Corrective Action Plans

Finding 544175 (2024-004)

Significant Deficiency 2024

DE

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

2024-004 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior...

2024-004 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: The Assistant Controller will implement review procedures for timely reconciliation of bank and ledger accounts & maintain an accurate listing of those discrepancies. This information will be timely shared with respective teams to address. Name(s) of the contact person(s) responsible for corrective action: Assistant Controller, Clifton Smith, II. Planned completion date for corrective action plan: July 2025

View Audit 350927

Finding 544174 (2024-003)

Material Weakness 2024

Delaware State University

DE

Matching / Level of Effort / Earmarking Student Financial Aid Material Weakness § 200.303

2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally...

2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the National Student Loan Data System (NSLDS). The Registrar’s Office will continue to work with the National Student Clearinghouse (NSCL) and National Student Loan Data System (NSLDS) on the specific enrollment submission scenarios that require a different submission/update requirement. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: December 2025

View Audit 350927

Finding 544161 (2024-002)

Significant Deficiency 2024

Volunteers of America of Eastern Washington and Northern Idaho

WA

Procurement, Suspension & Debarment

The SVP of Finance will revise the current procurement policy to include suspension and debarment, as well as subrecipient monitoring. They will also provide appropriate training for staff.

View Audit 350926

Finding 544159 (2024-007)

Significant Deficiency 2024

Washington Adventist University

MD

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

Action taken in response to finding: A formal review of will take place of NSLDS reporting. Written policy with a monthly checklist will be developed to be in compliance with the regulation for student statuses. Name(s) of the contact person(s) responsible for corrective action: Patrick Farley Plan...

Action taken in response to finding: A formal review of will take place of NSLDS reporting. Written policy with a monthly checklist will be developed to be in compliance with the regulation for student statuses. Name(s) of the contact person(s) responsible for corrective action: Patrick Farley Planned completion date for corrective action plan: June 30, 2025

View Audit 350924

Finding 544155 (2024-004)

Significant Deficiency 2024

Washington Adventist University

MD

Questioned Costs Matching / Level of Effort / Earmarking § 200.303

Action taken in response to finding: Move all promissory notes to a fireproof filing cabinet, that is stored in a secure area. Each promissory note has been backed up electronically. Assign all defaulted and potential default loans to the Department of Education. Name(s) of the contact person(s) res...

Action taken in response to finding: Move all promissory notes to a fireproof filing cabinet, that is stored in a secure area. Each promissory note has been backed up electronically. Assign all defaulted and potential default loans to the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Patrick Farley Planned completion date for corrective action plan: June 30, 2026

View Audit 350924 Questioned Costs: $1

Finding 544141 (2024-006)

Significant Deficiency 2024

Washington Adventist University

MD

Subrecipient Monitoring Student Financial Aid

Action taken in response to finding: To address the identified deficiencies in WAU’s written information security program and ensure compliance with 16 CFR § 314.4, the following actions have been taken: 1. Approval of the Information Security Program: o Action: We have updated the written informat...

Action taken in response to finding: To address the identified deficiencies in WAU’s written information security program and ensure compliance with 16 CFR § 314.4, the following actions have been taken: 1. Approval of the Information Security Program: o Action: We have updated the written information security program as formally approved by the appropriate individual within the institution, Rosalee Pedapudi, ITS Director. This step designates a qualified individual responsible for overseeing and implementing the information security program as a requirement under 16 CFR § 314.4(a). 2. Design and Implementation of Safeguards: o Action: According to 16 CFR § 314.4(c), institutions must implement safeguards to control identified risks, including encryption of customer information in transit and at rest. We have documented specific safeguards to control the risks identified through the institution's risk assessment, including a policy mandating the encryption of customer information both on the institution's systems and during transmission. As such, the university encrypts Non-Public Financial information both at rest and in transit using industry-standard encryption protocols (e.g. VPN). Where encryption is not feasible, compensating controls are implemented to protect sensitive data. The university also requires Multifactor Authentication (MFA) for systems that process, store, or transmit protected financial information. Access is governed by the principle of least privilege, with privileged access granted by authorized university officers, ensuring that only approved personnel can access sensitive data. 3. Regular Testing and Monitoring of Safeguards: o Action: According to 16 CFR § 314.4(d), WAU is required to regularly test and monitor the effectiveness of their safeguards to ensure the security of customer information. We have established procedures for annual penetration testing through Applied Technology Services and monitoring of the effectiveness of the implemented safeguards. Name(s) of the contact person(s) responsible for corrective action: Rosalee Pedapudi Planned completion date for corrective action plan: July 15, 2025.

