Corrective Action Plans

Finding 524723 (2024-004)

Material Weakness 2024

MI

HUD Housing Programs Material Weakness

Condition: The Commission did not conduct an annual review of utility data to ensure that the utility allowance schedule was properly updated. Planned Corrective Action: Contract has been issued to conduct utility allowance which is underway. DHC is expecting for allowance study implementation in Ju...

Condition: The Commission did not conduct an annual review of utility data to ensure that the utility allowance schedule was properly updated. Planned Corrective Action: Contract has been issued to conduct utility allowance which is underway. DHC is expecting for allowance study implementation in June 2025. Contact person responsible for corrective action: Felicia Burris, HCV Program Director Anticipated Completion Date: 6/30/2025

View Audit 344146

Finding 524720 (2024-003)

Significant Deficiency 2024

Detroit Housing Commission

MI

Questioned Costs HUD Housing Programs Significant Deficiency

Condition: The Commission did not complete fiscal year 2024 recertifications. Planned Corrective Action: Annual Delinquent Recertifications are being addressed according to HUD policy. Rent Calc training has been provided and passed by all staff. We certify and maintain it will be our standard opera...

Condition: The Commission did not complete fiscal year 2024 recertifications. Planned Corrective Action: Annual Delinquent Recertifications are being addressed according to HUD policy. Rent Calc training has been provided and passed by all staff. We certify and maintain it will be our standard operating procedure to ensure compliance with HUD policies. We will continue to mitigate PIC errors and ensure continued staff training to reduce these errors. HCV Manager, will randomly review 10% of files for accuracy. A list will be maintained. As of February 17, 2025, HUD’s Recertification score was 99.7% in compliance. Contact person responsible for corrective action: Felicia Burris, HCV Program Director Anticipated Completion Date: 6/30/2025

View Audit 344146 Questioned Costs: $1

Finding 524717 (2024-002)

Significant Deficiency 2024

Detroit Housing Commission

MI

HUD Housing Programs Subrecipient Monitoring Significant Deficiency

Condition: The Commission was not able to provide support the the units that had HQS deficiencies were corrected timely and the Commission did not abate the Housing Assistance Payments (HAP) for units that failed HQS Inspections. Planned Corrective Action: Contractor has been selected, and trained i...

Condition: The Commission was not able to provide support the the units that had HQS deficiencies were corrected timely and the Commission did not abate the Housing Assistance Payments (HAP) for units that failed HQS Inspections. Planned Corrective Action: Contractor has been selected, and trained in Yardi Systems. The Landlord liaison Supervisor will work closely with the new contractor to ensure abatements are conducted timely and in compliance with Program regulatory requirements. The Landlord liaison Supervisor along with Yardi monitoring will conduct 10% Quality Control reviews to ensure contractor is following HUD compliance guidelines as it pertains to abatement activity. Contact person responsible for corrective action: Felicia Burris, HCV Program Director Anticipated Completion Date: 6/30/2025

View Audit 344146

Finding 524713 (2024-001)

Significant Deficiency 2024

Norwich University

VT

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

Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response t...

Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The errors noted in the finding resulted from a missing step in the reconciliation process. Until recently the Registrar’s office relied on an error report from NSC to help identify any issues that might be noted in the student files. The findings noted, reenforced that this process alone was not sufficient to capture all errors. To ensure that these types of errors do not reoccur, subsequently, the registrars office team has initiated an additional monthly reconciliation between the NSLDS and internal student management system. This reconciliation will show any status variance or date mismatches. Any variances noted will be updated in the NSC/NSLDS system. Name(s) of the contact person(s) responsible for corrective action: Sarah Harris, Director, Office of Financial Aid Planned completion date for corrective action plan: December 2024

View Audit 344144

Finding 524706 (2024-002)

Significant Deficiency 2024

Housing and Redevelopment Authority of Austin

MN

Questioned Costs Cash Management Internal Control / Segregation of Duties

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Complia...

