Corrective Action Plans

Finding 540354 (2024-002)

Significant Deficiency 2024

IL

Allowable Costs / Cost Principles

Going forward the Organization will document the review and approval of the payroll allocated and charged to the federal award.

View Audit 350220

Finding 540345 (2024-001)

Significant Deficiency 2024

Centers for New Horizons, Inc.

IL

Internal Control / Segregation of Duties

The program tested requires a manual entry directly into the grantors system. Going forward the Organization will document the review and approval of the amounts submitted monthly to this system.

View Audit 350220

Finding 540344 (2024-001)

Material Weakness 2024

Alachua County District School Board

FL

Questioned Costs Special Tests & Provisions

PLANNED CORRECTIVE ACTION - Enhance procedures to update Federally funded construction contracts to require the submission of weekly certified payrolls to the appropriate District personnel. ANTICIPATED COMPLETION DATE - Immediate RESPONSIBLE CONTACT PERSON - Brandon Esposito, Director of Finance

View Audit 350218 Questioned Costs: $1

Finding 540343 (2024-001)

Significant Deficiency 2024

City of San Diego

CA

Procurement, Suspension & Debarment Subrecipient Monitoring HUD Housing Programs

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact t...

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact that the FSRS.gov system has since been retired and integrated into the SAM.gov system acknowledges the need for reducing duplicate recording in favor of an integrated system. Staff’s understanding of the process was in line with available guidance currently still posted on HUD’s website (https://www.hud.gov/sites/dfiles/CPD/documents/CPD_FSRS_Learning_Session_Final_8.26.21.pdf). The City of San Diego did not receive notification of the FSRS deadline from HUD for Fiscal Year (FY) 2024. With regard to the dates entered in the FSRS.gov system, the agreements’ effective dates cover the entire fiscal year, and the awards were approved by our City Council to be in effect for the full fiscal year. Hence, staff entered the date July 1, 2023. Management accepts that going forward, dates should be entered based on the date the agreements are fully executed. Management agrees to include specific FFATA training and procedures in all CDBG manuals and checklists including procedures for compliance, if and when federal agency communication is late or lacking. Implementation Date: The conditions described above have already been corrected. FFATA training and procedures will be implemented within 30 days. Contact: Michele Marano Assistant Deputy Director, Community Development Economic Development Department City of San Diego Email: mmarano@sandiego.gov Phone: 619.236.6381

View Audit 350217

Finding 540342 (2024-004)

Significant Deficiency 2024

Yolo County Transportation District

CA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.318 § 200.326 § 200.327

2024-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented measures to improve procurement recordkeeping and compliance. A structured procurement folders and subfolders system has been established to maintain all relevant d...

2024-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented measures to improve procurement recordkeeping and compliance. A structured procurement folders and subfolders system has been established to maintain all relevant documentation. Management is actively working with consultants to update policies and procedures. Staff is scheduled to complete a structured three-session training through GFOA to enhance their understanding of federal procurement regulations and best practices. The District will continue training and development efforts in public procurement, with a particular focus on federal compliance, strengthening internal controls, improving documentation, and ensuring adherence to regulatory requirements Responsible Party: Director of Finance & Administration and Department Managers Implementation Date: Ongoing; full implementation expected by June 30, 2025

View Audit 350214

Finding 540338 (2024-003)

Material Weakness 2024

Yolo County Transportation District

CA

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.303

2024-003 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the audit recommendations and remains committed to strengthening grant management and financial oversight. This year’s challenges in grant reconciliation stemmed from overlapping prior-year FTA claims is...

2024-003 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the audit recommendations and remains committed to strengthening grant management and financial oversight. This year’s challenges in grant reconciliation stemmed from overlapping prior-year FTA claims issues, pending grant amendments, and limited time, as noted in Finding 2024-002. Additionally, the increased complexity of federal grants following the pandemic required adjustments to allocation methods and financial reporting. To address these issues, staff has refined internal processes, including improving worksheets, enhancing review procedures, and consolidating grant data into a single summary sheet for better tracking. The 2024 FTA Triennial Review acknowledged these improvements, and the corrective action plan was considered sufficient, with recommendations to closely monitor grant activity and update the worksheets as necessary. Moving forward, staff will continue formalizing procedures for expense allocation, improve reconciliation processes, and ensure grant expenditures align with available funding. Grant tracking will provide a clearer overview of balances, deadlines, and remaining funds. The Finance department also adjusted its billing practices to reconcile expenses earlier in the reporting cycle, allowing sufficient time for review and claim adjustments. Regarding the overclaimed amounts of $183,548 and $175,143, staff will work with the FTA to determine whether repayment is required or if the funds can be applied to future eligible expenses. These efforts will strengthen compliance, improve accuracy in financial reporting, and overall grant management. Responsible Party: Director of Finance & Administration Implementation Date: Ongoing; full implementation expected by December 31, 2025

View Audit 350214

Finding 540332 (2024-002)

Significant Deficiency 2024

People Incorporated of Virginia and Affiliates

VA

Reporting HUD Housing Programs Significant Deficiency

Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards Condition: During the audit, Wipfli LLP noted there were certain federal grants received from pass-through entities that were inadvertently excluded from the Schedule of Expenditures of Federal Awards. Management’s Res...