View Audit 350924

Finding 544140 (2024-005)

Significant Deficiency 2024

Washington Adventist University

MD

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Action taken in response to finding: Washington Adventist University will review Institutional charges used in R2T4 to ensure that all institutional charges used in R2T4 calculations are accurate and align with federal definitions. Regular training sessions will be conducted for staff involved in R...

Action taken in response to finding: Washington Adventist University will review Institutional charges used in R2T4 to ensure that all institutional charges used in R2T4 calculations are accurate and align with federal definitions. Regular training sessions will be conducted for staff involved in R2T4 process to ensure they understand the requirements and procedures and also implement a system of review calculations and R2T4 cases before submission. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025

View Audit 350924

Finding 544139 (2024-003)

Significant Deficiency 2024

Washington Adventist University

MD

Questioned Costs Eligibility Student Financial Aid § 200.303

Action taken in response to finding: The University has SAP policies and procedures in place to determine student’s eligibility for Financial Aid that complies with Federal regulations, including qualitative (GPA), quantitative (pace of completion) and maximum timeframe standards. The SAP finding m...

Action taken in response to finding: The University has SAP policies and procedures in place to determine student’s eligibility for Financial Aid that complies with Federal regulations, including qualitative (GPA), quantitative (pace of completion) and maximum timeframe standards. The SAP finding may be due to system error with the Colleague ERP when the SAP report was run. The University will evaluate our SAP procedures and perform internal audits to identify gaps or inconsistencies and implement corrective actions as needed. Training will be provided to financial aid staff on SAP requirements and procedures to ensure consistent application and understanding. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025

View Audit 350924 Questioned Costs: $1

Finding 544138 (2024-002)

Material Weakness 2024

Washington Adventist University

MD

Student Financial Aid Internal Control / Segregation of Duties Cash Management § 200.303

Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to impro...

Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to improve segregation of duties where possible and follow the Committee of Sponsoring Organizations of the Treadway Commission best practices for small business. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025.

View Audit 350924

Finding 544136 (2024-001)

None 2024

Trinity Christian College

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be e...

All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed.

View Audit 350923

Finding 544135 (2024-001)

Significant Deficiency 2024

Accokeek Foundation, INC

MD

Questioned Costs

The finding from the September 30, 2024 schedule of findings and questioned cost is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Federal Award 2024-001 Summary of Finding During our testing over payroll auditors noted that for three pay p...

The finding from the September 30, 2024 schedule of findings and questioned cost is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Federal Award 2024-001 Summary of Finding During our testing over payroll auditors noted that for three pay periods there were variances between the total calculated amount to be charged to the grant based on the timecards and the total actual amount charged. As a result. payroll charged to the major program was understated by $2,591 for the year ended September 30, 2024. Statement of Concurrence or Nonconcurrence Management agrees with the finding and will implement the following corrective action. Corrective Action Accokeek Foundation will implement an enhanced payroll reconciliation process by updating the Excel workbook formula to ensure the timecard grant allocations are correctly captured and reported. The accounting team will test the updated formula to verify its accuracy and effectiveness. They will monitor the effectiveness of this corrective action through quarterly reviews and ensure that any discrepancies identified are promptly corrected. The enhanced reconciliation process and training will be implemented by June 30, 2025.

