Corrective Action Plans

Finding 1191373 (2025-006)

Material Weakness 2025

OK

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

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds ar...

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is evaluating its current Title IV funds procedures and implementing additional procedures to ensure timely return of refunds. This includes assigning additional staff to manage this process. Also, relevant staff have been reminded of the need to notify Financial Aid of student withdrawals timely. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid Planned completion date for corrective action plan: March 2026

View Audit 395389

Finding 1191337 (2025-004)

Material Weakness 2025

Langston University

OK

Eligibility Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Student Financial Aid Cluster: TEACH Grant – Assistance Listing No. 84.379 Recommendation: We recommend the University review and update current procedures to ensure that students meet eligibility requirements prior to receiving the TEACH Grant. Explanation of disagreement with audit finding: There ...

Student Financial Aid Cluster: TEACH Grant – Assistance Listing No. 84.379 Recommendation: We recommend the University review and update current procedures to ensure that students meet eligibility requirements prior to receiving the TEACH Grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has updated procedures to ensure verification of student GPA prior to disbursement of TEACH Grant funding. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid and Ms. Courtney Youngblood, Assistant Director of Financial Aid Planned completion date for corrective action plan: September 2025

View Audit 395389

Finding 1191322 (2025-001)

Material Weakness 2025

Langston University

OK

Subrecipient Monitoring Cash Management Significant Deficiency § 200.303 § 200.305

Research and Development – Assistance Listing No. 10.215 Research and Development – Assistance Listing No. 93.433 Recommendation: We recommend that the University review and update policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to per...

Research and Development – Assistance Listing No. 10.215 Research and Development – Assistance Listing No. 93.433 Recommendation: We recommend that the University review and update policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2023 audit report in May 2024. The 2023 audit was completed after substantially all of Fiscal Year 2024 had elapsed, so there was not adequate time for the University to fully implement corrective action. While these corrective measures were implemented during Fiscal Year 2025, they did not fully resolve the issue. The University continues to strengthen its accounts payable processes and sign-off approvals to help ensure reimbursements to subrecipients are paid timely. Additional updates to procedures for payment processing are also being developed. Methods for more accurate tracking of invoice receipt dates are being developed to ensure the 30-day period begins on the correct day. Principal investigators and designated administrative personnel within academic departments will be reminded of the need to initiate payments to subrecipients timely. Accounts payable training has been held for such personnel and will persist. Name(s) of the contact person(s) responsible for corrective action: Ms. Andrea Sherwood, Assistant Director, Grants and Contracts Financial Administration at Oklahoma State University and Ms. Nykkia Harris, Controller for Fiscal and Administrative Affairs Planned completion date for corrective action plan: May 2026

View Audit 395389

Finding 1191228 (2025-001)

Material Weakness 2025

Brownsville Housing Authority

TN

HUD Housing Programs Special Tests & Provisions

Auditors’ Recommendation: The Authority should perform housing quality control re-inspections according to HUD guidelines. Grantee Response: We will comply with the auditors’ recommendation. Anticipated Completion Date: June 30, 2026 Views of responsible officials and planned corrective actions: We ...

Auditors’ Recommendation: The Authority should perform housing quality control re-inspections according to HUD guidelines. Grantee Response: We will comply with the auditors’ recommendation. Anticipated Completion Date: June 30, 2026 Views of responsible officials and planned corrective actions: We will comply with the auditors’ recommendations.

View Audit 395383

Finding 1191227 (2025-004)

Material Weakness 2025

Isd # 13 Columbia Heights

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties School Nutrition Programs § 200.318

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-004 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Findi...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION – CHILD NUTRITION CLUSTER (ALN 10.553, 10.555, AND 10.559) 2025-004 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary 2 CFR § 180 and 2 CFR § 200.318-327 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – Bryan Hennekens, Director of Finance and Operations. Planned Completion Date – June 30, 2026. Disagreement With or Explanation of Finding – The District is in agreement with this finding. Plan to Monitor – Bryan Hennekens, Director of Finance and Operations, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

View Audit 395377

Finding 1191224 (2025-003)

Material Weakness 2025

University of Pikeville

KY

Student Financial Aid Eligibility

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.165(a). Condition: During our eligibility testing, 10 of 38 students who received Direct Loans were...