Finding 2024-002: Preparation of the Schedule of Expenditures of Federal Awards Condition: During the audit, Wipfli LLP noted there were certain federal grants received from pass-through entities that were inadvertently excluded from the Schedule of Expenditures of Federal Awards. Management’s Response PINC management acknowledges that some funds were inadvertently excluded from the Schedule of Expenditures of Federal Awards due to a combination of a recent CFO leadership transition and an outdated accounting system. However, these issues were not a result of fraud or misuse of funds, and the discrepancies were quickly addressed without any negative impact on the financial statements or audit timeline. The company is actively working to implement a new accounting system with an improved grants module to prevent similar issues in the future. These proactive steps reflect our commitment to compliance, financial accuracy, and continuous improvement in reporting processes. Contact Person Responsible for Corrective Action: Joshua Pevarnik, VP & CFO Anticipated Completion Date: Ongoing and by 6/30/2025

View Audit 350213

Finding 540331 (2024-001)

None 2024

Hughes Neighborhood Housing, Inc.c/o L.hayes & Associates

MD

Questioned Costs Cash Management HUD Housing Programs

A. Comments on Finding and Recommendations Comments: It is important to note that at no time did L. Hayes & Associates, Inc. (LHA), Managing Agent, use project funds for unrelated costs. This finding No. 2024-001 refers specifically to fraudulent check charges that were posted to the Hughes operatin...

A. Comments on Finding and Recommendations Comments: It is important to note that at no time did L. Hayes & Associates, Inc. (LHA), Managing Agent, use project funds for unrelated costs. This finding No. 2024-001 refers specifically to fraudulent check charges that were posted to the Hughes operating account in March 2024 by an unknown person. There was a total of three (3) checks written by the same person. This person is unknown to us and did not have access to our check stock nor our office. Therefore, it appears that the perpetrator used some type of machine to reproduce copies of our checks and the signature of Ms. Voundy-Thomas, Operations Manager. Recommendations: Based on the recommendation of our auditor, our office contacted the Maryland Banking Commission to report and pursue reimbursement of the fraudulent charges deducted from the Hughes Neighborhood Housing operating bank account and they referred us to contact the Office of the Comptroller of Currency. Our auditor also suggested that we discuss potential solutions with our HUD Account Executive. B. Actions Taken or Planned Actions Taken: Upon reconciliation of the Project’s March 2024 bank accounts and the discovery of the fraudulent charges, Ms. Voundy, Thomas immediately contacted Wells Fargo’s Fraud Claims Department to report our findings, request reimbursement of the charges, and to place an alert of the account. In addition, Ms. Voundy-Thomas and Mr. Merrick, Hughes, BOD President, visited a Wells Fargo branch to discuss this matter directly with an Account Representative. Unfortunately, the bank denied our request for reimbursement of the fraudulent charges stating that our claim was not processed within 30-days of the posted charges. Actions Planned: Per the guidance from the Maryland Banking Commission, our office has contacted the Office of the Comptroller of Currency to further pursue reimbursement of the fraudulent charges. Also, upon completion and submission of the above-mentioned audit, we plan to pursue any further actions recommended by our HUD Account Executive regarding this finding. Status of Corrective Action on Prior Findings No prior findings were noted.

View Audit 350209 Questioned Costs: $1

Finding 540329 (2024-003)

None 2024

Cornell University

NY

Reporting Matching / Level of Effort / Earmarking § 200.329

Finding Number: 2024 – 003 – Reporting Grantor: Department of Labor (DOL)-Office of Disability Employment Policy (ODEP) Program Name: Disability Employment Policy Development Award Name: Disability Employment Policy Development Award Number: 23475OD000001-01-00 (passthrough ID 24-SA-053-3203) Assist...