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Recommendation: We recommend that the HRA continue to evaluate their procedures and controls in place over the draw down of funds. Management’s Response: Management agrees with the finding and will continue to monitor the draws to ensure they are spent within the required timeframe. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will ensure that all draws of funds are spent within the required timeframe. Official Responsible for Ensuring CAP: Angela Maiden, Finance Director, is the official responsible for ensuring corrective action of the deficiency. Planned Completion Date for CAP: September 30, 2025 Plan to Monitor Completion of CAP: Taggert Medgaarden, Executive Director, will ensure that the draw downs are properly managed through discussions with the Finance Director.

View Audit 344136 Questioned Costs: $1

Finding 524703 (2024-001)

Significant Deficiency 2024

Abbotsford Housing Authority

WI

Internal Control / Segregation of Duties Reporting

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongo...

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing

View Audit 344133

Finding 524699 (2024-001)

Significant Deficiency 2024

Utica University

NY

The University has drafted a comprehensive written information security program to address the minimum requirements for compliance with GLBA, including the following: -The University has drafted a formal data security and privacy training policy for faculty and staff to be incorporated within the co...

The University has drafted a comprehensive written information security program to address the minimum requirements for compliance with GLBA, including the following: -The University has drafted a formal data security and privacy training policy for faculty and staff to be incorporated within the comprehensive written information security program. This is in addition to the mandatory annual security and privacy training for all faculty and staff, as directed through the employee handbook. -The University has drafted a vendor management policy to ensure thirdparty providers maintain appropriate safeguards for customer information. - The University has also drafted a change and patch management policy. A dedicated team from the Integrated Information Technology Services department will oversee the development and implementation of the above policies to ensure compliance with GLBA and the protection of sensitive student data. The University has completed a draft of a comprehensive written information security program to address the minimum requirements noted above. TheUniversity plans to have the comprehensive written information plan reviewed and finalized by February 28, 2025.

View Audit 344132

Finding 524695 (2024-001)

None 2024

Wilkes University

PA

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

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed a...

Management agrees with the finding and recommendation. The University will implement a process that ensures notification from the Registrar when a student drops from any course or from the University. A review of R2T4 will be completed at that time if deemed necessary. The process will be reviewed annually by the University to ensure compliance.

View Audit 344126

Finding 524684 (2024-002)

Significant Deficiency 2024

Texas Association for the Education of Young Children, Inc.

TX

Allowable Costs / Cost Principles

Management Response: The variance from the cost allocation is related to rounding errors as a result of the sum of the allocation percentages adding up to slightly over 100 percent. This is due to rounding errors when utilizing formula functions within Microsoft Excel. Additionally, when applying t...

Management Response: The variance from the cost allocation is related to rounding errors as a result of the sum of the allocation percentages adding up to slightly over 100 percent. This is due to rounding errors when utilizing formula functions within Microsoft Excel. Additionally, when applying the allocation percentages to a shared expenses, the resulting amounts do not always add up to the exact amount of the expenses. Typically, the resulting cautions produce an error within less than $5 and/or less than 1% of the total expense. TXAEYC staff manually adjust the allocated expenses to add up to the total expense. To remedy this from happening in the future, if any rounding issues produce a difference in the total expenses allocated, the difference will be allocated to the organization’s operating expense class rather than a class associated with a government grant. The following language will be added to the TXAEYC Accounting Manual: “Allocations percentages should be rounded to two decimal places (example 3.21%). If the total of percentages does not fully equal 100 percent, the difference should be added to the allocation percentage assigned to TXAEYC operating expenses. If the sum exceeds 100 percent, an equal amount should be attempted to be subtracted from each class associated with a government grant and added to the allocation percentage assigned to TXAEYC operating expenses. When applying the indirect cost allocations, if the total of the allocations when summed do not equal the total expense amount, the difference should be added to the allocations to TXAEYC operating expenses.” Parties Responsible and Timeline Updates to the Accounting Manual will be approved by TXAEYC’s Finance Committee and Governing board by April 30, 2025.

View Audit 344111

Finding 524683 (2024-001)

Significant Deficiency 2024

Texas Association for the Education of Young Children, Inc.

