Corrective Action Plans

Finding 547298 (2024-002)

Material Weakness 2024

Rising Sun - Ohio County Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description...

FINDING 2024-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When the criteria for the reporting is changed forcing us to change our answers, we will keep better notes of what we changed, and why we changed it. Our final numbers were correct, and we spent the money out of the correct categories. Jennifer Mossburger, Title I coordinator, and I worked together on this reporting. We will continue to work together on the reporting for the federal grants. However, we will do a better job of documenting our work. Anticipated Completion Date: 3/3/2025

View Audit 351598

Finding 547291 (2024-004)

Material Weakness 2024

Rising Sun - Ohio County Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2024-004 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the findi...

FINDING 2024-004 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We had never been instructed to do price quotes for items purchased from the HPS Purchasing Co-Op before. In the future, we will obtain price quotes when purchasing from HPS when purchases are above the micro-purchasing threshold. Or we will find a different purchasing avenue and will not use HPS. The cafeteria director is currently discussing this with each of the cafeteria supervisors to decide which avenue they will use to avoid the finding in the future. Going forward, for any vendor expected to equal or exceed $25,000 that is paid from school lunch funds (or any federal funds for that matter), someone at the school corporation will verify those vendors aren’t suspended or debarred. Anticipated Completion Date: 08/01/2025: The next school year.

View Audit 351598

Finding 547290 (2024-003)

Material Weakness 2024

Rising Sun - Ohio County Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2024-003 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective...

FINDING 2024-003 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Cafeteria Supervisor will have another employee spot-check 5 free and reduced applications per month. The other employee will review documentation of the review of the income guidelines updated in the system every year. Anticipated Completion Date: 3/3/2025

View Audit 351598

Finding 547287 (2024-001)

Material Weakness 2024

Wilton Community School District

IA

We have reviewed procedures and plan to make the necessary changes to improve internal control.

View Audit 351593

Finding 547286 (2024-008)

None 2024

State of South Dakota

SD

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

Finding No. 2024-008: Unallowable cost reimbursement under the Highway Planning and Construction Program Corrective Action Plan: Internal Controls will be strengthened to ensure accurate review of vouchers and construction pay estimates. Accountant II corrected the expense and the draw in August 202...

Finding No. 2024-008: Unallowable cost reimbursement under the Highway Planning and Construction Program Corrective Action Plan: Internal Controls will be strengthened to ensure accurate review of vouchers and construction pay estimates. Accountant II corrected the expense and the draw in August 2024. It is important to note that this would have been identified at the close of the project as the Department has a process in place to verify all amounts out of CM&P against the states accounting system. It is at that time the correction would have occurred. Contact Person: Patricia Devitt, Accounting Manager II Anticipated Completion Date: Fiscal year 2025

View Audit 351592 Questioned Costs: $1

Finding 547285 (2024-007)

Significant Deficiency 2024

State of South Dakota

SD

Subrecipient Monitoring § 200.332 § 200.501 § 200.521

Finding No. 2024-007: Inadequate Internal Controls over Monitoring of Subrecipient Audits The following are the actions that have been taken to come into compliance with monitoring subrecipient audits: • Office of Emergency Management’s, Recovery Branch Chief has reviewed the outstanding audit fin...

Finding No. 2024-007: Inadequate Internal Controls over Monitoring of Subrecipient Audits The following are the actions that have been taken to come into compliance with monitoring subrecipient audits: • Office of Emergency Management’s, Recovery Branch Chief has reviewed the outstanding audit finding and issued the management letter resolving the issue on March 12, 2025. • The Assistant Finance Officer reviewed FAC.gov for outstanding subrecipient audits in February of 2025. At this time, we discovered the two audits in question were not received through the Department of Legislative Audit (DLA). We have updated our process to review the subrecipient audit report tracking spreadsheet at least semi-annually, which will also include a review of FAC.gov to locate audit reports not submitted to DLA so that we can manage the timeliness of our review process and issue management letters, if required, within the 180-day period. • The Director of Administrative Services approved the updated process on March 14, 2025. Contact Person: Angie Lemieux, Director of Administrative Services Anticipated Completion Date: Issued management letter resolving the issue on March 12, 2025

View Audit 351592

Finding 547281 (2024-006)

Significant Deficiency 2024

State of South Dakota

SD

Internal Control / Segregation of Duties Special Tests & Provisions Significant Deficiency

Finding No. 2024-006: Inadequate Internal Controls over Special Tests and Provisions Corrective Action Plan: The Department of Social Services remains committed to a process of regularly updating internal controls across its divisions. The federal oversight requirement of having to pass system sec...