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.165(a). Condition: During our eligibility testing, 10 of 38 students who received Direct Loans were not notified of their disbursements timely by the University. Cause: The University did not have controls in place to ensure students were being notified of Direct Loan disbursements in a timely manner (within 30 days before or 30 days after crediting the students' account). Effect: The provisions of 34 CFR 668.165(a) were not followed and thus a total of 10 students were not notified of Direct Loan disbursements in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University update their internal controls related to Direct Loan disbursements and send required communications prior to crediting the students' accounts. Corrective Actions Taken or Planned: We agree with this finding and recommendation. The financial aid office has automated the process to send disbursement notifications. Disbursement notifications are sent the day after loans are posted to a student’s account. Responsible Parties: Daniel Donner, Director of Financial Aid Completion Date: November 05, 2025

View Audit 395369

Finding 1191223 (2025-002)

Material Weakness 2025

University of Pikeville

KY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR 685.309(b). Condition: During our testing of 40 students for NSLDS enrollment, we noted eight...

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR 685.309(b). Condition: During our testing of 40 students for NSLDS enrollment, we noted eight students' enrollment effective date was the commencement date instead of the last day of the term. One student's graduation status was not reported to the NSLDS and one student's graduation was not certified to the NSLDS within the 60-day requirement. Cause: The University did not have controls in place to ensure students' classification were being properly reported to the NSLDS or reported in a timely manner. Effect: There were ten student status changes that were either not reported, not reported accurately, or not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus, students were subsequently not placed into loan repayment status in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the University implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to the NSLDS. In addition, we recommend that the University submit roster files on a regular basis. Corrective Actions Taken or Planned: We agree with this finding and recommendation. The Director of Institutional Research will report the last day of the term for NSLDS reporting. Responsible Parties: Margaret Sidle, Director of Institutional research Completion Date: March 4, 2026

View Audit 395369

Finding 1191222 (2025-001)

Material Weakness 2025

University of Pikeville

KY

Student Financial Aid Reporting

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.22(a). Condition: During our testing of six official withdrawals, we noted one instance where the U...

Federal Program: U.S. Department of Education Student Financial Assistance Cluster: Federal Direct Student Loans, Federal Assistance Listing 84.268 Criteria: The University must comply with 34 CFR 668.22(a). Condition: During our testing of six official withdrawals, we noted one instance where the University incorrectly treated a student as withdrawn for Return of Title IV (R2T4) purposes. The student was enrolled in both modules for the Fall term, earned six credit hours in the first module and subsequently withdrew during the second module. The University reported the student as withdrawn to the National Student Loan Data System (NSLDS) and performed a R2T4 calculation using the total days of both modules in the denominator of the R2T4 calculation. However, since the student successfully completed six credit hours in the first module, which exceeds the coursework required for the University's definition of half time enrollment, the student should not have been classified as withdrawn nor had a R2T4 calculation performed. Upon further analysis from management, there were an additional five students that were enrolled in modules, earning half-time enrollment, who were reported as withdrawn to the NSLDS and a R2T4 calculation was erroneously completed for them. Cause: This error occurred due to inadequate internal controls over identifying withdrawal status for students enrolled in module courses, specifically related to assessing whether completed coursework met or exceeded the half-time enrollment threshold prior to performing an R2T4 calculation or reporting them as withdrawn to the NSLDS. Effect: The provisions of 34 CFR 668.22(a) were not followed and thus a total of six students had a R2T4 calculation erroneously performed. Six students were also erroneously reported as withdrawn to the NSLDS. Questioned Costs: There were no questioned costs associated with this finding Recommendation: We recommend that the University strengthen its internal controls related to R2T4 calculations by: (a) implementing a system control to evaluate whether or not completed module coursework meets the half-time threshold before classifying a student as withdrawn, (b) providing additional training to financial aid staff on withdrawal determinations and performing an R2T4 calculation for students enrolled in modules, and (c) performing a supervisory review of all R2T4 calculations related to module students. Corrective Actions Taken or Planned: We agree with this finding and recommendation. After further review of R2T4 rules for module programs, the University of Pikeville will no longer perform R2T4’s on any student that has met the Exemption rules per FSA handbook, Vol 5, Chapter 1, “R2T4 Withdrawal Exemptions”. Responsible Parties: Daniel Donner, Director of Financial Aid Completion Date: March 4, 2026