Finding Number: 2024 – 003 – Reporting Grantor: Department of Labor (DOL)-Office of Disability Employment Policy (ODEP) Program Name: Disability Employment Policy Development Award Name: Disability Employment Policy Development Award Number: 23475OD000001-01-00 (passthrough ID 24-SA-053-3203) Assistance Listing Titles: Disability Employment Policy Development Assistance Listing Numbers: 17.720 Award Year: Fiscal Year 2024 Passthrough Entity: The Council of State Governments Corrective Action Plan: Cornell acknowledges that performance reports for this award were not filed timely. To address this omission the university will reinforce the importance of timely reporting during routine training and update sessions in the coming year and remind departments that these requirements are stated in the award documents and the research administration system. Responsible individual: Mary-Margaret Klempa, Senior Director, Office of Sponsored Programs

View Audit 350193

Finding 540327 (2024-002)

None 2024

Cornell University

NY

Student Financial Aid Matching / Level of Effort / Earmarking

Finding Number: 2024 – 002 – Notification prior to disbursement of Title IV funds Grantor: Department of Education Program Name: Student Financial Assistance Cluster Award Name: Federal Pell Grant Program Award Numbers: not applicable Assistance Listing Titles: Federal Pell Grant Program Assistance ...

Finding Number: 2024 – 002 – Notification prior to disbursement of Title IV funds Grantor: Department of Education Program Name: Student Financial Assistance Cluster Award Name: Federal Pell Grant Program Award Numbers: not applicable Assistance Listing Titles: Federal Pell Grant Program Assistance Listing Numbers: 84.063 Award Year: Fiscal Year 2024 Passthrough Entity: various Corrective Action Plan: Cornell acknowledges that Title IV financial aid was disbursed before a student received their official aid offer due to a manual processing error. To prevent this issue in the future, Cornell implemented a new Peoplesoft system control called a “user edit message” in August 2024. • The new user edit message prevents Title IV and other financial aid disbursements until the system has generated and sent an official aid offer in August 2024. • The new user edit message is assigned (and cleared, when appropriate) via batch system processes that run prior to daily disbursement processes. • On-demand queries were also developed to monitor performance of the control as well as to proactively identify and address any currently unknown circumstances that may result in similar outcomes. • The new controls were implemented in all currently active aid years and will remain as standard controls in future years. Responsible individual: Kevin J. Jensen, Executive Director, Office of Financial Aid and Student Employment

View Audit 350193

Finding 539721 (2024-001)

None 2024

Cornell University

NY

Allowable Costs / Cost Principles § 200.334

Finding Number: 2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Program Name: Research and Development Cluster Award Name: various Award Numbers: various Assistance Listing Titles: Cancer Research Manpower; ...

Finding Number: 2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Program Name: Research and Development Cluster Award Name: various Award Numbers: various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Numbers: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: Fiscal Year 2024 Passthrough Entity: various Corrective Action Plan: Weill Cornell Medicine (WCM) acknowledges that it was unable to readily produce supporting documentation and justifications for certain cost transfers. The university will review its cost transfer policies and procedures by September 30, 2025. Updates to the policy and procedures will be communicated to the respective campuses and incorporated into ongoing training by December 31, 2025. In addition, the need to maintain comprehensive documentation for cost transfers in a readily accessible repository will be considered as future systems are implemented. Responsible individual: Melissa Paray, Director, Grants and Contract Accounting, Weill Cornell Medicine

View Audit 350193

Finding 539714 (2024-012)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Reporting Significant Deficiency

Finding Reference: 2024-012 - SFA Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has established a formalized procedure, effective immediately, to ensure the accurac...

Finding Reference: 2024-012 - SFA Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has established a formalized procedure, effective immediately, to ensure the accuracy and compliance of the annual Fiscal Operations Report and Application to Participate (FISAP). As part of this process, a FISAP Review Committee will be created to oversee the review of the FISAP and all supporting documentation at least three weeks before the official submission deadline. The FISAP will be prepared by the Executive Director of Student Financial Aid Services and Scholarships, who will also gather and compile all necessary supporting documentation. This completed report, along with all relevant data, will then be submitted to the FISAP Review Committee for thorough examination. The committee will verify the accuracy of all figures and ensure that the supporting documents meet FISAP compliance requirements. Submission of the FISAP will only proceed once the FISAP Review Committee has reached a consensus confirming the accuracy and completeness of the report. This structured review process will help safeguard against errors, enhance compliance, and ensure that JSU meets all federal reporting standards. Estimated Completion Date: September 1, 2025

View Audit 350191

Finding 539713 (2024-011)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Allowable Costs / Cost Principles HUD Housing Programs Significant Deficiency § 200.1 § 200.302 § 200.307

Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of ...

Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of the program. UMMC will make efforts to ensure that all practices and policies are clearly documented and evaluated periodically. Estimated Completion Date: June 30, 2025

View Audit 350191

Finding 539689 (2024-007)

None 2024

State of Mississippi Institutions of Higher Learning

MS

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Finding Reference: 2024-007 - SFA Eligibility (ASU) Responsible Official: Juanita Edwards, Director of Financial Aid Corrective Action Planned: ASU disburses aid to students’ accounts once the student has completed registration. The student was enrolled and eligible for the Pell grant. The student h...

