors as part of the vendor establishment process and began the process to verify existing vendors. Easton Utilities had around 3,000 established vendors in the system, leading to a longer period to verify all vendors. This finding relates to inventory transactions. At the time of purchase, this inventory was not yet determined to be related to the grant. The inventory was purchased through Easton Utilities' standard inventory procurement process related to keeping appropriate stock to support the ongoing business. Inventory is charged to the grant at the time it is used and requisitioned out. All material requisitions are approved by an appointed responsible person within the Easton Velocity team before entered by the Accounting team. The vendor was checked for status on 8/1/2024. 92% of the inventory associated with this purchase that was charged to the grant was charged after 8/1/2024. Name of the contact person responsible for corrective action: Carrie Manuel Planned completion date for corrective action plan: Corrective action was taken April 2024.

View Audit 395670

Finding 1191838 (2025-001)

Material Weakness 2025

The Housing Authority of the County of Kern

CA

FA-2025-001 Moving to Work Demonstration Program, United States Department of Housing and Urban Development, Federal Assistance listing number #14.881. Management’s Response/Planned Corrective Action: The Authority acknowledges the finding related to untimely and incomplete Housing Quality Standards...

FA-2025-001 Moving to Work Demonstration Program, United States Department of Housing and Urban Development, Federal Assistance listing number #14.881. Management’s Response/Planned Corrective Action: The Authority acknowledges the finding related to untimely and incomplete Housing Quality Standards (HQS) inspections under the Moving to Work Demonstration Program (Assistance Listing #14.881). To correct the deficiencies noted and ensure full alignment with HUD regulatory requirements, the Authority has undertaken the following corrective actions: 1. Immediate Staffing Intervention and Backlog Elimination: To address the substantial number of past-due inspections, the Authority hired two temporary inspectors dedicated exclusively to completing all overdue HQS inspections. This focused initiative was active from June 2025 through December 2025 and successfully brought delinquent inspections current. 2. Establishment of Permanent Oversight Structure: In December 2025, the Authority hired a full-time Lead Inspector to oversee all aspects of the HQS process. This position is responsible for: o Ensuring compliance with 24 CFR §§ 982.401–982.405 o Implementing quality control measures o Monitoring inspection timeliness o Supervising inspection staff and coordinating workload assignments o Ensuring that internal policies fully align with HUD requirements, including correction of Administrative Plan Section 7A 3. Implementation of Bi-Weekly Internal Compliance Audits: To ensure ongoing adherence to HQS requirements, the Authority has instituted bi-weekly internal audits. Under this process: o A program administrator reviews a sample of completed HQS inspections o Timeliness, accuracy, documentation, and system entries are verified o Any identified deficiencies are corrected immediately and used for staff retraining 4. Ongoing Training and Compliance Reinforcement: All inspection staff have received updated training on HQS requirements, inspection timelines, documentation standards, and the Administrative Plan. Additional refresher training will be conducted at least annually or whenever regulatory guidance is updated. Anticipated Completion Date: All corrective actions described above have already been implemented or are currently in the final stages of implementation. Responsible Officials • Housing Administrator over Voucher Programs – Oversight of HQS compliance and policy revision • Lead Inspector (HQS) – Daily operational management of inspections • Assistant Executive Director – Monitoring of audit controls and QA reviews

View Audit 395651

Finding 1191837 (2025-002)

Material Weakness 2025

Brown County Community Unit School District #1

IL

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: In order to rectify the finding related to the reporting of the meal claims, Brown County CUSD ...

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: In order to rectify the finding related to the reporting of the meal claims, Brown County CUSD #1 will provide an independent review of the Accuclaim records and the meal claim with a signature indicating approval. The person best suited to provide an approval signature is the superintendent of the district. Management Response: The superintendent agrees with the finding and will perform and document the review as stated in the corrective action plan.

View Audit 395649

Finding 1191829 (2025-007)

Material Weakness 2025

Lincoln University

MO

We acknowledge the auditor's finding regarding the timing of federal drawdowns and the draw down of Title III funds for expenditures related to another Department of Education program. We recognize that the drawdown of $174,553 exceeded substantiated program expenditures and that $3,772 was drawn do...