Finding No. 2024-006: Inadequate Internal Controls over Special Tests and Provisions Corrective Action Plan: The Department of Social Services remains committed to a process of regularly updating internal controls across its divisions. The federal oversight requirement of having to pass system security audits has been documented in the department's risk and control matrix. These risks will be evaluated annually, and control owners will attest to their review of both periodic, such as in this instance, and ongoing control activities twice per year. Department leadership will use the attestations to monitor compliance and verify the completion of such activities. Contact Person: Jason Simmons, Chief Financial Officer, Department of Social Services Anticipated Completion Date: The required biennial ADP risk analysis and system security review is in progress and will be completed by June 30, 2025.

View Audit 351592

Finding 547279 (2024-005)

Material Weakness 2024

State of South Dakota

SD

Questioned Costs Material Weakness Matching / Level of Effort / Earmarking

Finding No. 2024-005: Inadequate controls over the payment of claims. Corrective Action Plan: The Department of Social Services is committed to improving internal controls within the division of Child Protection Services (CPS). Over the past year, the division has made enhancements to the FACIS sy...

Finding No. 2024-005: Inadequate controls over the payment of claims. Corrective Action Plan: The Department of Social Services is committed to improving internal controls within the division of Child Protection Services (CPS). Over the past year, the division has made enhancements to the FACIS system that achieve segregation in duties during the prior authorization and claims entry processes. These enhancements include the creation of an audit trail for authorizations and claims in FACIS . The FACIS system will also be updated to restrict claim submissions so as to disallow exceeding the amount authorized by policy. This measure is meant to prevent the disbursement of payments that exceed amounts authorized by policy and/or the supervisor. Design of additional enhancements surrounding CPS's use of the CP-522 forms and inclusion of necessary supporting documentation will also be implemented in this current fiscal year. This enhancement will have the effect of requiring all payments issued from FACIS to include the same level of documentation as is required for the state's accounting system. Included with the soon-to-be added documentation requirement will also be a process requirement that applies to billing requirements from vendors that invoice the division regularly. This change applies to regular services providers that send itemized receipts that will accompany the CP-522 forms. Contact Person: Jason Simmons, Chief Financial Officer, Department of Social Services Anticipated Completion Date: In the fiscal year 2025, discussions and policy updates with CPS and Finance continued. The anticipated completion date for the corrective action plan is set for June 30, 2025.

View Audit 351592 Questioned Costs: $1

Finding 547277 (2024-012)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Corrective Action Plan: The University experienced changes with the Student Support Services program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation and reporting methods weren’t available due to the transit...

Corrective Action Plan: The University experienced changes with the Student Support Services program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation and reporting methods weren’t available due to the transition of key program personnel. Information that appears to be inaccurate serves as a combination of the inability to make revisions for previously reported students and human error. The CMC principal investigator for CMC was a first-time awardee, who was not fully acclimated to the grant reporting process prior to submitting the report. The Student Support Services program is committed to implementing continuous monitoring of program records to ensure compliance with federal, institutional, and program requirements. The program will review the existing program operating procedures and processes to align with requirements. Program personnel will engage in professional development opportunities and training to improve grant management. Currently, financial reporting is reviewed by individuals in both the Business Office and GSPAR. GSPAR will enhance its internal controls, policies, and procedures to ensure that all reporting is submitted with accurate information. GSPAR intends to create a centralized location to track and store all supporting documentation for easy access and review. GSPAR also intends to require that all financial information required by government agencies be reviewed by officials in both the Business and GSPAR Offices. In addition, GSPAR will implement a process for continuous monitoring of program records to ensure compliance with federal, Institutional and program requirements. The program staff will also engage in professional development opportunities to improve grant management and regulatory compliance. Anticipated Completion Date: December 31, 2025

View Audit 351580

Finding 547275 (2024-011)

Material Weakness 2024

Johnson C. Smith University

NC

Procurement, Suspension & Debarment

Corrective Action Plan: The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. During 2024 GSPAR revised...