Finding Reference: 2024-007 - SFA Eligibility (ASU) Responsible Official: Juanita Edwards, Director of Financial Aid Corrective Action Planned: ASU disburses aid to students’ accounts once the student has completed registration. The student was enrolled and eligible for the Pell grant. The student had not completed registration, so Pell was not disbursed. Moving forward ASU will review all student accounts to ensure students have completed the registration process. If they have not completed registration timely, they will be notified. Once notified and registration is complete, Title IV funds will be disbursed to the students’ accounts. Checks and balances have been reviewed and implemented to ensure the process is completed timely. Estimated Completion Date: June 30, 2025

View Audit 350191 Questioned Costs: $1

Finding 539687 (2024-005)

Material Weakness 2024

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Material Weakness Reporting

Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (ASU) Responsible Official: Kisha Bond, Registrar Corrective Action Planned: ASU must report enrollment status for students in the NSLDS database within a 60-day window. ASU reported the enrollment status for the ...

Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (ASU) Responsible Official: Kisha Bond, Registrar Corrective Action Planned: ASU must report enrollment status for students in the NSLDS database within a 60-day window. ASU reported the enrollment status for the students but not within 60 days. Moving forward, ASU will monitor the activity for the NSLDS database and submit student enrollment data on a timely basis. Estimated Completion Date: August 29, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (JSU) Responsible Official: Ms. Lakesha Tubbs, Registrar Corrective Action Planned: Jackson State University will implement a multi-tiered enrollment reporting schedule to enhance accuracy and prevent certification and enrollment reporting errors. Effective immediately, JSU will submit an initial enrollment reporting file to the National Student Clearinghouse at the beginning of each term. Additionally, two subsequent enrollment reports will be submitted—one at midterm and another within ten (10) days of final grade publication at the end of the term. To ensure consistency, transparency, and alignment across university departments, JSU will establish an Enrollment Reporting Oversight Committee composed of representatives from key university offices. This committee will convene quarterly throughout the academic year to review enrollment reporting processes, address potential discrepancies, and implement best practices. By fostering collaboration amongst stakeholders, JSU will ensure compliance, accuracy, and efficiency in enrollment reporting. Estimated Completion Date: May 9, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (MSU) Responsible Official: Emily Shaw, University Registrar Corrective Action Planned: In addition to reporting in a timely manner to National Student Clearinghouse, MSU will also begin to monitor NSC’s reports to NSLDS. Estimated Completion Date: June 15, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (MVSU) Responsible Official: Jeffrey Loggins, Director of Student Records Corrective Action Planned: The Office of Student Records will review the schedule submission dates for enrollment reporting to the National Student Clearinghouse to ensure compliance with certifying student enrollment within 60-day timeframe from program enrollment effective date. Additionally, enrollment reporting data will be carefully reviewed in an effort to avoid future enrollment errors. Moreover, this may include adding an additional date to report enrollment data during semesters. Estimated Completion Date: February 15, 2026 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (UMMC) Responsible Official: Emily Cole, Executive Director Office of Enrollment Management Corrective Action Planned: As an internal control measure, the Office of Enrollment Management has identified two individuals to verify all enrollment changes are appropriately captured in the National Student Loan Data System (NSLDS) within the 60-day time period. The Senior Record Specialist and Senior Enrollment Data Specialist will review pertinent records in the NSLDS monthly to verify all information has been correctly conveyed from the National Student Clearinghouse System. Estimated Completion Date: Effective immediately

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Finding 539685 (2024-003)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

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

Finding Reference: 2024-003 - SFA COD Reporting (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU reconciles Pell and federal direct student loans to COD monthly. The reconciliation is done timely, and ASU will continue to reconcile and pr...