View Audit 350919 Questioned Costs: $1

Finding 544133 (2024-002)

Material Weakness 2024

Marshall Public Schools

WI

Reporting

Finding #2024-002 - Lack of Financial lose Process and Delayed Accounting Condition: Cash and other accounts were adjusted during the audit process. Many audit journal entries were required to record and adjust activity. Effect: Financial reporting from the District's general ledger could be materi...

Finding #2024-002 - Lack of Financial lose Process and Delayed Accounting Condition: Cash and other accounts were adjusted during the audit process. Many audit journal entries were required to record and adjust activity. Effect: Financial reporting from the District's general ledger could be materially misstated. Delayed grant claims could cause cash flow issues. Cause: The District did not have procedures in place to ensure that all transactions were properly recorded on the general ledger prior to the audit. Criteria: During the close of the monthly financial statements, other balances should be reconciled to subsidiary detailed listings. Grant claims should be reconciled to the general ledger and submitted throughout the year. Receivables should be recorded as of year end as needed. Recommendation: The District should develop procedures to timely reconcile cash and other balance sheet accounts. The reconciliations should be reviewed by someone other than the person preparing the reconciliations. The reviewer should initial and date the reconciliations when the review is complete. The District should reconcile payroll liabilities. The District should develop procedures to review and submit grant claims throughout the year and reconcile to the general ledger. Response: The District will work to establish procedures to reconcile accounts monthly and grant claims are reconciled and submitted throughout the year. Contact Person: Jessie Backes, Interim Business Manager Anticipated Completion Date: Ongoing

View Audit 350917

Finding 544132 (2024-001)

Significant Deficiency 2024

City of Orange

CA

HUD Housing Programs Reporting Significant Deficiency

Name of Contact Person: Trang Nguyen Corrective Action: The Community Development Department has implemented the following steps for FY 2025. 1. Updated the City’s policy to iden􀆟fy the Housing Manager or designee as the responsible repor􀆟ng party to submit the reports by the submission deadline. 2....

Name of Contact Person: Trang Nguyen Corrective Action: The Community Development Department has implemented the following steps for FY 2025. 1. Updated the City’s policy to iden􀆟fy the Housing Manager or designee as the responsible repor􀆟ng party to submit the reports by the submission deadline. 2. Added to the policy administra􀆟ve support staff to set calendar reminders in outlook for follow up. 3. Finance will add to the quarterly and year-end checklist to ensure 􀆟mely repor􀆟ng. Proposed Completion Date: June 30, 2025

View Audit 350915

Finding 544116 (2024-004)

Material Weakness 2024

New Reach, Inc.

CT

Allowable Costs / Cost Principles

Finding No. 2024-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Description of Finding: The Organization was unable to produce records supporting the work performed or support the distribution of wages. Statement of Concurrence or Nonconcurrence: The organization agrees wit...

Finding No. 2024-004: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Description of Finding: The Organization was unable to produce records supporting the work performed or support the distribution of wages. Statement of Concurrence or Nonconcurrence: The organization agrees with this finding. Corrective Action: With the implementation of a revised cost allocation plan noted above the Organization now require all employees to attest the accurate allocation of their time via personnel activity reports (PARS) Allocation of payroll costs will be supported by the PARS and the calculation will be attached to each allocation journal entry within the general ledger. Name of Contact Person: Kellyann Day Chief Executive Officer, (203) 492-4866, kday@newreach.org Projected Completion Date: The project is anticipated to be completed during fiscal year 2025.

View Audit 350907

Finding 544100 (2024-003)

Material Weakness 2024

New Reach, Inc.

CT

Allowable Costs / Cost Principles

Finding No. 2024-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Description of Finding: The Organization was unable to produce documentation supporting its cost allocation plan ("CAP"). Operating expenditures reported on submitted grant reports did not consistently reconcil...