Corrective Action Plan: The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. During 2024 GSPAR revised the grant onboarding process to emphasize key federal regulations and emphasize the importance of compliance. Reminders were provided during GSPAR’s semi-annual grant compliance workshops, as well as campus faculty and staff compliance training. While there was improvement the issues were not fully remediated by June 30, 2024. During July 2024 the University deployed a sole source justification form for technology purchases. The form will be revised to cover all applicable federal purchases and will require the signature of the principal investigators as well as a representative from GSPAR. The approved form will be added to the purchases record in Colleague. In addition, the University has modified its new vendor process to require the vendor complete a Disbarment and Suspension Certificate Form, which provides the vendor’s name as well as the principles. Before the vendor is created, a search will be done on the federal website to confirm the vendors status. A screenshot of the results will be saved as part of the vendor record. The University’s implemented Colleague effective July 2024, which allows the complete purchasing records to be attached to the requisition. Training was provided to the campus to ensure compliance with the new purchasing requirements. Anticipated Completion Date: December 31, 2025

View Audit 351580

Finding 547272 (2024-010)

Significant Deficiency 2024

Johnson C. Smith University

NC

Equipment & Real Property Management

Corrective Action Plan: Government Sponsored Programs and Research (“GSPAR”) implemented a process for recording and inventorying federal purchases during the Spring of 2024, however, the information did not capture all the required information. While there was improvement the issues were not fully ...

Corrective Action Plan: Government Sponsored Programs and Research (“GSPAR”) implemented a process for recording and inventorying federal purchases during the Spring of 2024, however, the information did not capture all the required information. While there was improvement the issues were not fully remediated by June 30, 2024. GSPAR will update its inventory tracking process to capture required information. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. GSPAR will improve its internal controls, policies, and procedures to mandate a physical inventory count at a minimum of once every two years. This ensures accurate tracking and accountability of assets. Additionally, we plan to revise our current inventory form to incorporate all data points required by our governing governmental agency. GSPAR will review and rectify existing records for equipment acquisitions made within the past two years. Anticipated Completion Date: December 31, 2025

View Audit 351580

Finding 547270 (2024-009)

Significant Deficiency 2024

Johnson C. Smith University

NC

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Corrective Action Plan: The Student Support Services program experienced changes in program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation wasn’t available due to the transition of key program personnel. Du...

Corrective Action Plan: The Student Support Services program experienced changes in program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation wasn’t available due to the transition of key program personnel. During the transition for Student Support Service, we encountered difficulty locating explicit documentation for students who were awarded Grant Aid outside of first- or second-year classification. Section 3518(a) of the CARES Act granted the Department authority to “modify the required and allowable uses of funds” for certain programs authorized by the Higher Education Act of 1965, which included TRIO programs. The flexible extension remained in effect until September 30, 2024. Upward Bound requested a flexibility extension under the CARES Act. Due to a delayed response to the request, the extension request was re-sent for verification. Once received, UB was advised that the Department was no longer accepting new requests. As a result, stipends were processed before receiving the final response. During the Spring of 2024 the University began work to enhance its internal controls, policies and procedures to ensure the appropriate documentation was properly maintained. While there was improvement across all TRIO programs, the issues were not fully remediated by June 30, 2024. The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained. Both the Student Support Services and Upward Bound programs are committed to implementing continuous monitoring of program records to ensure compliance with federal, institutional, and program requirements. The TRIO-SSS program has implemented an online Grant Aid application process for all participants who are eligible for aid; which requires submission of demographic information and a need for support statement. With the expiration of exceptions allowed under the CARES Act, all TRIO programs have converted back to distributing stipends in accordance with current federal regulations. Each program will monitor their respective distributions for accuracy and program compliance. Supporting documentation of statutory and regulatory requirements will be retained in the Policy and Procedures manuals. Anticipated Completion Date: June 30, 2025

View Audit 351580 Questioned Costs: $1

Finding 547264 (2024-008)

Material Weakness 2024

Johnson C. Smith University

NC

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Corrective Action Plan: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs over the last few fiscal years. The changes in staffing lead to a loss of institutional knowledg...

