Corrective Action Plans

2025-001: Exit Counseling Notification Not Performed Timely Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period – Year Ended June 30, 2025 Condition Found During our student file testing, we noted one student out of forty was not sent exit counseling ...

2025-001: Exit Counseling Notification Not Performed Timely Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period – Year Ended June 30, 2025 Condition Found During our student file testing, we noted one student out of forty was not sent exit counseling notification within thirty days after the student withdrew. We consider the exit counseling notification not being performed in a timely manner to be an instance of noncompliance with the Eligibility Compliance Requirement. Corrective Action Plan The College has implemented two new procedures that query data to identify financial aid recipients that have withdrawn from classes. The first query identifies new loan borrowers that have dropped below half-time status and the second query identifies previous loan borrowers that have dropped below half-time status. These queries will be run bi-weekly to identify students that must be sent exit counseling notifications within thirty days of withdrawal. Responsible Person for Corrective Action Plan Jeffrey A. Heap, Sr. Director, Financial Services & Controller Deanna Hogan, Director, Financial Aid Implementation Date of Corrective Action Plan October 3, 2025

View Audit 376508

Finding 1165725 (2025-006)

Material Weakness 2025

Iditarod Area School District

AK

Allowable Costs / Cost Principles Significant Deficiency § 200.400

Finding 2025-006 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Activities Name of Contact Person: Tamara VanderPool, Payroll Director and Lisa Pearce, Business Manager Root Cause: **Insufficient staffing level. Inconsistent application of the personnel action form...

Finding 2025-006 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Activities Name of Contact Person: Tamara VanderPool, Payroll Director and Lisa Pearce, Business Manager Root Cause: **Insufficient staffing level. Inconsistent application of the personnel action forms and required documentation for changes to payroll details. Corrective Action Plan: • Clarify roles and responsibilities regarding payroll processing. • Establish a review process of all payroll transactions and documentation. Proposed Completion Date: Fall of 2025.

View Audit 376486

Finding 1165724 (2025-003)

Material Weakness 2025

Step Academy

MN

2025-003 Free and Reduced Lunch Reporting During our audit, we requested supporting documentation for the meal counts done by the Charter School and reported to MDE. We encountered the following: • The meals reported at the St. Paul school site did not agree to the numbers listed in the meal counts....

2025-003 Free and Reduced Lunch Reporting During our audit, we requested supporting documentation for the meal counts done by the Charter School and reported to MDE. We encountered the following: • The meals reported at the St. Paul school site did not agree to the numbers listed in the meal counts. • Meals appear to be under-reported in the months of December and January based on the support received. Corrective Action Plan (CAP): 1. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: The Charter School will review current procedures surrounding meal counts to ensure the numbers reported to MDE are properly supported. 3. Official Responsible for Ensuring CAP: Paul Scanlon, the Executive Director is the official responsible for ensuring corrective action. 4. Planned Completion Date for CAP: Fiscal year 2025-2026. 5. Plan to Monitor Completion of CAP: The Charter School will implement meal count procedures to be monitored by Paul Scanlon and completed by other staff members at the school.

View Audit 376469

Finding 1165722 (2025-003)

Material Weakness 2025

Bethany Lutheran College, Inc.

MN

Subrecipient Monitoring Significant Deficiency

Finding 2025-003: GLBA Repeat Finding 2024-003 Federal Program - Student Financial Assistance Cluster Federal Agency- U.S. Department of Education Pass-Through Entity- Not Applicable Assistance Listing Number - 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work-Study Pr...

