Corrective Action Plans

Finding 1216500 (2025-003)

Material Weakness 2025

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.318 § 200.403 § 200.405

The City has taken steps to strengthen internal controls over the CDBG program. The City will additionally implement formalized procedures requiring, centralized project files containing procurement documentation, cost support, and project eligibility records, document procurement procedures consist...

The City has taken steps to strengthen internal controls over the CDBG program. The City will additionally implement formalized procedures requiring, centralized project files containing procurement documentation, cost support, and project eligibility records, document procurement procedures consistent with Uniform Guidance requirements, including cost/price analysis and justification for contractor selection, collection and review of Davis-Bacon documentation, including wage determinations and certified payrolls, when applicable, verification that required permits are obtained prior to construction and retention of inspection and completion documentation, and secondary review by City staff to ensure all required documentation is complete prior to project closeout. Additionally, the City will provide training to staff involved in CDBG program administration. Responsible Persons: Community Development Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27

View Audit 402990

Finding 1216499 (2025-002)

Material Weakness 2025

City of Seal Beach

CA

Equipment & Real Property Management Internal Control / Segregation of Duties

The misclassification and subsequent omission of approximately $20,000 in equipment expenditures occurred during the revision of the Annual Certification Report for the Equitable Sharing Program. While correcting the classification of overtime expenditures, a full reconciliation of total expenditure...

The misclassification and subsequent omission of approximately $20,000 in equipment expenditures occurred during the revision of the Annual Certification Report for the Equitable Sharing Program. While correcting the classification of overtime expenditures, a full reconciliation of total expenditures to the underlying accounting records was not completed, resulting in the inadvertent omission of equipment costs. The City has reinforced existing review procedures and implemented an additional step requiring a documented reconciliation of the Annual Certification Report totals to the general ledger prior to submission and after any revisions or resubmissions. Responsible Persons: Police Chief Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27

View Audit 402990

Finding 1216498 (2025-001)

Material Weakness 2025

City of Seal Beach

CA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214

The City will update its written procurement procedures to incorporate suspension and debarment review requirements consistent with 2 CFR Part 180 and 2 CFR §200.214. Training will be provided for staff responsible for purchasing and grant administration to ensure compliance with federal requirement...

The City will update its written procurement procedures to incorporate suspension and debarment review requirements consistent with 2 CFR Part 180 and 2 CFR §200.214. Training will be provided for staff responsible for purchasing and grant administration to ensure compliance with federal requirements. Responsible Persons: Police Chief/Finance Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27

View Audit 402990

Finding 1216497 (2025-003)

Material Weakness 2025

Aurora East School District 131

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility

2025-003: Allocating Funds to Eligible School Attendance Areas and Schools Condition: The district’s approved Title I application established school-level building allocations under Title I Targeting Step 5 using a per-pupil allocation methodology based on low-income counts. The district should docu...

2025-003: Allocating Funds to Eligible School Attendance Areas and Schools Condition: The district’s approved Title I application established school-level building allocations under Title I Targeting Step 5 using a per-pupil allocation methodology based on low-income counts. The district should document school-level expenditures to verify that the per-pupil allocation is followed. The district does not have effective controls to monitor school-level expenditures for compliance with approved Title I building allocations. Six of the 20 schools overspent their allocation by approximately $554,000. The other schools were under their allocations as a result. Corrective Action Planned: The district is working with ISBE to ensure that our site-based resource allocations align with the district’s budget. Name of the Contact Person Responsible for Corrective Action: Mr. Daniel Ulrich, Executive Direct of Finance/ District Accountants/Auditor, Judy Freeman, District Accounts Grant Auditor, Chanbopha Loera Anticipated Completion Date: July 1st 2026.

View Audit 402987

Finding 1216495 (2025-002)

Material Weakness 2025

La Clinica Tepeyac

CO

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303

Consolidated Health Centers Grant – Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditor’s recommended the Organization update their termination procedures to verify that final payrolls are being calculated correctly and update their grant allocation process to ensure accurate wage rat...