Corrective Action Plan: The University experienced turnover of key positions throughout campus, particularly in the Division of Finance, Government Sponsored Programs and various federally funds programs over the last few fiscal years. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide. During the Spring of 2024 the University began work to enhance its internal controls, policies, and procedures to ensure the appropriate documentation to support expenditures was properly maintained, and to ensure that level of effort reporting appropriately documented and timely completed. While there were some improvements (i.e., level of effort reporting), issues were not fully remediated. The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies, and procedures to ensure the appropriate documentation to support is maintained, and to ensure that level of effort is appropriately documented and reported. The level of effort reporting process has been modified to a consistent reporting for all campus awards. Level of Effort reports are done by academic term, and the reports are due within 30 days following the end of the term. The Office of Government Sponsored Programs (“GSPAR”) has implemented monitoring and tracking measures to all reports are captured and completed according to federal guidelines. A system of multiple reviews has been implemented to help in reducing errors in reporting and increase efficiency in timeliness of the reports. Additionally, GSPAR intend to work closely with the JCSU Human Resources department to ensure accurate and efficient Time and Effort reporting. In addition, the University mandated participation in compliance training for all faculty and staff; participants are required to submit an acknowledgement that they participated in the training and are aware of the compliance requirement. Specific to the TRIO programs, as the result of a re-organization in February 2025 the University created a new position: Assistant Vice President (AVP) for Student Affairs, TRIO, and Well-being. This role will oversee Time and Effort Reporting, Annual Performance Report submissions, and financial transactions, ensuring accuracy and adherence to all relevant policies, regulations, and procedures. Additionally, this position will support professional development initiatives to enhance grant management and compliance. The AVP will also support university efforts to conduct regular program reviews to ensure proper documentation supporting TRIO eligibility and adherence to program requirements. To improve program knowledge and standardize practices, TRIO personnel will continue engaging in professional development offered locally and nationally. Internally, the TRIO Leadership Team (TRIO Project Directors and SVP of Student Enrollment & Retention Management) established TRIO Professional Development Day, a two-day training designed specifically for JCSU TRIO staff. These sessions provide guidance on university policies, financial compliance, Time and Effort reporting, effective record-keeping, and data management. The event also includes a roundtable discussion to promote collaboration and shared learning across programs. In addition, the TRIO Leadership Team will continue to explore best practices from high-functioning TRIO programs. To enhance communication and strengthen internal controls, the TRIO Leadership Team implemented monthly TRIO Program meetings. These meetings, involving TRIO Project Directors and the Senior Vice President of Strategic Enrollment and Retention Management, facilitate discussions on compliance, streamline processes, and support policy development. Additionally, the TRIO Leadership Team established monthly interdepartmental meetings among TRIO programs, the Division of Government Sponsored Programs and Research, and the Division of Business and Finance to further ensure alignment with institutional and federal requirements. Human Resources will also participate in future meetings to review Time and Effort Reporting procedures. TRIO Project Directors maintain ongoing communication with the Department of Education Program Officer, seeking written guidance on allowable costs, staffing adjustments, and fund reallocations, when necessary. Continuous monitoring and evaluation will ensure the effectiveness of these corrective actions, allowing the university to identify areas for ongoing improvement and maintain full compliance with all regulatory requirements. Anticipated Completion Date: December 31, 2025

View Audit 351580 Questioned Costs: $1

Finding 547261 (2024-007)

Significant Deficiency 2024

Johnson C. Smith University

NC

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Corrective Action Plan: We acknowledge the accuracy of this finding, such that one student’s required return of funds was identified as having been improperly calculated during the R2T4 calculation. The order in which the funds were reduced and returned to the Department was incorrect. Lack of clari...