We acknowledge the auditor's finding regarding the timing of federal drawdowns and the draw down of Title III funds for expenditures related to another Department of Education program. We recognize that the drawdown of $174,553 exceeded substantiated program expenditures and that $3,772 was drawn down from the Title III award for non-Title III costs. The root cause of this issue was insufficient processes and controls within the administration and finance department related to cash management and award-specific drawdown procedures. These gaps contributed to delays between drawdown and expenditure, as well as the misallocation of drawdowns to the incorrect award. To address the findings, Lincoln has implemented the following corrective measures: • Revised Cash Management Procedures: We have updated our federal drawdown procedures to ensure compliance with the requirement to minimize the time between drawdown and disbursement of funds. Drawdowns will be calculated on a reimbursement basis and tied directly to documented, allowable, and incurred expenditures. • Award-Specific Drawdown Controls: We have implemented a mandatory pre-draw review process requiring reconciliation of expenditures to the correct award prior to any drawdown request. This includes a secondary review by the Comptroller. • Staff Training: All personnel involved in grant accounting and cash management have completed refresher training on federal cash management requirements, including the distinction between awards and the importance of accurate allocation. • Monthly Internal Reconciliations: We have instituted monthly reconciliations of drawdowns to expenditures for all federal awards to ensure accuracy and timely correction of discrepancies. The corrective measures above are designed to ensure full compliance with federal cash management regulations and to prevent future occurrences of excessive or misallocated drawdowns.

View Audit 395639

Finding 1191826 (2025-006)

Material Weakness 2025

Lincoln University

MO

The University acknowledges the audit finding regarding the reporting of undergraduate tuition and fees on the Fiscal Operations Report and Application to Participate (FISAP). We appreciate the auditors' review and agree that the amounts reported did not align with the institution's underlying recor...

The University acknowledges the audit finding regarding the reporting of undergraduate tuition and fees on the Fiscal Operations Report and Application to Participate (FISAP). We appreciate the auditors' review and agree that the amounts reported did not align with the institution's underlying records due to the use of net tuition and fee data that included both undergraduate and graduate/professional activity. To address the findings, Lincoln has implemented the following corrective measures: - Procedures have been updated to ensure that only gross undergraduate tuition and fee data-consistent with FISAP reporting requirements will be used in future submissions. - Financial Aid and Finance staff will jointly review the FSAP instructions and clarify the data elements required for accurate reporting. - A cross-departmental reconciliation step between Financial Aid and Finance prior to FISAP submission. - Documentation of data sources and validation steps to ensure consistency with underlying financial records. The corrective measures above are designed to ensure amounts reported for tuition and fees on the FISAP align with the institution's underlying records.

View Audit 395639

Finding 1191824 (2025-005)

Material Weakness 2025

Lincoln University

MO

The Office of Student Financial Services acknowledges the finding related to the Return of Title IV Funds. We recognize the importance of ensuring accurate calculations and timely return of unearned Title IV funds as part of our federal compliance obligations. The Office of Student Financial Service...

The Office of Student Financial Services acknowledges the finding related to the Return of Title IV Funds. We recognize the importance of ensuring accurate calculations and timely return of unearned Title IV funds as part of our federal compliance obligations. The Office of Student Financial Services will strengthen procedures for Return of Title IV (R2T4) calculations. All withdrawals will be reviewed using the R2T4 calculation worksheet, and calculations will be verified by a second staff member prior to posting. A tracking log will be maintained to ensure funds are returned within required timeframes. Written procedures will be updated to include required timelines and review steps. Staff training will be conducted to ensure consistent application of federal regulations. The Director of Financial Aid will periodically review completed calculations for accuracy. These actions are intended to correct the issues that contributed to the calculation errors and delays noted during the audit and to ensure compliance with Return of Title IV Funds regulations moving forward.

View Audit 395639

Finding 1191822 (2025-004)

Material Weakness 2025

Lincoln University

MO

The University concurs with the finding that the University does not have a written information security program that addresses all required elements of the Gramm-Leach-Bliley Act . While the University processes defined to address GLBA are in place, the Information Security Policy does not specific...

The University concurs with the finding that the University does not have a written information security program that addresses all required elements of the Gramm-Leach-Bliley Act . While the University processes defined to address GLBA are in place, the Information Security Policy does not specifically address Gramm-Leach-Bliley Act (GLBA) security criteria. It is now understood that the defined processes that address and support GLBA security criteria need to be put into a format that is published for access by the Lincoln community. Lincoln has started the process to create and publish the written information security program that addresses all required elements of GLBA. The corrective measures above are designed to ensure full compliance with all required elements of the GLBA.

View Audit 395639

Finding 1191820 (2025-003)

Material Weakness 2025

Lincoln University

MO

The Office of Student Financial Services acknowledges the findings related to Reporting: Financial Reporting through the Common Origination and Disbursement (COD) System. We recognize the importance of accurate and timely reporting of origination data to ensure compliance with federal Pell Grant and...

The Office of Student Financial Services acknowledges the findings related to Reporting: Financial Reporting through the Common Origination and Disbursement (COD) System. We recognize the importance of accurate and timely reporting of origination data to ensure compliance with federal Pell Grant and Direct Loan requirements. The Office of Student Financial Services will implement additional controls to ensure accuracy of origination and disbursement reporting to COD. Prior to submission, staff will review enrollment dates, academic year dates, and disbursement dates against the academic calendar and student records in Colleague. A second-level review will be performed for a sample of records each term. Written procedures will be updated to document required verification steps before transmitting data to COD. Training will be provided to staff responsible for COD processing. These actions are intended to correct the issues contributing to this repeat finding, strengthen reporting accuracy, and ensure continued compliance with COD reporting requirements.