Consolidated Health Centers Grant – Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditor’s recommended the Organization update their termination procedures to verify that final payrolls are being calculated correctly and update their grant allocation process to ensure accurate wage rates are used to calculate the allocations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has updated the payroll termination process to include a documented review before payroll is finalized. The finance team will review final payroll calculations for terminated employees after HR provides the termination details and payout calculation. Payroll changes and review steps are documented as part of the bi-weekly payroll update emails.

View Audit 402985

Finding 1216493 (2025-001)

Material Weakness 2025

La Clinica Tepeyac

CO

Internal Control / Segregation of Duties Subrecipient Monitoring

Consolidated Health Centers Grant – Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categori...

Consolidated Health Centers Grant – Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that all documentation supporting the sliding discount provided is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization continues to make improvements to processes and procedures to ensure the accurate documentation and application of the sliding fee discounts. An improvement over the prior year's finding was realized, however more active internal audit checks and balances will need to be made to fully resolve these issues.

View Audit 402985

Finding 1216491 (2025-004)

Material Weakness 2025

Town of Charlestown, Rhode Island

RI

Reporting Internal Control / Segregation of Duties

Corrective Action:The Town will implement the following corrective actions to address this finding:1. The Town will establish formal written procedures for the preparation, review, reconciliation, and submission of all federal reports, including the Project and Expenditure Report required under the ...

Corrective Action:The Town will implement the following corrective actions to address this finding:1. The Town will establish formal written procedures for the preparation, review, reconciliation, and submission of all federal reports, including the Project and Expenditure Report required under the Coronavirus State and Local Fiscal Recovery Funds program.2. Prior to submission, the Town Treasurer/Finance Office will perform and document a reconciliation of all reported obligations and expenditures to the Town’s underlying accounting records for the applicable reporting period.3. The Town will require management review and approval of all federal reports before submission to ensure completeness, accuracy, and compliance with federal requirements.4. The Town will work with its third-party consultant to clearly define responsibilities related to report preparation and submission and require the consultant to provide a final draft report for Town review and approval prior to filing with the U.S. Treasury.5. The Town anticipates these corrective actions will be fully implemented for all future federal reporting submissions beginning with the next required reporting cycle.Responsible Official: Patrick Gormley, TreasurerAnticipated Completion Date: June 30, 2026

View Audit 402982

Finding 1216490 (2025-003)

Material Weakness 2025

Town of Charlestown, Rhode Island

RI

Procurement, Suspension & Debarment

Corrective Action: 1. Verification Procedures Implementation: The Town should establish verification procedures to confirm the eligibility of potential transaction partners. 2. Documented Verification Process: Develop a documented verification process outlining the steps to be taken to verify the st...

Corrective Action: 1. Verification Procedures Implementation: The Town should establish verification procedures to confirm the eligibility of potential transaction partners. 2. Documented Verification Process: Develop a documented verification process outlining the steps to be taken to verify the status of potential transaction partners. This process should include checking relevant databases and contacting appropriate authorities, if necessary. This can be accomplished through the use of sam.gov to verify transaction partners current standing.3. Designated Responsible Party: Assign a designated responsible party within the Town administration to oversee the verification process.4. Integration into Transaction Process: Integrate the verification procedures into the Town's transaction approval process. Ensure that verification is completed before finalizing any covered transactions.5. Regular Review and Updates: Establish a schedule for regular review and updates of the verification procedures to ensure they remain effective and up-to-date with any changes in regulations or requirements.6. Training and Awareness: Provide training to relevant staff members involved in the transaction approval process to ensure they understand the importance of the verification procedures and their role in implementing them effectively.By implementing these corrective actions, the Town will enhance its compliance with regulations, mitigate the risk of engaging in transactions with excluded entities, and ensure the integrity of its procurement and contracting processes.Responsible Official: Patrick Gormley, TreasurerAnticipated Completion Date: June 30, 2026

View Audit 402982

Finding 1216488 (2025-004)

Material Weakness 2025

Habilitative Systems, Inc.