Finding 2025-003: GLBA Repeat Finding 2024-003 Federal Program - Student Financial Assistance Cluster Federal Agency- U.S. Department of Education Pass-Through Entity- Not Applicable Assistance Listing Number - 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work-Study Program 84.038 - Federal Perkins Loan Program 84.063 - Federal Pell Grant Program 84.268 - Federal Direct Student Loans Criteria: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their informationsharing practices to their customers and to safeguard sensitive data (16 CFR 314). institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with few that 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution's written information security program must address the implementation ofthe minimum safeguards identified in 16 CFR 314.4(c)(l) through (8) including: assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16CFR 314.4(d)). Condition/Context: Under a college's Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned Costs: Not applicable. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The Corporation's students' personal information could be vulnerable. Recommendation: We recommend the Corporation review each element of GLBA to ensure compliance with all necessary requirements. Corrective Action Plan: Corrective Action Planned: To ensure continued GLBA compliance the Corporation contracted with FRSecure to develop a risk assessment and roadmap which did a system scan for issues, an assessor interviewed staff including IT, HR, Finance Leaders and others to learn more about the current state of overall security program. Compliance with GLBA was part of their review. FRSecure issued an assessment 'Roadmap Plan' for the department to review and the Corporation will implement the results as feasible. Name of the contact person responsible for corrective action: John Sehloff, Director of Information Technology Anticipated Completion Date: June 30, 2026

View Audit 376467

Finding 1165717 (2025-002)

Material Weakness 2025

Cicero Housing Development Fund Company, Inc.

NY

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

Finding 2025-002: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 and entity-wide Recommendation: Our auditors recommended that we schedule and hold an annual meeting of the board of directors and document minutes ...

Finding 2025-002: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 and entity-wide Recommendation: Our auditors recommended that we schedule and hold an annual meeting of the board of directors and document minutes and the annual report of directors. Additionally, they recommended that we adopt a board governance calendar with statutory checkpoints (annual meeting, director elections, policy reviews) and assign responsibility for compliance tracking. Action Taken: Sacred Heart Apartments has drafted an annual report of directors and are in the process of scheduling an annual meeting. Additionally, Sacred Heart Apartments has implemented a governance calendar and checklist. Name of Contact Person Responsible for Corrective Action: John Lutz, Vice President of Finance, (315) 424- 1821. Anticipated Completion Date: March 31, 2026

View Audit 376456

Finding 1165716 (2025-001)

Material Weakness 2025

Cicero Housing Development Fund Company, Inc.

NY

HUD Housing Programs

U.S. Department of Housing and Urban Development Cicero Housing Development Fund Company, Inc. (Sacred Heart Apartments), HUD Project No. 014-11192 respectfully submits the following corrective action plan for the year ended March 31, 2025. Name and address of independent public accounting firm: Bon...

U.S. Department of Housing and Urban Development Cicero Housing Development Fund Company, Inc. (Sacred Heart Apartments), HUD Project No. 014-11192 respectfully submits the following corrective action plan for the year ended March 31, 2025. Name and address of independent public accounting firm: Bonadio & Co., LLP, 432 North Franklin Street #60, Syracuse, New York 13204 Audit period: April 1, 2024 – March 31, 2025 The finding from the 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2025-001: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Condition: During the audit, a sample of 4 tenant files were tested. It was noted that the executed lease and HUD Form 50059 were not properly signed and dated by the tenant as required by HUD regulations. Recommendation: Sacred Heart Apartments should implement a control procedure to verify that all leases and HUD Form 50059 certifications are fully signed and dated by both parties prior to move-in or recertification. Action Taken: Sacred Heart Apartments reviewed tenant files for required documentation. Completion Date: December 2025 Name of Contact Person Responsible for Corrective Action: John Lutz, Vice President of Finance, (315) 424-1821.

View Audit 376456

Finding 1165715 (2025-002)

Material Weakness 2025

Pond Street Housing Development Fund Company INC

NY

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

Finding 2025-002: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 and entity-wide Recommendation: Our auditors recommended that we schedule and hold an annual meeting of the board of directors and document minutes ...

Finding 2025-002: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 and entity-wide Recommendation: Our auditors recommended that we schedule and hold an annual meeting of the board of directors and document minutes and the annual report of directors. Additionally, they recommended that we adopt a board governance calendar with statutory checkpoints (annual meeting, director elections, policy reviews) and assign responsibility for compliance tracking. Action Taken: Bishop Harrison Apartments has drafted an annual report of directors and are scheduling an annual meeting. Additionally, Bishop Harrison Apartments has implemented a governance calendar and checklist. Name of Contact Person Responsible for Corrective Action: John Lutz, Vice President of Finance, (315) 424- 1821. Anticipated Completion Date: March 31, 2026

View Audit 376453

Finding 1165714 (2025-001)

Material Weakness 2025

Pond Street Housing Development Fund Company INC

NY

HUD Housing Programs Cash Management

U.S. Department of Housing and Urban Development Pond Street Housing Development Fund Company, Inc. (Bishop Harrison Apartments), HUD Project No. 014-11248 respectfully submits the following corrective action plan for the year ended March 31, 2025. Name and address of independent public accounting f...