Corrective Action Plan: We acknowledge the accuracy of this finding, such that one student’s required return of funds was identified as having been improperly calculated during the R2T4 calculation. The order in which the funds were reduced and returned to the Department was incorrect. Lack of clarity about the enrollment level and activity of the student during the term caused the miscalculated award amounts. A lack of system driven calculation and insufficient knowledge of the proper order of funds (and required student authorization of post-withdrawal disbursement) were also contributing factors that resulted in this finding. The University underwent a re-organization the resulted in the creation of a new division, Strategic Enrollment and Retention Management (“SERM”), effective February 2025. The recent organizational restructuring that placed the Registrar’s Office and the Office of Financial Aid under the new division of Strategic Enrollment and Retention Management is a strategic move to enhance the synchronization of essential data between these departments. This alignment is crucial for accurately determining withdrawal dates and understanding the academic calendar, which are essential components of the R2T4 calculation process. Enhanced inter-departmental communication facilitated by this structure will ensure more accurate and timely data sharing, essential for meeting compliance requirements. The ongoing support from FAS in setting up and optimizing Ellucian Colleague for our specific needs will significantly strengthen our capacity to meet and exceed compliance standards, thus preventing future occurrences of similar issues. Starting June 2025, the Financial Aid Office will engage with FSA Partners and utilize NASFAA study materials to conduct comprehensive training for staff responsible for R2T4 calculations. Continuous education will be emphasized to keep staff updated on regulatory changes and best practices. We will utilize the capabilities of Ellucian Colleague to automate R2T4 calculations. This system will be set up to require authorization for post-withdrawal disbursements and ensure that award reductions are calculated in the correct order. We will introduce a secondary review process for all R2T4 calculations, where a seasoned financial aid counselor will verify the accuracy of the initial calculation and authorization documentation. We will standardize the process for documenting the authorization of post-withdrawal disbursements. Develop a standard communication template within Ellucian Colleague that includes explicit requests for student or parent authorization, ensuring compliance with federal regulations. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547259 (2024-006)

Significant Deficiency 2024

Johnson C. Smith University

NC

Student Financial Aid Eligibility Reporting

Corrective Action Plan: A lack of systematic communication between the Registrar’s Office and the Office of Financial Aid, coupled with an absence of an established process flow or calendar to guide quality assurance activities, led to these discrepancies. The University understands that accurate re...

Corrective Action Plan: A lack of systematic communication between the Registrar’s Office and the Office of Financial Aid, coupled with an absence of an established process flow or calendar to guide quality assurance activities, led to these discrepancies. The University understands that accurate reporting of student enrollment status is crucial for managing student eligibility for federal financial aid, including loans and grants; however, in these cases, there were several discrepancies. The University underwent a re-organization the resulted in the creation of a new division, Strategic Enrollment and Retention Management (“SERM”), effective February 2025. SERM aims to address the root causes of this finding by fostering enhanced synergy and communication between the Registrar’s Office and the Office of Financial Aid. This structural change aligns both departments under the governance of the Senior Vice President, ensuring cohesive and compliant operational practices. The alignment will facilitate a unified approach to meet federal reporting requirements more effectively and efficiently, thereby enhancing our administrative capability and compliance with critical federal requirements. This proactive governance restructuring is expected to significantly improve our process accuracy and compliance integrity, safeguarding our students' financial interests and maintaining our standing with federal financial aid programs. In addition, the University will establish audit and verification processes that involve conducting an exhaustive audit of current enrollment reporting processes in collaboration with Financial Aid Services (FAS) to identify and amend discrepancies. We will implement comprehensive, quarterly training for all staff involved in enrollment reporting starting August 2025 to ensure adherence to federal regulations. The Registrar’s Office will establish bi-weekly reporting schedules to the National Student Clearinghouse (NSC), including during summer terms, to ensure timely updates in NSLDS. There will also be regular review sessions to evaluate the effectiveness of the new reporting protocols and make necessary adjustments. Anticipated Completion Date: August 31, 2025

View Audit 351580

Finding 547255 (2024-005)

Significant Deficiency 2024

Johnson C. Smith University

NC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Corrective Action Plan: The University acknowledges shortcomings in our institutional processes for managing and communicating the details of Tier One and Tier Two financial arrangements. This has been due to a combination of factors, including outdated website management practices, a lack of clear ...

Corrective Action Plan: The University acknowledges shortcomings in our institutional processes for managing and communicating the details of Tier One and Tier Two financial arrangements. This has been due to a combination of factors, including outdated website management practices, a lack of clear guidelines on compliance responsibilities for web content, and insufficient inter-departmental communication regarding changes in federal regulations and their implications for our disclosure practices. The University is establishing a continuous feedback loop between Financial Aid, the Business Office, and University Communications and Marketing departments to ensure that our contractual disclosures are not only compliant but also clear and accessible to our stakeholders. Enhanced communication and collaboration across these departments are pivotal for maintaining ongoing compliance and ensuring that all disclosures are managed efficiently and transparently. This proactive approach is aimed at fostering a culture of compliance and transparency throughout the University. The University will improve the accessibility and visibility of contractual disclosures on its website to ensure compliance with federal requirements. The updated URLs will be provided to the Department of Education for publication of the contract in a centralized, accessible database. In addition, in partnership with Financial Aid Services (FAS), the University will conduct comprehensive interdepartmental training sessions by August 2025 for all relevant staff, emphasizing the critical nature of compliance with federal disclosure requirements. Anticipated Completion Date: August 31, 2025

View Audit 351580

Finding 547254 (2024-004)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Student Financial Aid Subrecipient Monitoring

Corrective Action Plan: The University relied on third-party technology to notify students of their disbursements without monitoring if their process was being executed. The failure stemmed from inadequate oversight of the notification process, leading to non-compliance with federal requirements for...