TX

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting

Management Response: TXAEYC’s Payroll Processing section of the Accounting Manual will be updated to reflect the following changes: “Direct supervisors will review and approve their direct reports’ timesheets to ensure time is accurately recorded and all hours worked are assigned a cost allocation...

Management Response: TXAEYC’s Payroll Processing section of the Accounting Manual will be updated to reflect the following changes: “Direct supervisors will review and approve their direct reports’ timesheets to ensure time is accurately recorded and all hours worked are assigned a cost allocation. The Director of Operations conducts a second layer of approval for all employee timesheets and processes payroll via the payroll platform. The Director of Operations may not process payroll without ensuring Supervisor Approval has been entered for all timesheets within the payroll platform. Additionally, the Director of Operation shall approve the timesheet of the Executive Director/Chief Executive Officer.” Parties Responsible and Timeline Updates to the Accounting Manual will be approved by TXAEYC’s Finance Committee and Governing board by April 30, 2025. The Director of Operation will implement changes to approved by the Finance Committee and Governing Committee immediately following their approval.

View Audit 344111

Finding 524679 (2024-004)

Significant Deficiency 2024

La Salle University

PA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster-Assistance Listing No. 84.0007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Explanati...

Student Financial Assistance Cluster-Assistance Listing No. 84.0007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding : La Salle University will identify outstanding not cashed checks for each term. A term is normally 4 months in total as each semester generates a list of uncashed checks. Within two weeks of establishing outstanding checks, we will send letters to students informing them that they have outstanding refund checks. For approximately six months, the process of reviewing the outstanding list repeats, and if a check has not been cashed, another letter of notice is mailed. After six months, finance will send the outstanding list to Student Financial Services for a 30-day final review/outreach. At 21 O days from original refund issuance, Finance will provide the list to Financial Aid who will return balances to DOE. Name(s) of the contact person(s) responsible for corrective action: Zak Thornton, Assistant Vice President of Finance Planned completion date for corrective action plan: Corrected as of Spring 2025.

View Audit 344109 Questioned Costs: $1

Finding 524678 (2024-003)

Significant Deficiency 2024

La Salle University

PA

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

Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action tak...

Student Financial Assistance Cluster - Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have contracted with RPK, a leading higher educating consulting firm who has been assisting us with examining our systems, practices, policies, and procedures. We have reorganized the student accounts receivable functions into a seamless student financial service and created a student financial operations backend where all database maintenance, automation, processing, and audits are being coordinated by a team separate from those servicing students directly. We have replaced all ineffective staff members including those who oversaw the record keeping process based on the support and recommendations of RPK, and are completing audits of all files, current and past, in a manual review of all cabinets to correctly alphabetize and organize. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President, Student Financial Services Planned completion date for corrective action plan: Summer 2025

View Audit 344109

Finding 524677 (2024-002)

Significant Deficiency 2024

La Salle University

PA

Reporting Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordan...