Finding No. 2024-003: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Description of Finding: The Organization was unable to produce documentation supporting its cost allocation plan ("CAP"). Operating expenditures reported on submitted grant reports did not consistently reconcile directly back to the underlying accounting records. Statement of Concurrence or Nonconcurrence: The organization agrees with this finding. Corrective Action: Subsequent to year end the organization updated its CAP Beginning in July the allocation calculation and documentation will be attached to all allocation journal entries. Name of Contact Person: Kellyann Day Chief Executive Officer, (203) 492-4866, kday@newreach.org Projected Completion Date: The project is anticipated to be completed during fiscal year 2025.

View Audit 350907

Finding 544096 (2024-002)

Significant Deficiency 2024

New Reach, Inc.

CT

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding No. 2024-002: Compliance Reporting Description of Finding: The Organization submitted periodic reports that did not reconcile to the accounting records and were not submitted by the due date. Statement of Concurrence or Nonconcurrence: The organization agrees with this finding. Corrective Ac...

Finding No. 2024-002: Compliance Reporting Description of Finding: The Organization submitted periodic reports that did not reconcile to the accounting records and were not submitted by the due date. Statement of Concurrence or Nonconcurrence: The organization agrees with this finding. Corrective Action: In August 2024 the Organization engaged the services of an outside consultant who is a practicing CPA with extensive experience auditing not-for profit organizations. Policies and related procedures have been implemented to ensure the books and records are closed on a monthly basis and all reports are reviewed for agreement with the accounting records and approved prior to being filed. Name of Contact Person: Kellyann Day Chief Executive Officer, (203) 492-4866, kday@newreach.org Projected Completion Date: The project is anticipated to be completed during fiscal year 2025.

View Audit 350907

Finding 544094 (2024-001)

Significant Deficiency 2024

Quinnipiac University

CT

Student Financial Aid Procurement, Suspension & Debarment Cash Management

Uniform Guidance Corrective Action Plan Year ended June 30, 2024 Federal Finding #2024-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, bu...

Uniform Guidance Corrective Action Plan Year ended June 30, 2024 Federal Finding #2024-001 Returns of Title IV funds are required to be deposited or transferred into the student financial assistance account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines the student withdrew. Quinnipiac University agrees with the finding. For one student who withdrew during the 2023 – 2024 academic year, the Direct Loan funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. For one student who withdrew during the 2023 – 2024 academic year, the Pell and Direct Loan funds awarded to that student were not returned to the student financial assistance account within 45 days after the University determined the student withdrew. The finding is attributed to programs previously being reconciled monthly or when enough authorized funds became available within G5. At the time the above students withdrew, there were not enough authorized funds to process the net total of draw downs and returns so a batch was held until more funds were available, which resulted in returns surpassing the 45 day threshold. In December 2023, Management implemented additional steps within the reconciliation process of Title IV awards in order to prioritize the return of any unearned Title IV awards so that they are remitted to the student financial assistance account within G5 in a timely manner. The students mentioned above withdrew prior to these additional steps being implemented. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

View Audit 350901

Finding 544091 (2024-007)

Significant Deficiency 2024

Jersey City Public Schools

NJ

Reporting

With respect to the American Rescue Plan (ARP)- ESSER Program: o The District's budget report related to the American Rescue Plan - ESSER program be reviewed to ensure that appropriations and resulting balances accurately reflect remaining program funds available. o The...

With respect to the American Rescue Plan (ARP)- ESSER Program: o The District's budget report related to the American Rescue Plan - ESSER program be reviewed to ensure that appropriations and resulting balances accurately reflect remaining program funds available. o The Board resolution approving hourly rates for employees funded by the American Rescue Plan - ESSER program be amended to reflect revised contractual rates. In addition, timesheets for such employees be signed for approval by the appropriate supervisory personnel.