View Audit 395369

Finding 1191221 (2025-001)

Material Weakness 2025

Housing Authority of Gilmer

TX

HUD Housing Programs Allowable Costs / Cost Principles

Corrective Action Plan - Public and Indian Housing - interfund receivable balance. Contact person: Alana Burnet, Executive Director, Housing Authority of Gilmer, 104 Circle Drive, Gilmer, TX 75644-0397, telephone number (903) 843-3141. Correction action planned: The PHA will have its Section 8 new c...

Corrective Action Plan - Public and Indian Housing - interfund receivable balance. Contact person: Alana Burnet, Executive Director, Housing Authority of Gilmer, 104 Circle Drive, Gilmer, TX 75644-0397, telephone number (903) 843-3141. Correction action planned: The PHA will have its Section 8 new construction program reimburse the Public and Indian Housing Program for the interfund balance and make sure any interfund activity is reimbursed on a monthly basis. Anticipated completion date: Immediately.

View Audit 395356

Finding 1191220 (2025-003)

Material Weakness 2025

Talladega College

AL

Procurement, Suspension & Debarment § 200.318

1. Finding Summary: The College entered into contracts with vendors without verifying their eligibility to receive federal funds. Testing of 50 procurement transactions identified that the College could not provide documentation that a suspension or debarment check had been performed via SAM.gov pri...

1. Finding Summary: The College entered into contracts with vendors without verifying their eligibility to receive federal funds. Testing of 50 procurement transactions identified that the College could not provide documentation that a suspension or debarment check had been performed via SAM.gov prior to the award for 13 contracts (exceeding the $25,000 threshold). Additionally, the contracts did not include a provision requiring the contractor to certify their eligibility. While the subsequent search of SAM.gov revealed that the vendors involved were not actually suspended or debarred, the College was in violation of federal compliance requirements. 2. Management’s Position – Management agrees with the finding. We are currently implementing a new procurement checklist that requires a printed copy of the SAM.gov search results to be attached to the purchase order packet. Staff training on federal procurement requirements will be required. 3. Corrective Action – Management will adhere to new procurement checklist that requires a printed copy of the SAM.gov search results to be attached to the purchase order packet. Management will consider whether certain contracts will require the contractor to certify their eligibility as part of the request for proposal or submission of a final contract. Staff training on federal procurement requirements will be required, with a target completion date prior to July 1, 2026. 4. Responsible Party – While the Office of Sponsored Research and Programs will be responsible for adherence to the policy and completing the checklist, the VP of Finance & Administration will monitor compliance of this process. Additionally, the VP of Finance & Administration will reinforce adherence of the new policy with personnel involved with any federal contracts, specifically ensuring that the executive cabinet members are aware as well as the Director of Sponsored Programs. 5. Implementation Timeline – Implementation effective July 1, 2026. 6. Status of Corrective Action (if related to prior year) – Corrective actions are in progress.

View Audit 395352

Finding 1191219 (2025-006)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management

Finding Reference 2025-06 Corrective Action Plan: To strengthen internal controls, improve monitoring, and reduce delays in the certification and payment process, the Authority will implement the following operational improvements: The Authority is using the Finance Office Dashboard to track the sta...