Corrective Action Plan: The University relied on third-party technology to notify students of their disbursements without monitoring if their process was being executed. The failure stemmed from inadequate oversight of the notification process, leading to non-compliance with federal requirements for the timely and accurate notification of loan disbursements. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition to Ellucian Colleague for financial aid management. University officials are committed to rectifying this deficiency through significant enhancements to our notification processes and technological infrastructure. The systematic integration of notification with the actual disbursement function via Ellucian Colleague represents a robust solution to ensure compliance. By handling this process internally, we ensure greater control, reliability, and compliance with federal regulations. Regular audits of the disbursement and notification process will be implemented to guarantee that our procedures remain in alignment with federal requirements and best practices. This proactive approach ensures that all loan disbursements are properly managed and communicated, safeguarding both our students' financial interests and the university's compliance status. The university has already begun to amend procedures to ensure that all loan disbursements are accompanied by timely and accurate notifications. The Office of Financial Aid will maintain detailed records showing compliance with these notifications. The integration of Ellucian Colleague will automate the notification process. This system ensures that notifications are sent immediately upon disbursement processing, using various modalities such as email, text messages, or direct updates to the student portal. We will enhance our enhance record-keeping through the utilization of Ellucian Colleague by logging all communications sent, ensuring that there is traceable evidence of compliance. This system integration addresses previous dependencies on third-party technologies and brings control of this crucial compliance aspect in-house. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547250 (2024-003)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Student Financial Aid Reporting

Corrective Action Plan: The verification for one student was improperly conducted, leading to financial aid awards and disbursements based on unverified or incorrectly verified financial data, specifically regarding untaxed IRA distributions and pensions. The verification failure was due to an overs...

Corrective Action Plan: The verification for one student was improperly conducted, leading to financial aid awards and disbursements based on unverified or incorrectly verified financial data, specifically regarding untaxed IRA distributions and pensions. The verification failure was due to an oversight by the aid administrator who incorrectly verified the untaxed IRA distribution and pension as zero, despite contradictory evidence or a lack of supporting documentation. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. Resulting from the work of FAS, the verification policies will be thoroughly reviewed, and revised, to ensure comprehensive coverage as mandated by federal regulations. The University will also establish a robust quality control system to regularly review verification practices and compliance, ensuring adherence to updated policies. We will update and maintain a verification checklist that includes all data elements required for verification. This checklist will be used in all verifications, with a secondary review and sign-off by another trained administrator to ensure accuracy and completeness. In addition, we will bolster training for all financial aid staff, utilizing resources from FAS and the National Association of Student Financial Aid Administrators (NASFAA) to deepen understanding and expertise in verification processes. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547248 (2024-002)

Significant Deficiency 2024

Johnson C. Smith University

NC

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Corrective Action Plan: The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS syste...

Corrective Action Plan: The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS systems contributed to erroneous COA budgets. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition from the use of PowerFaids to Ellucian Colleague for financial aid management. Resulting from the work of FAS, the University will institute a systematic monthly reconciliation process to ensure consistency across all systems (COD, PowerFAIDS, Jenzabar and Colleague). This includes matching COA and disbursement records to ensure accuracy. To optimize workflow, we will establish a comprehensive calendar of disbursement and reporting deadlines, with routine internal audits every 30 days, starting April 2025. This measure will enforce accountability and timeliness in reporting. We will enhance integration between financial systems (Jenzabar and PowerFAIDS) to prevent data mismatches and streamline the reporting process. In addition, we will leverage our partnership with FAS to conduct regular training sessions for staff across the Financial Aid, Registrar, and Finance Offices to ensure everyone is aware of compliance requirements and system functionalities. These training sessions will start May 2025. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547245 (2024-001)

Significant Deficiency 2024

Johnson C. Smith University

NC

Questioned Costs Student Financial Aid Subrecipient Monitoring

Corrective Action Plan: The University did not appropriately review eligibility documentation resulting in over awards. The error arose due to the manual processing of student loans by a single financial counselor without adequate checks, leading to non-compliance with specific fund restrictions rel...