View Audit 350893

Finding 544090 (2024-006)

Significant Deficiency 2024

Jersey City Public Schools

NJ

Student Financial Aid Reporting

The District's budget report related to the ESEA Title IV program be reviewed to ensure that appropriations and resulting balances accurately reflect remaining program funds available.

View Audit 350893

Finding 544086 (2024-004)

Material Weakness 2024

Wide Ruins Community School

AZ

Procurement, Suspension & Debarment § 200.318 § 200.326

Finding Number: 2024‐004 Program Name/Assistance Listing Titles: Indian School Equalization; Indian School Student Transportation Assistance Listing Numbers: 15.042, 15.044 Contact Person: Aurelia Tapaha, Business Manager; Stephanie Woody, Business Technician Anticipated Completion Date: July 2025 P...

Finding Number: 2024‐004 Program Name/Assistance Listing Titles: Indian School Equalization; Indian School Student Transportation Assistance Listing Numbers: 15.042, 15.044 Contact Person: Aurelia Tapaha, Business Manager; Stephanie Woody, Business Technician Anticipated Completion Date: July 2025 Planned Corrective Action: The School will revisit financial policies and procedures and strictly comply with procurement processes. There are specific requirements for different amounts of purchases. The School will review requisitions and ask for required documents before processing. Repeat finding due to employee’s not following the procurement processes and business office personnel accepting requisitions without proper documentation attached.

View Audit 350888

Finding 544085 (2024-003)

Significant Deficiency 2024

Wide Ruins Community School

AZ

Special Tests & Provisions Period of Performance Significant Deficiency

Finding Number: 2024‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Jeannie Raphaelito, Human Resources Technician; Donna Manuelito, Principal Anticipated Completion Date: July 2025 Planned Corrective Action: The School will co...

Finding Number: 2024‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Jeannie Raphaelito, Human Resources Technician; Donna Manuelito, Principal Anticipated Completion Date: July 2025 Planned Corrective Action: The School will conduct background investigations as soon as consent is signed by applicant or employee. Prioritization of background completion will be done in accordance with personnel policies and procedures. Repeat Finding due to school board vacating the Human Resources position. The School Board did reconsider dual title of Business Manager/Human Resources and removed the Human Resource Manager duties from Business Manager position description. This change happened before hiring for the vacated Human Recourse position; therefore, all HR duties and responsibilities were not met.

View Audit 350888

Finding 544084 (2024-002)

Significant Deficiency 2024

Wide Ruins Community School

AZ

Reporting

Finding Number: 2024‐002 Program Names/Assistance Listing Titles: Indian School Equalization, Indian Education Facilities, Operation, and Maintenance Assistance Listing Numbers: 15.042, 15.047 Contact Person: Aurelia Tapaha, Business Manager Anticipated Completion Date: April 2025 Planned Corrective...

Finding Number: 2024‐002 Program Names/Assistance Listing Titles: Indian School Equalization, Indian Education Facilities, Operation, and Maintenance Assistance Listing Numbers: 15.042, 15.047 Contact Person: Aurelia Tapaha, Business Manager Anticipated Completion Date: April 2025 Planned Corrective Action: The School will start submitting SF‐425 Quarterly report before the last day of the month. Attend training provided by Bureau of Indian Education to learn of compliance with federal regulations and guidelines.

View Audit 350888

Finding 544083 (2024-001)

Significant Deficiency 2024

Wide Ruins Community School

AZ

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Significant Deficiency

Finding Number: 2024‐001 Program Names/Assistance Listing Titles: Indian School Equalization, Indian Education Facilities, Operations and Maintenance Assistance Listing Numbers: 15.042, 15.047 Contact Person: Aurelia Tapaha, Business Manager; Stephanie Woody, Business Technician; Donna Manuelito, Pr...