Finding Reference 2025-06 Corrective Action Plan: To strengthen internal controls, improve monitoring, and reduce delays in the certification and payment process, the Authority will implement the following operational improvements: The Authority is using the Finance Office Dashboard to track the status of certifications and invoices in real time, identify bottlenecks in the approval process, and support proactive management of pending payments. A standardized Construction Certification Compliance Checklist will be used to validate all required federal compliance documentation before certifications are submitted to the Finance Office. This measure is expected to reduce the number of returned submissions and prevent delays during the billing review process. The Authority will develop a Help Desk platform for certification and invoice inquiries to formally manage, document, and track inquiries or claims related to Construction Certifications and Pre- Construction invoices, improving transparency and response times. The Authority will launch the ICMM Payment Tracking Table to consolidate and monitor the payment status of certifications and invoices. Additionally, the Authority is establishing intermediate milestones to progressively reduce the payment processing cycle, with the objective of moving from the current 40-day average toward the 30-day target. As part of this initiative, the Authority is expanding the use of the Project Management Information System (PMIS) to standardize and streamline the processing of construction certifications and payment documentation. Responsible: Mr. Angel M. Felix Cruz, Acting Director, Confidential Finance Office Planned Implementation Date: In process. The first operational improvement has been implemented. The remaining three measures are pending implementation. Expected to be completed on or before June 30, 2026.

View Audit 395336

Finding 1191218 (2025-005)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding Reference 2025-05 Corrective Action Plan: The Authority implemented the following actions in March 2026 to ensure compliance with the Davis-Bacon Act and strengthen payroll certification process: On March 11, 2026, all personnel of the Construction Office receive adequate training on Davis-B...

Finding Reference 2025-05 Corrective Action Plan: The Authority implemented the following actions in March 2026 to ensure compliance with the Davis-Bacon Act and strengthen payroll certification process: On March 11, 2026, all personnel of the Construction Office receive adequate training on Davis-Bacon Act requirements and payroll certification processes. On March 20, 2026, the Authority prepared a formal communication to reinforce the compliance with the Davis Bacon Act and to provide updated forms and instructions for completing certification payroll process. On March 3, 2026, the Authority contracted external consultants to enhance monitoring procedures over contractors and subcontractors, including timeliness tracking of properly certified payroll on a weekly basis and follow-up on missing or incomplete documentation Responsible: Mr. Emilio Garay, PE, Construction Office Director Planned Implementation Date: In process. Expected to be completed on or before June 30, 2026.

View Audit 395336

Finding 1191217 (2025-004)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Subrecipient Monitoring § 200.303 § 200.332

Finding Reference 2025-04 Corrective Action Plan: The Authority will implement the following plan to perform this sub recipient monitoring within the required threeyear cycle established in its State Management Plan: 1. Scheduled On-site Monitoring Visit Scheduled for June 1 O, 2026 The visit will i...

Finding Reference 2025-04 Corrective Action Plan: The Authority will implement the following plan to perform this sub recipient monitoring within the required threeyear cycle established in its State Management Plan: 1. Scheduled On-site Monitoring Visit Scheduled for June 1 O, 2026 The visit will include programmatic, financial, and compliance reviews in accordance with FTA requirements and 2 CFR 200 2. Pre-visit Desk Review A comprehensive desk review will be conducted prior to the visit, including financial reports, subrecipient agreements, audit reports, and prior monitoring documentation 3. Standardized Monitoring Procedures ' The Authority will use an Oversight Review Checklist to ensure consistency, compliance, and proper documentation. 4. Monitoring Report Issuance A monitoring letter will be issued within 30 days of the visit, detailing findings, concerns, and required corrective actions, if applicable. 5, Follow-up and Resolution The Subrecipient will be required to submit a CAP, if findings are identified. The Authority will conduct follow-up procedures until full resolution is achieved. Preventive Measures The Authority will implement the following measures to prevent recurrence of this finding: Establish and maintain a risk-based Oversight Visit Schedule Ensure inclusion of: Subrecipients receiving reimbursement-based funding Subrecipients identified as high-risk based on financial, operational, or compliance factors Strengthen internal controls to ensure adherence to monitoring cycles Maintain centralized and complete documentation of all monitoring activities Responsible: Ora. Norma L. Garcf a Lebron, Management Officer, Federal Coordination Office Luis F. Colon Morales, Director, Federal Coordination Office Planned Implementation Date: In process. Expected to be completed on or before July 31, 2026.

View Audit 395336

Finding 1191216 (2025-003)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Internal Control / Segregation of Duties Subrecipient Monitoring

Finding Reference 2025-03 Corrective Action Plan: The Authority has assigned an Analyst and a Supervisor the responsibility of monitoring compliance with all federal requirements related to the reporting process of these funds. In addition, an adequate training will be provided to the personnel invo...