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes 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 : Like many US institutions, La Salle contractually relies on the National Student Clearinghouse (NSC) to conduct its enrollment reporting to NSLDS. In order to comply with established regulations, we set up an Enrollment Reporting Submission Schedule with the NSC. La Salle's schedule for 2025 is below: Term Begin Date Term End Date Transmission Type : Schedule Transmission Date Received Date Transmission Status 1/ 13/ 2025 5/ 9/ 2025 F rst of Term 1/ 31/ 2025 1/ 31 /2 25 Edtts Comp eted 1/13/ 2025 5/9/2025 Subsequent of - erm 2/ 17/ 2025 Not Yet Rece ed 1/ 13/ 2025 5/ 9/ 2025 Subsequent of Term 3/ 17/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5/ 9/ 2 25 Subsequent of-erm t./ 15/ 2025 Not Yet Rece'ved 1/ 13/ 2025 5_/9/ 2025 Subsequent of -e,m 5/ 20/ 2025 Not Yet Rece v ed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er F,r;.: 6/ 3/ 2025 Not Yet Rece ved 5/ 19/ 2025 8/ 22/2025 Summer Subsequent 7/ 9/ 2025 Not Yet Recewed 5/ 19/ 2025 8/ 22/ 2025 Sumr,er Subsequent 8/ 13/ 2025 Not Yet Recev ed 8/ 25/ 2025 12/ 13/2025 F rst of Terr, 9/ 23/ 2025 Not Yet Rece'ved 8/ 25/ 2025 12/13/ 2025 Subsequent of Term 10/ 28/ 2025 Not Yet ReceiVed 8/ 25 / 2025 12/ 13/ 2::>25 Subsequent of-erm 11/ 15/ 2025 Not Yet Rece·ved 8/ 25/ 2025 12/ 13/ 2025 Subsequent of-erM 12/16/ 2025 Not vet Receved Adherence to this reporting schedule would ensure timely reporting, as the NSC subsequently transmits data monthly to NSLDS, throughout the academic year, well within the requirement to report student enrollment status at least every 60 days. Our Associate Registrar for Academic Information Systems is specifically charged with maintaining, executing, and adhering to this schedule, as part of the routine duties assigned to that position in our office. Regarding accuracy, data structures are defined in our BANNER database to classify a given student's enrollment status in a given semester as full, three-quarter, half, or less-than-half time, and withdrawn. Those structures are long-established by student level (graduate, undergrad, doctoral), and do not change from semester to semester. BANNER processes extract the registration data and its timing, in light of those definitions and the data is formatted for transmission to the NSC as prescribed. Sound data entry practices have been established to make certain dates associated with those statuses, and the transition of a student within them, are accurately recorded. Consequently, we rely on the BANNER NSC extract, and the NSC's reporting relationship with NSLDS to accurately transmit that data accordingly. The NSC does work with us to rectify or resolve any seemingly inconsistent or incorrect data, based on prior transmissions and current regulations, prior to committing the given enrollment extract to the NSC database for our institution. They help us stay in compliance and consistent on both the campus-level and program-level basis upon which we're required to report. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Fall 2024

View Audit 344109

Finding 524672 (2024-001)

Significant Deficiency 2024

La Salle University

PA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are return...

Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to ensure that there is not an instance where a student does not receive their credit balance within the required 14-day window, the disbursement scheduled has been re-configured to ensure that there are no automatic disbursements running overnight the week leading up to a university and/or federal holiday. A new financial operations team has been created within the student financial services structure to ensure that processes are running smoothly and that systems between both financial aid and the finance office are effectively communicating with each other. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt, Assistant Vice President for Student Financial Services Planned completion date for corrective action plan: Corrected as of Fall 2024.

View Audit 344109

Finding 524671 (2024-001)

Significant Deficiency 2024

Selma Housing Authority

NC

Eligibility HUD Housing Programs Reporting

Finding 2024-001 Name of Contact Person: Melody Wilkins Executive Director Corrective Action: We will implement proper internal control procedures for the Public and Indian Housing program eligibility requirements. Proposed Completion Date: Immediately

View Audit 344104

Finding 524670 (2024-004)

None 2024

Community Development Partnership

MA

Allowable Costs / Cost Principles Reporting

We are in the process of submitting the required operating budget and self certification letter to the USDA - Anticpated Completion date -March 31,2025 Kathleen Boyce ,CFAO

View Audit 344101

Finding 524666 (2024-003)

Material Weakness 2024

Community Development Partnership

MA

Allowable Costs / Cost Principles § 200.302

We continue to review and update our procedures and process to insure that all financial transactions are properly allocated to programs/ properties funded with federal funds - Anticipated Completion Date-April 30, 2025.Responsible Contact Person-Kathleen Boyce, CFAO

View Audit 344101

Finding 524665 (2024-002)

None 2024

Community Development Partnership

MA

Reporting

Once the FY 24 audit is complete we will insure that we are up to date with all required report filings. Anticipated Completion Date-April 30, 2025.Responsible Contact Person-Kathleen Boyce, CFAO

View Audit 344101

Finding 524664 (2024-001)

Material Weakness 2024

Community Development Partnership

MA

Material Weakness

Our accounting system does allow for these reports to be produced for the RD Project once we have the opening balance sheet separated by program. We are working with our Net Suite consultants to correct the historical transactions on the balance sheet to insure that all balance sheet accounts are m...