Finding Reference: 2024-003 - SFA COD Reporting (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU reconciles Pell and federal direct student loans to COD monthly. The reconciliation is done timely, and ASU will continue to reconcile and provide evidence of review. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships; Ms. Lakesha Tubbs, Registrar; Adrienne Walls, Bursar Corrective Action Planned: In previous years, Jackson State University has extended the purge and registration dates to better serve a high number of students from underrepresented communities and low-income backgrounds, ensuring that they have the opportunity to complete the enrollment process. However, this practice has led to inaccurate reporting of enrollment dates. Moving forward, Jackson State University will work with new, continuing, and readmit students beginning in April 2025 through the start of the Fall 2025 semester on August 18, 2025, to ensure all enrollment materials are completed before the beginning of each term. As part of this effort, Jackson State University has redesigned its new student orientation process with the goal of ensuring students are completely registered before arriving on campus for the fall semester. Within this new model, a dedicated position has been created for First-Time Freshmen to establish proactive outreach and education regarding costs to students and families. The redesigned orientation process places a strong emphasis on First-Time Freshmen, guaranteeing they receive the necessary guidance and support to successfully transition into college life. Additionally, the university will enforce enrollment deadline dates to prevent inaccurate enrollment data and eliminate errors in disbursement records. In addition to enhancing the student enrollment process, JSU is also taking steps to strengthen financial accountability. Furthermore, Jackson State University’s Financial Aid Office, in coordination with its Business Office, will begin holding regularly scheduled reconciliation meetings at the end of each month. These meetings will ensure that the amounts disbursed on both sides align and that figures from both departments match what has been drawn down and either paid out or returned to the U.S. Department of Education Common Origination and Disbursement (COD). Both departments will also utilize an institutional reconciliation document to add another layer of control and prevent errors. These strategic improvements reflect Jackson State University’s ongoing commitment to compliance, operational efficiency, and student success. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The internal control procedures will initiate a reconciliation of disbursement dates against COD data. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (UMMC) Responsible Official: Davita Weary, Director of Student Financial Aid Corrective Action Planned: Reconciliations will be reviewed with Kelly Dismuke, Director of Finance Operations, on a monthly basis. Estimated Completion Date: March 26, 2025 Finding Reference: 2024-003 - SFA COD Reporting (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: USM reconciles Pell and DL monthly. Copies of reconciliations are saved in a shared drive and can be made available upon request. The reconciliations will be reviewed on a monthly basis by the Financial Aid Assistant Director (Alanna McDonald) and Director (David Williamson), and the Bursar (Barbara Madison) when necessary. Estimated Completion Date: March 17, 2025

View Audit 350191

Finding 539678 (2024-008)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: The Jackson State University Division of Financial Aid has implemented a co...

Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: The Jackson State University Division of Financial Aid has implemented a comprehensive training initiative to strengthen compliance, improve accuracy, and enhance staff proficiency in federal student aid verification. As of May 7, 2024, ongoing training has commenced for all financial aid staff on the 2024-2025 verification process and required documentation. Additionally, beginning April 4, 2025, the department will launch continuous training on verification procedures and Federal Student Aid compliance to ensure staff remains informed of regulatory updates and best practices. To further enhance accuracy and accountability, the department will collaborate with the Department of Information Technology (IT) to develop internal error reports that proactively identify discrepancies in student records. An internal checklist will also be implemented to ensure that each student selected for verification by the U.S. Department of Education has submitted all required documentation. This checklist must be reviewed and signed off by the Executive Director of Student Financial Aid Services and Scholarships before final processing. As part of the department’s transition to a more automated verification process, JSU will integrate Campus-Logic, powered by Ellucian, to streamline operations and reduce manual errors. Comprehensive training sessions will be conducted to ensure financial aid staff are proficient in using the platform. Additionally, an internal checklist within Campus-Logic will be established to facilitate structured review and compliance tracking. A final verification review will be conducted by the Executive Director of Student Financial Aid Services and Scholarships to uphold accuracy and federal compliance, ultimately mitigating errors and improving audit outcomes. Estimated Completion Date: December 19, 2025 Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The verification process will ensure all student data is accurate and corrected by staff. Estimated Completion Date: September 30, 2025

View Audit 350191

Finding 539677 (2024-006)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

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

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver ...

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver credit balance to students. The contract with the servicer should have been uploaded to the Dept of Ed database. Since the audit finding, the contract has been uploaded. ASU will upload the contract timely going forward. Estimated Completion Date: Effective Immediately Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (MVSU) Responsible Official: Mrs. Brittney Manuel-Carpenter, Account Receivable Supervisor Corrective Action Planned: MVSU acknowledged the findings of reference 2024-06 SFA-Special Test- Using a Servicer to Deliver Title IV Credit Balances. MVSU acknowledges that the servicer contract is uploaded to the Department of Education database and is available for viewing. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: University will contact the Department of Education Cash Management to correct the URL link. While the link was broken on the Cash Management site it was active on the USM Business Services website: https://www.usm.edu/business-services/refunds.php and is continually maintained on their site. Estimated Completion Date: April 1, 2025

View Audit 350191

Finding 539676 (2024-004)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

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

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that...