Finding Reference 2025-03 Corrective Action Plan: The Authority has assigned an Analyst and a Supervisor the responsibility of monitoring compliance with all federal requirements related to the reporting process of these funds. In addition, an adequate training will be provided to the personnel involved in the administration of this program. The Authority has also implemented the following procedure to ensure accurate financial reporting and supervision: The Analyst will prepare the reports in accordance with the work plan and submit them to the Supervisor for review and approval. The Supervisor will review the reports and will send an email confirming the approval. Once approved, the Analyst will send the reports to the pass though entity. Responsible: Mrs. Johanna Perez Falcon, Acting Director of the Office of Budget Planned Implementation Date: Completed.

View Audit 395336

Finding 1191215 (2025-002)

Material Weakness 2025

Puerto Rico Highways and Transportation Authority

PR

Reporting Internal Control / Segregation of Duties § 200.510

Finding Reference 2025-02 Corrective Action Plan: The Designated Office responsible for processing federal funds received through state agencies will deliver to the Finance Office a transaction list and a reconciliation of the disbursements made during the fiscal year. The Finance Office will review...

Finding Reference 2025-02 Corrective Action Plan: The Designated Office responsible for processing federal funds received through state agencies will deliver to the Finance Office a transaction list and a reconciliation of the disbursements made during the fiscal year. The Finance Office will review all transactions recorded during the current fiscal year and will prepare an accrual entry. These transactions will be reconciled against the transactions recorded during the subsequent fiscal year to confirm that funds were recorded in the appropriate fiscal period. The review and recording of these transactions will be completed during the final phase of the accounting closing process and prior to delivery of the Trial Balance to the external auditors. Responsible: Ms. Maria Del R. Ramos Ocasio, Accounting and Finance Manager Planned Implementation Date: In process. Expected to be completed on or before September 30, 2026.

View Audit 395336

Finding 1191214 (2025-003)

Material Weakness 2025

Concordia University Chicago

IL

Student Financial Aid Significant Deficiency § 200.303

2025-003 Documentation of Review Recommendation: We recommend the University re-evaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to ...

2025-003 Documentation of Review Recommendation: We recommend the University re-evaluate its procedures and review policies surrounding controls implemented for Title IV Aid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The Office of Financial Aid will re-evaluate its current policies and procedures to clearly define internal control objectives and strengthen overall compliance. 2) The Office of Financial Aid has implemented – and will continue to maintain - a dual-review process (second-level review) for Return of Title IV Funds, federal award packaging, and the review of the FISAP report to ensure accuracy and regulatory compliance. 3) The Director and Assistant Director of Financial Aid will continue cross-training staff to promote operational continuity, reinforce internal controls, and maintain clear oversight of key processes. Name(s) of the contact person(s) responsible for corrective action: Vanesa Teran-Martinez, Jennifer Monroy Planned completion date for corrective action plan: June 30, 2026 If the Department of Education has questions regarding this schedule, please call Vanesa Teran-Martinez at 708-209-3338.

View Audit 395330

Finding 1191208 (2025-002)

Material Weakness 2025

Concordia University Chicago

IL

Student Financial Aid Reporting Significant Deficiency

2025-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with au...

2025-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review and strengthen its reporting procedures to ensure that student statuses are accurately reported to NSLDS, as required by federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) All enrollment reporting was submitted to the National Student Clearinghouse in a timely manner. The delay occurred during the National Student Clearinghouse’s processing and submission to NSLDS. 2) The Office of the Registrar will work with the Office of Financial Aid to learn more about NSLDS compliance requirements and gain a better understanding of their relationship with the National Student Clearinghouse. 3) The Office of the Registrar will work with the National Student Clearinghouse to confirm the submitted reporting schedule for academic year 2026 – 2027 complies with and meets their expectations and will adjust (if needed). 4) The Office of the Registrar will continue to work with the Enrollment Offices to remind them that students who are not enrolled (and not on leave of absence, graduated, and/or deceased) must be marked as withdrawn based on external reporting compliance requirements. 5) The Office of the Registrar continues to work with IT (Banner Team) to improve reporting to capture students who are not enrolled (and not on leave of absence, graduated, and/or deceased) to be marked as withdrawn to comply with the National Student Clearinghouse and NSLDS compliance reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Ingrid Sorensen, Katarzyna Rodriguez Planned completion date for corrective action plan: June 30, 2026