Our accounting system does allow for these reports to be produced for the RD Project once we have the opening balance sheet separated by program. We are working with our Net Suite consultants to correct the historical transactions on the balance sheet to insure that all balance sheet accounts are maintained by program.Anticipated Completion Date- April 30, 2025. Responsible Contact Person- Kathleen Boyce, CFAO

View Audit 344101

Finding 524663 (2024-002)

Material Weakness 2024

University of Southern Indiana

IN

Subrecipient Monitoring § 200.303 § 200.332 § 200.521

FINDING 2024-002 Finding Subject: PPHF Geriatric Education Centers - Subrecipient Monitoring Summary of Finding: Audit Finding 2024-002 states that the University of Southern Indiana did not establish a system of internal controls to ensure that subrecipient audit reports are received and reviewed, ...

FINDING 2024-002 Finding Subject: PPHF Geriatric Education Centers - Subrecipient Monitoring Summary of Finding: Audit Finding 2024-002 states that the University of Southern Indiana did not establish a system of internal controls to ensure that subrecipient audit reports are received and reviewed, when required, to ensure that subrecipients are properly monitored in accordance with Federal regulations. Contact Person Responsible for Corrective Action: Jina Platts, Assistant Vice President for Finance and Administration and Assistant Treasurer Contact Phone Number and Email Address: 812-465-7090; jlplatts@usi.edu Views of Responsible Officials: We concur with the finding that the University should have ensured that subrecipient audit reports were received and reviewed, when required, to ensure that subrecipients are properly monitored in accordance with Federal regulations. The University had other controls in place related to subrecipient monitoring including the review of financial reports and requests for reimbursement for subrecipient expenses. One purpose of collecting and reviewing subrecipient audit reports is to determine the level of monitoring required as high, medium, or low. Although the University treats all subrecipients as high risk, we are unable to issue a formal management decision to subrecipients within six months of acceptance of the audit report by the Federal Audit Clearinghouse without assurance that audit reports are received and reviewed in a timely manner. Description of Corrective Action Plan: The University will update subrecipient monitoring procedures as follows: 1. Upon issuance of a subaward, the Business Office will verify if a subrecipient is subject to single audit according to OMB Uniform Guidance. If so, the subrecipient must provide a complete copy of their most recent independent audit used to meet their OMB Uniform Guidance requirement or a link to their record on the Federal Audit Clearinghouse. 2. The Business Office will review the report to verify that there are no findings that may impact the proposed subaward. In the event there are such findings, the Business Office will notify the Office of Sponsored Projects & Research. Together the two offices will determine an appropriate plan of action and issue a Management Decision Letter as required by Uniform Guidance. 3. The Business Office will identify subrecipients receiving payments quarterly and verify that their most recent audit reports have been received and reviewed. Any audit reports completed after issuance of a subaward will be reviewed as described in #2 above. Anticipated Completion Date: Planned corrective actions to be implemented in January 2025.

View Audit 344100

Finding 524659 (2024-001)

Material Weakness 2024

University of Southern Indiana

IN

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

FINDING 2024-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Summary of Finding: The University had designed a key control that one employee would perform the required verifications, and a second employee would then review a sample of those ver...