Corrective Action Plan: The University did not appropriately review eligibility documentation resulting in over awards. The error arose due to the manual processing of student loans by a single financial counselor without adequate checks, leading to non-compliance with specific fund restrictions related to the student’s year in school and dependency status. A significant contributing factor was the absence of structured, periodic quality assurance reviews. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will transition from the use of PowerFaids to Ellucian Colleague for financial aid management, which was driven by the need for more robust, systematic controls that can accurately adjust and calculate Cost of Attendance (COA) on a per-student basis. This system change is expected to automate many of the processes that were previously prone to human error, ensuring compliance with regulatory requirements. The University’s Financial Aid counselors will continue to monitor students' credit hours and make necessary adjustments to aid awards, thereby maintaining compliance and addressing any discrepancies proactively. This plan reflects our commitment to upholding the highest standards of financial aid management and ensuring that our processes are transparent, compliant, and responsive to the needs of our students. The University will integrate automated processes in our financial aid packaging to reduce human error. The adoption of the Ellucian Colleague system by JCSU will allow for automatic enforcement of packaging and transmittal rules, tailored to specific funds. Additionally, we will utilize exception reports from Ellucian Colleague to identify and correct discrepancies in real-time. We will establish a routine monitoring system to regularly check the accuracy of financial aid awards against eligibility criteria. Anticipated Completion Date: September 30, 2025

View Audit 351580 Questioned Costs: $1

Finding 547233 (2024-001)

Significant Deficiency 2024

East Meadow Union Free School District

NY

Equipment & Real Property Management § 200.313

2024-001. Equipment and Real Property Management United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN:84.02...

2024-001. Equipment and Real Property Management United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN:84.027X Special Education Preschool Grants: IDEA Preschools ALN: 84.173 Special Education Preschool Grants: DEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief ALN: 84.425U COVID-19: American Rescue Plan - Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W Condition: The District did not include all equipment purchased with federal grant awards within its current year additions in the District’s capital assets inventory records. Planned Corrective Action: The District will implement procedures where a formal reconciliation will be performed between the District’s equipment expenditure codes and the additions to the District’s capital assets inventory records. Responsible Contact Person: Dr. Patrick Pizzo Assistant Superintendent for Business and Finance East Meadow Union Free School District 718 The Plain Road Westbury, New York 11590 Anticipated Completion Date: June 30, 2025.

View Audit 351570

Finding 547232 (2024-001)

Significant Deficiency 2024

The University of Charleston, INC

WV

Reporting Student Financial Aid

The University recognizes the untimely staff turnover and the impact it has had on University compliance. University leadership has taken steps to ensure immediate and future compliance with the regulations referenced in this finding. The following corrective action plan has been implemented to prev...

The University recognizes the untimely staff turnover and the impact it has had on University compliance. University leadership has taken steps to ensure immediate and future compliance with the regulations referenced in this finding. The following corrective action plan has been implemented to prevent delays in future reporting. An experienced Institutional Researcher (IR) has been hired for the University, with over 20 years of student enrollment data management and reporting to the National Student Clearinghouse (Clearinghouse). The schedule for reporting student enrollment has been modified to reflect reporting within 30-to-45-day intervals. Reporting at this interval will ensure compliance with the 60-day requirement. Email notifications of enrollment reports due, enrollment reports submitted, correction reports, and report delinquencies from the Clearinghouse are now sent to the IR, the Registrar, and the Provost’s Office. The Provost and the IR meet at least weekly regarding compliance and ongoing reporting for the University.

View Audit 351564

Finding 547231 (2024-002)

None 2024

Puerto Rico Safe Drinking Water Treatment Revolving Loan Fund

PR

Equipment & Real Property Management Subrecipient Monitoring Cash Management § 200.465

Finding No. 2024-002 – Rental Costs of Real Property and Equipment Condition Found When renewing the rental contract for the administration of the Revolving Fund, the DOH, as the Revolving Fund administrator, complied with statutory laws and procedures governing contract renewal. However, under the ...