Finding Number: 2024‐001 Program Names/Assistance Listing Titles: Indian School Equalization, Indian Education Facilities, Operations and Maintenance Assistance Listing Numbers: 15.042, 15.047 Contact Person: Aurelia Tapaha, Business Manager; Stephanie Woody, Business Technician; Donna Manuelito, Principal Anticipated Completion Date: July 2025 Planned Corrective Action: The School will review the procurement flowcharts and required documents for Business Technician. The School will obtain training for chart of accounts training for business staff along with procurement training. Business staff and administrators will keep abreast of law changes, GASB updates, and budget changes with grants received. The School will review school credit and implement a timeframe where the no use of the credit card is enforced. The School will collect all required documents to process payments. The entire balance will be paid in full amount for each month. Training on use of credit cards will be given during orientation. Update of Financial Policies to reflect changes to OMB Circular. Repeat finding due to change in Administration and our focus to meet requirements of BIE and Department of Dine Education took precedence.

View Audit 350888

Finding 544082 (2024-001)

Significant Deficiency 2024

Bridgewater College

VA

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

2024-001 Enrollment Reporting (Significant Deficiency), Department of Education, Student Financial Aid Cluster, Special Tests and Provisions Condition: The College did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Unless it ...

2024-001 Enrollment Reporting (Significant Deficiency), Department of Education, Student Financial Aid Cluster, Special Tests and Provisions Condition: The College did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended (34 CFR 685.309(b)(2)(i)). Cause: The College does not have adequate procedures in place to ensure students’ enrollment statuses are updated on NSLDS timely. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the students’ loans. The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Context: From a population of 42 students that withdrew officially during a term, we tested 5 students and noted that all 5 were not reported timely. Recommendation: We recommend that the College put procedures in place to ensure that any changes in student enrollments are properly tracked and updated to the NSLDS. Management Response: When the Registrar’s Office is notified of a student’s withdrawal (official or unofficial), within 24 hours the student’s record in the National Student Clearinghouse will be manually flagged as withdrawn with their last date of attendance. Party responsible: Sherry A. Phelps Office phone: 540-828-5313 Email address: sphelps2@bridgewater.edu Expected date of correction: This problem was corrected on 6/27/2024 when it was brought to my attention and since that date the required information has been correctly reported directly into the National Student Clearinghouse within 24 hours of the date of determination of a student’s withdraw from the college.

View Audit 350883

Finding 544078 (2024-001)

Material Weakness 2024

Gaudenzia Inc.

PA

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

2024-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of S...

2024-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of Schuylkill - Home Investment Partnerships and Housing Trust Funds Programs: Fountain Springs - Loan Mayor and City of Baltimore: Baltimore Housing - Park Heights Women and Children - Loan Condition: As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless), and lease or housing agreement (depending on program requirements). Of the 40 resident client files reviewed, management was unable to provide any proof of income or determination of homelessness or residency for 24 files. Recommendation: We recommend that management adopt policies and procedures including both the communication of compliance requirements between staff and locations and the development of documentation and processes to assist in how income eligibility is determined. This includes management developing certain income verification documents that can be used as part of the intake process for determining the eligibility of the residential client. In addition, process will need to be developed for the redetermination of income if a residential client has lived over a year at a particular location. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Gaudenzia, Inc believes that had the requisite documentation been completed, it would have been in compliance with the low-income compliance requirement as the referral sources that were used to place the clients in the program are all coming from CBH as well as other MCO funded partners. These referral sources are typically Medicaid clients and are typically well below the low-income requirement thresholds. Action taken in response to finding: Gaudenzia, Inc has incorporated existing low-income eligibility procedures to the Project Home Loans program sites to be in full compliance of the eligibility requirements. These procedures will be reinforced within our programs to ensure the requisite documentation is in place. Name of the contact person responsible for corrective action: Nikant Ohri, Chief Financial Officer, nikant.ohri@guadenzia.org (610) 860-2061 Planned completion date for corrective action plan: June 30, 2025

View Audit 350881

Corrective Action Plans

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