U.S. Department of Housing and Urban Development Pond Street Housing Development Fund Company, Inc. (Bishop Harrison Apartments), HUD Project No. 014-11248 respectfully submits the following corrective action plan for the year ended March 31, 2025. Name and address of independent public accounting firm: Bonadio & Co., LLP 432 North Franklin Street #60 Syracuse, New York 13204 Audit period: April 1, 2024 – March 31, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2025-001: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditors recommended that we ensure residual receipts are made within 60 days of year-end in accordance with the HUD Regulatory Agreement. Action Taken: Bishop Harrison Apartments made the required deposit on June 27, 2024. Name of Contact Person Responsible for Corrective Action: John Lutz, Vice President of Finance, (315) 424-1821. Completion Date: June 27, 2024

View Audit 376453

Finding 1165711 (2025-002)

Material Weakness 2025

Pompei Housing Development Fund Company, Inc.

NY

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

Finding 2025-002: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 and entity-wide Recommendation: Our auditors recommended that we schedule and hold an annual meeting of the board of directors and document minutes ...

Finding 2025-002: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 and entity-wide Recommendation: Our auditors recommended that we schedule and hold an annual meeting of the board of directors and document minutes and the annual report of directors. Additionally, they recommended that we adopt a board governance calendar with statutory checkpoints (annual meeting, director elections, policy reviews) and assign responsibility for compliance tracking. Action Taken: Pompei North Apartments has drafted an annual report of directors and are in the process of scheduling an annual meeting. Additionally, Pompei North Apartments has implemented a governance calendar and checklist. Name of Contact Person Responsible for Corrective Action: John Lutz, Vice President of Finance, (315) 424- 1821. Anticipated Completion Date: March 31, 2026

View Audit 376450

Finding 1165710 (2025-001)

Material Weakness 2025

Pompei Housing Development Fund Company, Inc.

NY

HUD Housing Programs

U.S. Department of Housing and Urban Development Pompei Housing Development Fund Company, Inc. (Pompei North Apartments), HUD Project No. 014-11249 respectfully submits the following corrective action plan for the year ended March 31, 2025. Name and address of independent public accounting firm: Bon...

U.S. Department of Housing and Urban Development Pompei Housing Development Fund Company, Inc. (Pompei North Apartments), HUD Project No. 014-11249 respectfully submits the following corrective action plan for the year ended March 31, 2025. Name and address of independent public accounting firm: Bonadio & Co., LLP, 432 North Franklin Street #60, Syracuse, New York 13204 Audit period: April 1, 2024 – March 31, 2025 The finding from the 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2025-001: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Condition: The required deposit of $139,991 for the year ended March 31, 2024 was made after the 60 day deadline. Recommendation: Pompei North Apartments should ensure residual receipts are made within 60 days of year-end in accordance with the HUD Regulatory Agreement. Action Taken: The required deposit was made on June 27, 2024. Completion Date: June 27, 2024 Name of Contact Person Responsible for Corrective Action: John Lutz, Vice President of Finance, (315) 424-1821.

View Audit 376450

Finding 1165709 (2025-001)

Material Weakness 2025

North Scott Community School District

IA

School Nutrition Programs

The District will annually prepare the indirect cost charged to the program based on current state guidance and templates.

View Audit 376449

Finding 1165704 (2025-001)

Material Weakness 2025

Comstock Public Schools

MI

Eligibility Allowable Costs / Cost Principles Significant Deficiency

Condition: The School District charged an expenditure to the grant which was incurred in a school building that was not an eligible school building under the award. Planned Corrective Action: Associate Accountant will ensure the Assistant Superintendent’s signature is on all invoices charged to fede...