View Audit 395330

Finding 1191202 (2025-001)

Material Weakness 2025

Concordia University Chicago

IL

Student Financial Aid Eligibility Significant Deficiency

2025-001 Pell Grant Under Award Recommendation: We recommend the University implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit ...

2025-001 Pell Grant Under Award Recommendation: We recommend the University implement a review process that compares enrolled credits to Pell awards to ensure all students receive the correct Pell Grant amounts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The Office of Financial Aid will continue to run monthly or bi-monthly enrollment reports for Pell Grant recipients to ensure awards are accurately determined based on enrollment status. 2) Financial Aid Counselors will continue to review the daily and weekly Hour Change Reports for each payment period to ensure Pell Grant awards are adjusted appropriately in response to enrollment status changes. 3) The Director and Assistant Director of Financial Aid will continue providing Banner (student information system) training to staff to ensure Pell Grant amounts are updated accurately within the system. Name(s) of the contact person(s) responsible for corrective action: Vanesa Teran-Martinez, Jennifer Monroy Planned completion date for corrective action plan: June 30, 2026

View Audit 395330

Finding 1191200 (2025-002)

Material Weakness 2025

South Suburban College - Community College District #510

IL

Special Tests & Provisions Student Financial Aid Matching / Level of Effort / Earmarking

Finding: 2025-002 – Controls and Noncompliance Over Special Tests and Provisions: Return of Funds Management’s Response South Suburban College acknowledges this finding and has implemented corrective actions to strengthen compliance with established policies and procedures. These actions will ensure...

Finding: 2025-002 – Controls and Noncompliance Over Special Tests and Provisions: Return of Funds Management’s Response South Suburban College acknowledges this finding and has implemented corrective actions to strengthen compliance with established policies and procedures. These actions will ensure that Return of Title IV (R2T4) calculations are performed accurately, using correct term dates, and completed within required timeframes. Action Plan 1. Training The Director of Financial Aid will provide formal training to the Financial Aid Manager on federal Return of Title IV Funds (R2T4) calculation procedures, including the use of accurate term dates. Training of additional personnel will support the internal review process. 2. Control Process South Suburban College has established and will reinforce internal control processes to ensure compliance with federal Return of Title IV (R2T4) requirements. All Return of Title IV Funds R2T4 calculations prepared by the Financial Aid Director or Manager will have second review prior to final submission. This review process will ensure accuracy, timeliness, and compliance with Title IV regulations. Anticipated Date of Completion Note the audit found the error to be remedied as of Spring 2025 and the college continue its efforts. The additional actions noted above demonstrate South Suburban College’s commitment to ensuring Return of Title IV (R2T4) calculations are performed accurately and completed within required timeframes. Name of Contact Person: Yolanda Freemon Director of Financial Aid yfreemon@ssc.edu ext.5845

View Audit 395329

Finding 1191196 (2025-001)

Material Weakness 2025

South Suburban College - Community College District #510

IL

Student Financial Aid Reporting

Finding 2025-001: Controls and Noncompliance Over Reporting - Pell Common Origination and Disbursement; Fiscal Operations Report and Application to Participate Management's Response: The College acknowledges this finding and has implemented the corrective actions outlined below to reinforce establis...