FINDING 2024-001 Finding Subject: Student Financial Assistance Cluster - Special Tests and Provisions - Verification Summary of Finding: The University had designed a key control that one employee would perform the required verifications, and a second employee would then review a sample of those verifications. However, the control was not properly implemented or operating effectively as the University had not established proper segregation of duties. The same employee was responsible for performing and reviewing verifications during the audit period without an independent oversight, review, or approval process involving a second employee. Contact Person Responsible for Corrective Action: Joanna Riney, Director of Student Financial Assistance Contact Phone Number and Email Address: 812-465-7049; jriney@usi.edu Views of Responsible Officials: We concur with the finding. While the University of Southern Indiana had internal controls in place to prevent aid from disbursing before verification was marked complete and assigned responsibility for verification processing to a well-trained employee with 20 years of verification processing experience, staff vacancies in the department in addition to training and preparation for vast changes in application, award calculation, and system controls for the 2024-2025 aid year limited the ability to conduct an independent review on a sample of students for which verification had been performed. Given the fact that there were very minimal changes to the verification process from the verification process performed in the last several years, in lieu of an independent review, management determined that for the 2023-2024 aid year, utilizing an after-the-fact review on a sample of completed verifications by the employee performing the verification, to review/double-check the verification procedures, provided reasonable assurance that compliance would be achieved. No instances of non-compliance in verification procedures were detected in the audit. Description of Corrective Action Plan: Staffing levels are returning to normal and new staff have a more complete understanding of overall financial aid including the verification process. Also, the Department of Education has provided additional clarification and guidance for all 2024-2025 processing and reduced the number of students selected for verification, allowing management the ability to resume the performance of an independent review on a sample of students for which verification had been performed. Anticipated Completion Date: The independent review was reinstated effective for verifications performed in Fall 2024 and going forward.Per Uniform Guidance: 2 CFR § 200.511(a) – “The auditee is responsible for follow-up and corrective action on all audit findings. . .The auditee must also prepare a corrective action plan for current year audit findings. . .􀀃The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. ” 2 CFR § 200.511(c) – “At the completion of the audit, the auditee must prepare, in a document separate from the auditor's findings described in § 200.516, a corrective action plan to address each audit finding included in the current year auditor's reports. The corrective action plan must provide the name(s) of the contact person(s) responsible for corrective action, the corrective action planned, and the anticipated completion date. If the auditee does not agree with the audit findings or believes corrective action is not required, then the corrective action plan must include an explanation and specific reasons.”

View Audit 344100

Finding 524649 (2024-007)

Significant Deficiency 2024

Eureka College

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-007 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not complete monthly reconciliations for Direct Loan funds. We consider this condition to be a significant deficiency in internal control over compliance relating to the Special Tests and Provisions compliance requirement. Management Response: Management agrees with the finding Corrective Action Plan: JFA deletes prior reconciliation reports. Separate file location on the cloud has been created to hold these monthly reconciliation files. Corresponding reconciliation within Sonis (see above corrective action plan for excess cash) will also occur. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088

Finding 524647 (2024-006)

Significant Deficiency 2024

Eureka College

IL

Questioned Costs Student Financial Aid Special Tests & Provisions

2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: JFA did not accurately include days of breaks for Spring Break. A manual R2T4 calculation is in place to catch errors in the days in a semester. Responsible Person: Tim Marten Implementation Date: 7/01/2024

View Audit 344088 Questioned Costs: $1

Finding 524641 (2024-005)

None 2024

Eureka College

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-005 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not submit the Fiscal Operations Report (FISAP) on or before the specified deadline of September 30, 2023. We consider this condition to be an instance of noncompliance relating to the Reporting compliance requirement. Management Response: Management agrees with the finding Corrective Action Plan: FISAP will be completed by September 15th each year. Plan is in place to ensure access to a wet signature. Prior late submission was due to staffing change and rejected application. Responsible Person: Tim Marten and Michael Bauman Implementation Date: 7/01/2024

View Audit 344088

Finding 524640 (2024-004)

None 2024

Eureka College

IL

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

2024-004 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-004 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: One of the 40 student files (2.5%) we examined, we noted the students were not properly awarded Pell grants. Management Response: Management agrees with the finding Corrective Action Plan: Pell calculations are automatic as part of JFA. Any manual changes to Pell grant amounts will be documented on the student file to justify differing amounts. The only way an amount should differ is if a student is close to their SULA and/or less than full time. Responsible Person: Tim Marten Implementation Date: 7/01/2024

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