Condition: The School District charged an expenditure to the grant which was incurred in a school building that was not an eligible school building under the award. Planned Corrective Action: Associate Accountant will ensure the Assistant Superintendent’s signature is on all invoices charged to federal grants including the Regional Assistance Grant. The Finance Director will ensure this during the invoice approval process. Finance Director and Assistant Superintendent meet monthly to discuss federal grants which includes the Regional Assistance Grant. Part of this meeting is to discuss known expenditures for federal grants so far this year to ensure they are properly coded and expended. Finance Director will run a general ledger analysis every two months to compare posted grant expenditures to approved grant budgets. Expenditures in question will be discussed at monthly meetings. Any determined to be incorrect will be moved to non-grant accounts via journal entry most likely prepared by Finance Director and approved by Associate Accountant. Contact person responsible for corrective action: RJ Wiersema and Jill Ansel Anticipated Completion Date: 12/31/2025

View Audit 376434

Finding 1165691 (2025-004)

Material Weakness 2025

Priority Trust Credit Union

TX

Reporting Significant Deficiency

Management agrees with the finding and will establish the recommended procedure outlined in the Schedule of Findings and Questioned Costs.

View Audit 376420

Finding 1165679 (2025-001)

Material Weakness 2025

Oakridge Public Schools

MI

Subrecipient Monitoring Reporting

Finding 2025-001: Education Stabilization Fund Special Reporting Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 84.425U and 84.425V Award numbers: COVID-19 213713 2122 and COVID-19 221037 2324 Award y...

Finding 2025-001: Education Stabilization Fund Special Reporting Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 84.425U and 84.425V Award numbers: COVID-19 213713 2122 and COVID-19 221037 2324 Award year end: September 30, 2024 Recommendation: The School District should create a process for gathering all requirements for special reporting under Uniform Guidance and the School District should prepare and submit the necessary special reports. Action taken: The Finance Director has created a process for gathering all requirements for special reporting under Uniform Guidance and for preparing and submitting the necessary special reports. Responsible Person and Anticipated Completion Date: Finance Director, January 2026. If the Michigan Department of Education has questions regarding this plan, please call Todd Hronek at (231) 788-7109.

View Audit 376383

Finding 1165677 (2025-002)

Material Weakness 2025

The School District of Kansas City, Missouri

MO

Subrecipient Monitoring Special Tests & Provisions Reporting

Identifying Number: 2025-002 Audit Finding: Per the U.S. Department of Agriculture at 7 CFR 226.16(d)(4) and the Missouri Department of Health and Human Services, sponsoring organizations must conduct three monitoring review visits for each of their facilities and no more than six months may lapse b...

Identifying Number: 2025-002 Audit Finding: Per the U.S. Department of Agriculture at 7 CFR 226.16(d)(4) and the Missouri Department of Health and Human Services, sponsoring organizations must conduct three monitoring review visits for each of their facilities and no more than six months may lapse between monitoring visits for CACFP compliance. At least two of the three reviews must be unannounced. If a violation occurs during the visit, the sponsor must follow up with the facilities noted as having problems, and the follow-up visit must be conducted no less than one week after the initial finding, and the visit must be documented. Kansas City Public Schools did not perform the required three site visits per year within a six-month timeframe for five of the samples, and the supporting documentation provided for all six samples did not contain the total of participants in attendance during the meal service and the total number of meals claimed during the five consecutive days. Corrective Actions Taken or Planned: The District agrees with the finding. The District will implement and strengthen the following internal controls to ensure that all three required visits are accurately documented using the DHSS Site Visit Report by June 30, 2026: a. Training: Child Nutrition Services (CNS) will review and provide training to all supervisors and department leaders on DHSS Sponsor Review requirements. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance b. SOP: CNS will utilize a central repository [CNSReporting@kcpublicschools.org] to streamline and time-stamp audit submissions. The original copy will be stored in a designated binder, and a digital copy will be retained in the CNS shared drive. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance c. Monitoring: C CNS leaders, as designated by the Officer of Nutrition & Compliance, will conduct Supper audits during SY 2025–2026 in September, December, and March. Snack audits will be conducted in November, February, and April. Additional audits will be scheduled as necessary to ensure compliance with program requirements. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance d. Reporting: As part of progress monitoring, at the end of each monitoring month, each applicable site will be reviewed to confirm completion & accuracy of a Sponsor Review. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance

View Audit 376372

Finding 1165676 (2025-003)

Material Weakness 2025

The School District of Kansas City, Missouri

MO

Allowable Costs / Cost Principles Reporting § 200.431

Identifying Number: 2005-003 Audit Finding: The District must demonstrate that costs incurred are allowable and internal controls are in place to record hours worked and required educational credentials for staffing levels. Hours per timesheet did not reconcile to hours per payroll system for servic...

Identifying Number: 2005-003 Audit Finding: The District must demonstrate that costs incurred are allowable and internal controls are in place to record hours worked and required educational credentials for staffing levels. Hours per timesheet did not reconcile to hours per payroll system for services rendered for four samples and one sample did not hold the required educator credentials for their staffing level. Corrective Actions Taken or Planned (Timesheets): The District agrees with the finding. The District will implement and strengthen the following internal controls to ensure that hours paid agree with time reported by June 30, 2026. a. Training – The District has fully implemented an electronic time keeping system for hourly employees. Training has been provided to all hourly staff, and supervisors responsible to review and approve time reported. Person responsible for implementation: Erin Thompson, Chief Finance Officer b. SOP: Business & Finance will continue training of employees and supervisors who review and approve time worked. Person responsible for implementation: Erin Thompson, Chief Finance Officer c. MonitoringLeadership will periodically meet with the Department Director to verify compliance. Person responsible for implementation: Dr. Latanya Franklin Chief Academic & Accountability Officer d. Reporting: On a district-wide basis, the Payroll Department will provide to management when adherence to procedures is not followed. Person responsible for implementation: Erin Thompson, Chief Finance Officer Corrective Actions Taken or Planned (Credentials): The District agrees with the funding. The District will implement and strengthen the following internal controls to ensure staff have the required educational credentials. a. SOP: Human Resources maintain a central repository documenting certification-related notifications Person responsible for implementation: Micah Enders, Executive Director Human Recourses b. Monitoring: On a quarterly basis, reviews will be conducted to track and update certification status. Person responsible for implementation: Micah Enders, Executive Director Human Recourses c. Reporting: As part of the quarterly monitoring, a quarterly compliance report will be submitted to management. Person responsible for implementation: Micah Enders, Executive Director Human Recourses

View Audit 376372

Finding 1165674 (2025-001)

Material Weakness 2025

County of Pittsylvania, Virginia

VA

Eligibility Reporting

Assign supervisors responsibility for ,specific program related timeliness and compliance reports to improve accountability and avoid duplicative monitoring. Require supervisors to conduct and document monthly review of assigned reports and take corrective action as needed. Upon filling the vacant m...

Assign supervisors responsibility for ,specific program related timeliness and compliance reports to improve accountability and avoid duplicative monitoring. Require supervisors to conduct and document monthly review of assigned reports and take corrective action as needed. Upon filling the vacant manager position, require agency-wide review of supervisory reports. Incorporate handson exposure to Medical Assistance screens in VACMS during SNAP processing for new staff. Reinforce expectations for simultaneous processing of SNAP and Medical Assistance combination cases.

View Audit 376358

Finding 1165672 (2025-001)

Material Weakness 2025

Marshall Public Schools

MO

Cash Management School Nutrition Programs

U.S. Department of Education Marshall Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Caleb Petet, Superintendent Marshall Public Schools Independent Public Accoun...

U.S. Department of Education Marshall Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Caleb Petet, Superintendent Marshall Public Schools Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended June 30, 2025 The findings from the June 30, 2025, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Significant Deficiency 2025-001 Child Nutrition Cluster Recommendation: We recommend that fund balances should be monitored to ensure that balances remain in line with child nutrition compliance requirements.

View Audit 376342

Corrective Action Plans

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