Finding 2025-001: Controls and Noncompliance Over Reporting - Pell Common Origination and Disbursement; Fiscal Operations Report and Application to Participate Management's Response: The College acknowledges this finding and has implemented the corrective actions outlined below to reinforce established policies and procedures. This will ensure the institution submits disbursement information to the Department of Education’s Common Origination and Disbursement (COD) site within the required 15-day timeframe. Corrective Action Plan: 1. Control Process South Suburban College has established an internal control process to ensure that all records are submitted in a timely manner. The Financial Aid Director and Manager now have access to be promptly notified of updates the Colleague software system. Notifications were previously accessible only to the IT Department. 2. System Upgrade South Suburban College is in the process of transitioning to new software by March 2026. Once the new software is in place, the South Suburban College ‘s IT department may no longer need to update the Colleague system to support the submission of Pell Grant disbursements. The transition to the new system is expected to streamline the process and improve reporting accuracy with automated reminders, updated calendars and other notification mechanisms in the College’s Colleague system to compliment manual. 3. Ongoing Monitoring and Training Regular system audits will continue to be conducted to ensure that personnel are well-informed and that policies are consistently followed. The retaining of documentation to support amounts within the FISAP has been implemented. The Financial Aid Department will also continue to monitor the COD site for compliance and address any discrepancies promptly. Anticipated Date of Completion Note the audit found the error to be remedied as of Spring 2025. However, with these corrective actions, South Suburban College is committed to ensuring that Pell Grant disbursements are reported accurately and submitted in compliance with federal regulations within the specified 15-day window. Name of Contact Person: Yolanda Freemon Director of Financial Aid yfreemon@ssc.edu ext.5845

View Audit 395329

Finding 1191192 (2025-003)

Material Weakness 2025

Unified School District No. 321

KS

Reporting § 200.502

2025-003 Prparation of and internal controls over SEFA preparation (Material Weakness). Federal Agency: U.S. Department of Education. Program Name: Child Nutrition Cluster; Education Stabilization Fund. Assisstance Listing Number: 10.553,10.555, 10.559; 84.425. Award Period: June 30, 2025. RECOMMEND...

2025-003 Prparation of and internal controls over SEFA preparation (Material Weakness). Federal Agency: U.S. Department of Education. Program Name: Child Nutrition Cluster; Education Stabilization Fund. Assisstance Listing Number: 10.553,10.555, 10.559; 84.425. Award Period: June 30, 2025. RECOMMENDATION: The Board of Education and managment shoudl review the financial reporting process. Once this review is cimplete, the District should then perform a risk assessment to determine the best way to implement appropriate intnernal controls over financial reporting to ensure that the District prepares the schedule in conformity with Uniform Guidance. Action Taken (unauditied): managment plans to have the Board Clerk and the Board Treasurer complete the Schedule of Expenditures together and to ensure that the correct expenses are being reported.

View Audit 395323

Finding 1191188 (2025-002)

Material Weakness 2025

MARY'S PLACE SEATTLE

WA

Procurement, Suspension & Debarment

Significant Deficiency in Internal Control Over Compliance – Suspension and Debarment Contact Persons: Chief Financial Officer – Robert te Winkel, rtewinkel@marysplaceseattle.org Controller – Dzhennet Bird dbird@marysplaceseattle.org Senior Accountant - Robin Sing vsing@marysplaceseattle.org Correct...

Significant Deficiency in Internal Control Over Compliance – Suspension and Debarment Contact Persons: Chief Financial Officer – Robert te Winkel, rtewinkel@marysplaceseattle.org Controller – Dzhennet Bird dbird@marysplaceseattle.org Senior Accountant - Robin Sing vsing@marysplaceseattle.org Corrective Action Plan: Management concurs with the finding. Mary’s Place has strengthened its suspension and debarment compliance procedures consistent with 2 CFR Part 180 and Uniform Guidance requirements. The enhanced controls are now embedded in procurement activities, with final documentation alignment concluding by February 28, 2026. 1. Mandatory Pre-Award SAM.gov Verification (Preventive Control) For all covered federal transactions, the Controller (or designated finance staff) performs and documents a SAM.gov verification prior to contract execution and prior to release of the initial payment. Verification is completed at the time the vendor is selected and before signature of any federally funded contract. Documentation includes a date-stamped screenshot retained in the vendor file. 2. Executive-Level Review Prior to Execution (Oversight Control) As part of the accounts payable process, the CFO reviews procurement documentation for federally funded contracts prior to the first payment to confirm that SAM.gov verification was completed and properly documented. No payment is released without evidence of verification on file. This creates a secondary compliance checkpoint independent of the initial verification. 3. Documentation Retention and Ongoing Monitoring On a quarterly basis, CFO performs a spot check of federally funded contracts executed during the period to confirm: • SAM.gov verification occurred prior to execution • Documentation is complete and retained • No payments were issued prior to verification Any exceptions are documented and addressed promptly. Anticipated Completion Date: February 28, 2026 (final documentation alignment and full operational rollout; ongoing monitoring thereafter).