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that addresses all 7 required elements of the GLBA regulations: • Review GLBA Requirements: Conduct a thorough review of the Gramm-Leach-Bliley Act (GLBA) regulations to understand the 7 required elements. - Completed • Gap Analysis: A gap analysis has been performed to identify missing elements in the current information security program. - Completed • Program Development: Develop and implement policies and procedures to address the identified gaps. This includes administrative, technical, and physical safeguards. - In Progress • Training: Provide training to staff on the new policies and procedures to ensure compliance and proper implementation. - Planning • vCISO Support: Leverage the expertise of the newly hired virtual Chief Information Security Officer (vCISO) to guide the development and implementation of the information security program. - In Progress 2. Conduct a Comprehensive Risk Assessment to identify and address significant gaps in the risk assessment process: • Risk Assessment Framework: Establish a risk assessment framework that aligns with GLBA requirements. - In Progress • Identify Risks: Identify potential risks to the confidentiality, integrity, and availability of customer information. – In Progress • Evaluate Controls: Assess the effectiveness of existing controls and identify areas for improvement. – In Progress • Mitigation Plan: Develop a risk mitigation plan to address identified vulnerabilities and implement appropriate controls. - Planning • vCISO Support: Utilize the vCISO's expertise to ensure a thorough and effective risk assessment process. – In Progress 3. Monitoring and Continuous Improvement to ensure ongoing compliance and continuous improvement of the information security program: • Regular Audits: Conduct regular audits to ensure compliance with GLBA regulations and the effectiveness of the information security program. – Planning • Feedback Mechanism: Establish a feedback mechanism to gather input from staff and stakeholders on the effectiveness of the program. - Planning • Update Policies: Periodically review and update policies and procedures to address emerging threats and changes in regulations. – In Progress • vCISO Support: Engage the vCISO in monitoring and continuous improvement efforts to maintain high standards of information security. – In Progress 4. Reporting and Accountability to ensure accountability and transparency in the implementation of the corrective action plan: • Assign Responsibility: Assign responsibility for the implementation of the corrective action plan to a dedicated team or individual. - Planning • Progress Reports: Provide regular progress reports to senior management and stakeholders on the implementation of the corrective action plan. - Planning • Documentation: Maintain thorough documentation of all actions taken to address the identified issues. - Planning • vCISO Support: Include the vCISO in reporting and accountability processes to ensure expert oversight and guidance. – In Progress By following this corrective action plan and leveraging the expertise of the vCISO, MVSU can address the deficiencies in its information security program and risk assessment process, ensuring compliance with GLBA regulations and protecting customer information effectively. Estimated Completion Date: November 30, 2025

View Audit 350191

Finding 539675 (2024-002)

Material Weakness 2024

State of Mississippi Institutions of Higher Learning

MS

Questioned Costs Student Financial Aid Special Tests & Provisions

Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU will ensure that post withdrawal aid that could have been disbursed will be disbursed timely unless...

Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU will ensure that post withdrawal aid that could have been disbursed will be disbursed timely unless the student requests otherwise. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has examined the error and has implemented targeted training on the Return of Title IV (R2T4) process. This training focuses on accurately determining break days and performing the required calculations to ensure precision and compliance. To reinforce these efforts, the university will continue to provide quarterly training and cross-training opportunities for staff, ensuring a comprehensive understanding of R2T4 policies and procedures. To further strengthen accuracy, an additional internal review process has been established within the financial aid office. This review will be conducted by the Executive Director of Financial Aid, who will oversee calculations until the responsibility is designated to another team member with demonstrated expertise in R2T4 processing. These corrective measures will enhance the accuracy of R2T4 calculations, ensure compliance with federal regulations, and improve overall financial aid operations at Jackson State University. Estimated Completion Date: May 2, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (MSU) Responsible Official: Lori Ball Executive Director for Financial Aid and Scholarship Corrective Action Planned: Our interpretation of the regulation was that if classes were held on weekends before or after the 5-day break, the weekend days were not counted, only the week itself (Monday- Friday) and the weekend afterwards. Classes started back the next Monday so we used 7 days. If we do not have classes on Saturday before spring break, we are now counting 9 days. Estimated Completion Date: March 15, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The internal control procedures have been updated to incorporate a nine-day break. The refund of funds to the Department of Education will be processed upon completion of the necessary calculations. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (UM) Responsible Official: Mr. Eduardo Prieto, Vice Chancellor for Enrollment Management Corrective Action Planned: The University of Mississippi’s Office of Financial Aid has an existing process for next-level supervisor review of all Return of Title IV (R2T4) calculations. To further strengthen compliance, future R2T4 reviews will also include any documentation used to determine the date of withdrawal. While it is believed that communication with instructors was accurate, messaging will be refined to clarify which activities cannot be used to document academic engagement (e.g., simply logging into the online system). Additional scrutiny will be applied when determining the last date of attendance for online courses, and instructors will be contacted for clarification as needed. The Office of Financial Aid has also established a unit to enhance compliance through internal reviews of various processes, including R2T4. Although not all R2T4 calculations will be selected for examination, sample evaluations will provide an additional level of oversight. Additionally, a transition to Ellucian’s Banner system is planned for the 2026-2027 academic year, requiring instructors to report the last date of attendance for all F grades at the time of grade entry. This change will help minimize ambiguity regarding unofficial withdrawals. Estimated Completion Date: April 1, 2025 Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (UMMC) Responsible Official: Coralisa Williams, Senior Financial Aid Advisor Corrective Action Planned: Processing procedure has been updated to state the use of the “last date in class” from the academic calendar published in the UMMC Bulletin to ensure consistent and correct processing of R2T4. Estimated Completion Date: Effective immediately (has reviewed current R2T4 for accuracy) Finding Reference: 2024-002 - SFA Special Tests and Provisions - Return of Title IV Funds (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: The university included the Friday commencement day as last day of the term. Our reasoning is that some students are still completing assignments, tests, and class projects through the day of commencement. The financial aid office will verify the number of class days with the registrar office before each semester to ensure all class days are included in the award period. The student with the possible post-withdrawal disbursement withdrew prior to our census and all institutional charges were reversed and we could not verify that the student actually attended any of their classes. Effective February 3, 2025, institutions are exempt from performing an R2T4 calculation in this situation. Amend § 668.22(a)(2)(ii)(A)(6) to exempt institutions from performing an R2T4 calculation if: (1) a student is treated as never having begun attendance; (2) the institution returns all title IV, HEA assistance disbursed to the student for that payment period or period of enrollment; (3) the institution refunds all institutional charges to the student for that payment period or period of enrollment; and (4) the institution writes off or cancels any payment period or period of enrollment balance owed by the student to the institution due to the institution's returning of title IV, HEA funds to the Department. Going forward, USM intends to not perform R2T4 calculations for students that meet one of the above exemptions. Other possible post withdrawal disbursement will be tracked, and communication will be sent to students eligible once they are identified and calculated upon withdrawal. Estimated Completion Date: March 17, 2025