View Audit 395639

Finding 1191818 (2025-002)

Material Weakness 2025

Lincoln University

MO

The University acknowledges the findings related to Special Tests: NSLDS Reporting. We recognize the importance of accurate and timely enrollment reporting to the National Student Loan Data System (NSLDS) to ensure proper administration of federal student aid programs. The institution reports enroll...

The University acknowledges the findings related to Special Tests: NSLDS Reporting. We recognize the importance of accurate and timely enrollment reporting to the National Student Loan Data System (NSLDS) to ensure proper administration of federal student aid programs. The institution reports enrollment and program information to NSLDS via the National Student Clearinghouse. The Student Clearinghouse offers a complimentary service for reviewing and correcting reporting issues for compliance. The office of the Registrar will engage the services of the Student Clearinghouse to identify where procedural errors may be causing delays or inaccuracies in the reporting data based on the findings of the 2025 audit. Recommendations made by the Student Clearinghouse consultant will be added into the documentation and standard practices for enrollment reporting. These actions are intended to correct the issues contributing to this repeat finding, strengthen reporting accuracy, and ensure continued compliance with NSLDS reporting requirements.

View Audit 395639

Finding 1191816 (2025-001)

Material Weakness 2025

Lincoln University

MO

The Office of Student Financial Services acknowledges the finding and will implement corrective actions to ensure full compliance regarding Year-Round Pell Grant eligibility. To address the issue, enhanced processes and internal controls will be established to ensure all eligible students are accura...

The Office of Student Financial Services acknowledges the finding and will implement corrective actions to ensure full compliance regarding Year-Round Pell Grant eligibility. To address the issue, enhanced processes and internal controls will be established to ensure all eligible students are accurately identified for Summer Pell Grant disbursements. The Office of Student Financial Services will implement enhanced procedures to ensure all eligible students are properly identified for Year-Round Pell Grant awards. Each term, a review report will be generated to identify summer enrollees who received Pell Grant funding during the fall and/or spring terms. Financial aid staff will assess eligibility prior to disbursement by verifying enrollment intensity, cost of attendance, and remaining annual Pell eligibility. Written procedures will be updated to require a Pell eligibility review before processing any summer disbursements. The Director of Financial Aid will review the report each term to monitor compliance with these procedures.

View Audit 395639

Finding 1191812 (2025-002)

Material Weakness 2025

St Luke's Health Corporation

MO

Finding 2025-002 – Earmarking (Significant Deficiency) View of Responsible Official: Management concurs with the finding. Management costs charged to the FEMA award exceeded the 5% statutory cap. Management has implemented enhanced monitoring procedures to track cumulative management costs against t...

Finding 2025-002 – Earmarking (Significant Deficiency) View of Responsible Official: Management concurs with the finding. Management costs charged to the FEMA award exceeded the 5% statutory cap. Management has implemented enhanced monitoring procedures to track cumulative management costs against total FEMA obligated amounts on a recurring basis and to review compliance with the statutory limitation before additional amounts are submitted or recorded. Specifically, management will maintain a calculation of the allowable management cost cap based on total FEMA obligations, reconcile cumulative management costs recorded to that cap, and require supervisory review of the calculation and supporting documentation prior to submission of future claims and during period-end close. Management will also review the amount identified as questioned costs and work with the appropriate parties to resolve the excess amount in accordance with applicable grant requirements. Responsible Parties: Director of Finance, Vice President of Finance Anticipated Completion Date: June 30, 2026

View Audit 395627

Finding 1191811 (2025-001)

Material Weakness 2025

St Luke's Health Corporation

MO

Management response Finding 2025-001 – Allowability and Period of Performance (Material Weakness) View of Responsible Official: Management concurs with the finding. During the audit period, controls over payroll documentation for FEMA-related labor costs were not sufficiently designed and documented...

Management response Finding 2025-001 – Allowability and Period of Performance (Material Weakness) View of Responsible Official: Management concurs with the finding. During the audit period, controls over payroll documentation for FEMA-related labor costs were not sufficiently designed and documented to demonstrate independent supervisory review and approval of timecards, nor were controls in place to evidence review of wage rates for reasonableness prior to charging labor costs to the award. Management has strengthened its control procedures. Supervisors are required to review and approve employee timecards each pay period in UKG, and compliance with timecard approval is monitored through exception reporting provided to management. In addition, management has implemented a review control over wage rates charged to FEMA claims to verify that rates used are supported and reasonable in accordance with applicable Uniform Guidance requirements and internal policy. These controls will be documented and retained as part of the support for future federal award reporting. Responsible Parties: Payroll Manager, Director of Finance, Vice President of Finance Anticipated Completion Date: Complete

View Audit 395627

Corrective Action Plans

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