Finding No. 2024-002 – Rental Costs of Real Property and Equipment Condition Found When renewing the rental contract for the administration of the Revolving Fund, the DOH, as the Revolving Fund administrator, complied with statutory laws and procedures governing contract renewal. However, under the applicable regulations, if a contract renewal does not include a fee increase, there is no statutory requirement to evaluate comparable rental properties or conduct a periodic market study to assess potential changes in market conditions. As a result, the Revolving Fund lacks, within its existing processes and documentation, established policies and procedures for performing and documenting such assessments and did not conduct the evaluation required under 2 CFR § 200.465 in a timely manner. However, during discussions with the auditors, the required evaluation was performed, demonstrating that the rental costs remain reasonable in accordance with federal regulations. Views of Responsible Officials and Corrective Action Plan Having addressed and resolved the matter in reference, we also concur what was discussed with the auditors, that the required information was provided demonstrating that the costs for rent are reasonable and are in accordance with the provisions of the federal regulations, proceeded as follows: • In parallel to the current process of renewal of the lease contract, the Program performed the reasonableness study for rent cost, regardless of the non-requirement within the current procedure. The study confirmed that the rent costs are reasonable and cost effective. • For the purpose and as part of the corrective action plan, the Program incorporated as part of its processes a procedure to achieve the implementation of periodic evaluation of rental costs. This procedure incudes among others, the frequency in which such evaluations will be carried out. • The Program, as Administrator, will recommend the Department of Health’s management the need to incorporate the periodic requirement in compliance with the 2 CRF § 200.465 federal section. Name (s) of the Contact Person (s) Responsible for Corrective Action Ángel Pantoja Rodríguez, Secretary of the Treasury Department, Eduardo Rivera Cruz, Executive Director Puerto Rico Infrastructure Financing Authority and Victor Ramos, Secretary of the Puerto Rico Department of Health. Anticipated Completion Date Immediately

View Audit 351563

Finding 547230 (2024-001)

Significant Deficiency 2024

Puerto Rico Safe Drinking Water Treatment Revolving Loan Fund

PR

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

Finding No. 2024-001 -Allowable Activities-Loans repayments Condition Found Principal and interest have not been collected from the Revolving Fund on projects that were completed since before the execution of the loan agreement, which are included as part of the financial agreement dated September 2...

Finding No. 2024-001 -Allowable Activities-Loans repayments Condition Found Principal and interest have not been collected from the Revolving Fund on projects that were completed since before the execution of the loan agreement, which are included as part of the financial agreement dated September 2, 2022. Therefore, repayment of principal and payment of interest should have begun on their respective dates, as set forth in the loan agreement and notes payable executed thereto. Views of Responsible Officials and Corrective Action Plan Once the final inspection of a construction project is performed, DOH will submit notifications to PRASA requesting the Notice of Substantial Completion letter from PRASA concurring that the project is acceptable of the operation. Such letter will be an attachment to the formal notification that DOH will send to PRASA and PRIFA. DOH’s letter will specify the starting operating date and the useful life of the project. Therefore, PRIFA will be in position to collect principal and interest for the project according to federal regulations and as established in the loan agreement. Name (s) of the Contact Person (s) Responsible for Corrective Action Ángel Pantoja Rodríguez, Secretary of the Treasury Department, Eduardo Rivera Cruz, Executive Director Puerto Rico Infrastructure Financing Authority and Victor Ramos, Secretary of the Puerto Rico Department of Health. Anticipated Completion Date Immediately

View Audit 351563

Finding 547229 (2024-001)

Material Weakness 2024

Royalton Fire District #1

VT

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Material Weakness § 200.318 § 200.327

CORRECTIVE ACTION PLAN (CONCERNING FINDING 2024-001-RF3-407-3.0) Contact Person Responsible for Corrective Action: Judy L Hayward Corrective Action Plan: The Royalton Fire District 1 will take the following actions to address finding 2024-01. We will prepare and adopt a federal procurement policy, A...

CORRECTIVE ACTION PLAN (CONCERNING FINDING 2024-001-RF3-407-3.0) Contact Person Responsible for Corrective Action: Judy L Hayward Corrective Action Plan: The Royalton Fire District 1 will take the following actions to address finding 2024-01. We will prepare and adopt a federal procurement policy, Anticipated Completion Date: June 30, 2025.

View Audit 351553

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