View Audit 350191 Questioned Costs: $1

Finding 539670 (2024-010)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Questioned Costs Eligibility Significant Deficiency

Finding Reference: 2024-010 - Eligibility (Board Office) Responsible Official: Dr. Casey Prestwood, Associate Commissioner for Academic and Student Affairs Corrective Action Planned: An evaluation form was developed and implemented to be used with each applicant review as a checklist of requirements...

Finding Reference: 2024-010 - Eligibility (Board Office) Responsible Official: Dr. Casey Prestwood, Associate Commissioner for Academic and Student Affairs Corrective Action Planned: An evaluation form was developed and implemented to be used with each applicant review as a checklist of requirements. In addition, there is a second layer of review of all approved applicants’ eligibility prior to requesting disbursement of funds. An outside CPA firm was contracted in May 2024 to perform the second layer of review of each approved applicant before disbursement, to review all disbursement prior to that date in the current grant cycle, and to provide guidance on internal controls. An additional staff person to assist with grant awarding and programmatic operations was hired in August 2024. Estimated Completion Date: August 2024

View Audit 350191 Questioned Costs: $1

Finding 539669 (2024-009)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Subrecipient Monitoring § 200.332 § 200.501

Finding Reference: 2024-009 - Subrecipient Monitoring (UM) Responsible Official: Dr. John Higginbotham, Vice Chancellor of Research and Economic Development Corrective Action Planned: On March 13, 2025, the University of Mississippi issued amendments to notify the two subrecipients that the subawar...

Finding Reference: 2024-009 - Subrecipient Monitoring (UM) Responsible Official: Dr. John Higginbotham, Vice Chancellor of Research and Economic Development Corrective Action Planned: On March 13, 2025, the University of Mississippi issued amendments to notify the two subrecipients that the subawards issued under ALN 95.010 during the fiscal year ended June 30, 2024, were not classified as research and development. The University of Mississippi will ensure that subaward agreements, including all attachments, are reviewed for accuracy by a second party before issuance. Estimated Completion Date: March 13, 2025 Finding Reference: 2024-009 - Subrecipient Monitoring (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Similar to UMMC’s response on Finding Reference 2024-001, UMMC engaged with a Workday certified consulting firm to review the operational effectiveness of the configuration of Workday, review reports available, and assess processes and procedures. As part of the engagement, this firm also evaluated various operational processes within the contract and grants office. The engagement began in June of 2024 and has made significant changes to Workday to bring operational efficiency into our processes and configurations; as well as, developed reports that identify variances and differences that need to be researched and corrected. The team also corrected reports that were pulling data inaccurately and trained internal UMMC IT staff on how to address system corrections going forward and the methodology to develop/modify IT reports. The firm also revamped our award setup process in Workday and built checklists along with Standard Operating Procedures that bring efficiencies and accuracy into our Award setup process. We also built in roles for review of an award at the time of setup to ensure that errors are quickly identified and corrected in the system. The firm also provided Workday training sessions to help us understand how the different fields are supposed to be utilized, especially in cases where UMMC is either a subrecipient or has a subaward with a different institution. Estimated Completion Date: June 30, 2025

View Audit 350191

Finding 539652 (2024-001)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Subrecipient Monitoring Reporting Student Financial Aid § 200.502

Finding Reference: 2024-001 - SEFA Reporting (ASU) Responsible Official: Sabrena Johnson, Director of Grants and Contracts Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $298,151 from the Mississippi Department...