View Audit 395320

Finding 1191187 (2025-004)

Material Weakness 2025

Eastern Michigan University

MI

Reporting

Condition: Federal programs must be grouped into clusters only when specifically designated by the Office of Management and Budget (OMB). Planned Corrective Action: Additional review procedures have been implemented to prevent SEFA classification errors. Specifically, the Sponsored Research Accounti...

Condition: Federal programs must be grouped into clusters only when specifically designated by the Office of Management and Budget (OMB). Planned Corrective Action: Additional review procedures have been implemented to prevent SEFA classification errors. Specifically, the Sponsored Research Accounting Manager now conducts a detailed review of the award documentation prior to SEFA categorization. Furthermore, a verification step has been added to the grant set-up checklist, performed by Sponsored Research Accounting staff, to ensure accurate classification of all awards prior to inclusion in SEFA reporting. Contact person responsible for corrective action: Joel Clendenin, Grants Manager Anticipated Completion Date: 6/30/2026

View Audit 395317

Finding 1191185 (2025-003)

Material Weakness 2025

Eastern Michigan University

MI

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.332

Condition: The University could not provide evidence of conducting a formal risk assessment of subrecipients, nor was there documentation showing that the subrecipient’s SAM.gov registration was reviewed or it's most recent Single Audit report. Additionally, the University did not document ongoing m...

Condition: The University could not provide evidence of conducting a formal risk assessment of subrecipients, nor was there documentation showing that the subrecipient’s SAM.gov registration was reviewed or it's most recent Single Audit report. Additionally, the University did not document ongoing monitoring procedures or retain records. The University relied on information self-reported by the subrecipient without independently validating or documenting the required monitoring steps. Planned Corrective Action: At the subrecipient proposal development stage, the University currently requires subrecipients to certify in writing that they are not excluded or disqualified from receiving Federal Funds. However, to strengthen verification controls over subrecipient eligibility, the University Purchasing Department will add debarment reviews for subrecipients at the time a purchase requisition is initiated. Contact person responsible for corrective action: Joel Clendenin, Grants Manager Anticipated Completion Date: 6/30/2026

View Audit 395317

Finding 1191177 (2025-002)

Material Weakness 2025

Eastern Michigan University

MI

Procurement, Suspension & Debarment § 200.318

Condition: The University did not follow the written procurement procedures in place. Planned Corrective Action: It was noted that certain purchase orders and requisitions were processed after services had already been performed. To address this issue, procurement training will now be required for c...

Condition: The University did not follow the written procurement procedures in place. Planned Corrective Action: It was noted that certain purchase orders and requisitions were processed after services had already been performed. To address this issue, procurement training will now be required for certain faculty and staff, emphasizing that requisitions and purchase orders must be submitted and approved prior to the initiation of any services, to ensure adherence to the University’s documented competitive bid process. The University Purchasing Department currently provides monthly procurement policy training. In the new award setup phase, the Office of Research Development and Administration will require that a Principal Investigator (PIs) with awards with direct costs greater than the University bid limit attend such training within three months of award date. PIs with multiple awards will only be required to attend such training every 24 months. Additionally, Sponsored Research Accounting will follow up with PIs on all awards opened within the first three months to confirm adherence to University purchasing policies. Continued non-compliance may result in corrective actions for the applicable Principal Investigator/award team, including, but not limited to, loss of eligibility to submit future proposals, suspension of existing funding, or the requirement to use indirect cost (IDC) funds to cover any unallowable expenses. Contact person responsible for corrective action: Joel Clendenin, Grants Manager Anticipated Completion Date: 6/30/2026

View Audit 395317

Corrective Action Plans

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