Finding Reference: 2024-001 - SEFA Reporting (ASU) Responsible Official: Sabrena Johnson, Director of Grants and Contracts Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $298,151 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, Alcorn State University has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: May 31, 2025 Finding Reference: 2024-001 - SEFA Reporting (DSU) Responsible Official: Jacnita Robinson, Grant Accountant Corrective Action Planned: Delta State University acknowledges the audit finding related to errors in the Schedule of Expenditures of Federal Awards (SEFA) reporting. The federal award in question was not intentionally omitted from the SEFA. At the time of SEFA preparation, Delta State University believed the award would be reported on the Mississippi Department of Finance and Administration’s SEFA, as they were identified as the recipient of the award. The University’s intention was to prevent the duplication of expenditures and avoid double-booking the same federal funds on both SEFAs. To prevent this type of error in the future, Delta State University will review and revise its internal controls and procedures for identifying and classifying federal awards. Additional training will be provided to the staff responsible for award set-up and SEFA reporting to ensure proper classification and communication with state agencies regarding the reporting responsibilities for pass-through and beneficiary awards. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (JSU) Responsible Official: Dr. Almesha Campbell, Vice President for Research and Economic Development Corrective Action Planned: Jackson State University will follow the procedures outlined for preparing the Schedule of Expenditures of Federal Awards. Such procedures include, but are not limited to the following: • Verify the ALN provided on the award documents and cover page and then enter it in Banner during the award set-up process. In addition, review the ALNs for continuation awards. If errors are identified during this process, they will be corrected. • Review previous year’s SEFA report and data support to ensure the report is in the format requested by IHL • Correspond with the Division of Business and Finance to include additional expenditures. Currently, the expenditures to include are 1) Direct Loans, 2) Expenditures with ALN 21.027, and 3) Perkins Loans Expenditures • The Director for Fiscal Reporting and Compliance will complete a subsequent review after the Director for Grants and Contracts prepares the report for submission. Furthermore, the newly created Oversight Committee will review the SEFA before submission to ensure that the Federal Perkins Loan program expenditures are included on the SEFA. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (MUW) Responsible Official: Rachel Sudduth, Assistant Director of University Accounting Corrective Action Planned: University Accounting will review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified, this would also include federal expenditures made through Mississippi Bureau of Buildings. Estimated Completion Date: March 21, 2025 Finding Reference: 2024-001 - SEFA Reporting (MVSU) Responsible Official: Mr. Samuel Melton, Director of Sponsored Programs/Title III Corrective Action Planned: Mississippi Valley State University will ensure that federal awards are correctly coded when preparing the Schedule of Expenditures of Federal Awards using the following procedures: • The Office of Business and Finance and Office of Sponsored Programs will verify the ALN provided on the award documents provided by the sponsor (i.e., federal agency and/or pass-through entity). If errors are identified during this process, they will be corrected. • The Director of Accounting will complete a subsequent review after the designated Staff Accountant prepares the report for submission. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (UM) Responsible Official: Dr. Steven G. Holley, Vice Chancellor for Administration and Finance Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024, was revised to include $131,454 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN 21.027. Additionally, the University of Mississippi has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 30, 2024 Finding Reference: 2024-001 - SEFA Reporting (USM) Responsible Official: Andrea Phillips, Controller Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $597,135 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, USM has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 23, 2024 Finding Reference: 2024-001 - SEFA Reporting (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: UMMC engaged with a Workday certified consulting firm to review the operational effectiveness of the configuration of Workday, review reports available, and assess processes and procedures. As part of the engagement, this firm also evaluated various operational processes within the contract and grants office. The engagement began in June of 2024 and has made significant changes to Workday to bring operational efficiency into our processes and configurations; as well as, developed reports that identify variances and differences that need to be researched and corrected. The team also corrected reports that were pulling data inaccurately and trained internal UMMC IT staff on how to address system corrections going forward and the methodology to develop/modify IT reports. The firm also revamped our award setup process in Workday and built checklists along with Standard Operating Procedures that bring efficiencies and accuracy into our Award setup process. We also built in roles for review of an award at the time of setup to ensure that errors are quickly identified and corrected in the system. Estimated Completion Date: June 30, 2025

View Audit 350191

Finding 539649 (2024-004)

Significant Deficiency 2024

Municipality of Florida

PR

Subrecipient Monitoring Reporting

The Municipality will establish additional procedures to maintain the schedule of the required reports in order to avoid this situation.

View Audit 350185

Finding 539647 (2024-003)

Significant Deficiency 2024

Municipality of Florida

PR

Subrecipient Monitoring Reporting § 200.328

The Municipality will establish additional procedures to maintain the schedule of the required reports in order to avoid this situation.

View Audit 350185

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