IL

Reporting

Finding 2025-004 Noncompliance with Federal and State Financial Reporting Requirements Criteria Uniform Guidance stipulates that entities required to complete a single audit must submit a Data Collection Form, schedule of expenditures of federal awards (SEFA) and single audit reports to the Federal ...

Finding 2025-004 Noncompliance with Federal and State Financial Reporting Requirements Criteria Uniform Guidance stipulates that entities required to complete a single audit must submit a Data Collection Form, schedule of expenditures of federal awards (SEFA) and single audit reports to the Federal Audit Clearinghouse within the earlier of thirty (30) calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period. Additionally, the Illinois Grant Accountability and Transparency Act (GATA) stipulates that entities required to complete a single audit who received a grant from a State of Illinois agency must submit financial statements audited in accordance with Government Auditing Standards, SEFA, Consolidated Year-End Financial Report (CYEFR), and certain other required documents to the State of Illinois GATA portal. This submission is also due within the earlier of thirty (30) calendar days after receipt of the auditor’s report or nine (9) months after the end of the audit period. Views of Responsible Officials and Planned Corrective Actions Management agrees with the auditor’s finding and will implement the auditor’s recommendation. Person responsible: Jason House Anticipated date of implementation: June 2026

View Audit 402980

Finding 1216487 (2025-003)

Material Weakness 2025

Habilitative Systems, Inc.

IL

Allowable Costs / Cost Principles Reporting

Finding 2025-003 Material Weakness in Internal Control Over Allowable Costs/Cost Principles Criteria HSI is responsible for keeping adequate supporting documentation of salaries and wage expense charged to federally funded grants. Required documentation includes personnel activity reports, electroni...

Finding 2025-003 Material Weakness in Internal Control Over Allowable Costs/Cost Principles Criteria HSI is responsible for keeping adequate supporting documentation of salaries and wage expense charged to federally funded grants. Required documentation includes personnel activity reports, electronic or manual time sheets, pay records integrated with grant codes, certification statements, budget-to-actual reconciliations, and activity descriptions and reports. Views of Responsible Officials and Planned Corrective Actions Management agrees with the auditor’s finding and will implement the auditor’s recommendation. Person responsible: Jason House Anticipated date of implementation: June 2026

View Audit 402980

Finding 1216472 (2025-001)

Material Weakness 2025

Green Bay Metropolitan Sewerage District

WI

Procurement, Suspension & Debarment Subrecipient Monitoring

FINDINGS— FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY 2025-001 Suspension and Debarment Recommendation: We recommend the District review and update procurement policies for the entire District to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a pr...

FINDINGS— FEDERAL AWARD PROGRAMS AUDITS SIGNIFICANT DEFICIENCY 2025-001 Suspension and Debarment Recommendation: We recommend the District review and update procurement policies for the entire District to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The District is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants. Name(s) of the contact person(s) responsible for corrective action: Courtney Mueller Planned completion date for corrective action plan: 5/31/2026

View Audit 402971

Finding 1216466 (2025-001)

Material Weakness 2025

Metafund, Corp.

OK

Procurement, Suspension & Debarment § 200.214

Finding Number: 2025-001 – Suspension and Debarment Planned Corrective Action: Management concurs with the finding. The organization will implement the following: • Update our internal procedures checklist for federal awards to include performing and documenting suspension and debarment checks in SA...

Finding Number: 2025-001 – Suspension and Debarment Planned Corrective Action: Management concurs with the finding. The organization will implement the following: • Update our internal procedures checklist for federal awards to include performing and documenting suspension and debarment checks in SAM.gov prior to executing any agreements funded with CDFI ERP Award, or any other federal award, funds. • Include the required suspension and debarment representation into all contracts, including loan agreements and promissory notes. Management has already performed a retrospective review of CDFI ERP-funded transaction and determined no other additional corrective actions are necessary. Persons responsible for Corrective action Plan: Steve Holmes (Controller), and Laura Hensley (Compliance Manager) Anticipated Date of Completion: May 22, 2026

View Audit 402964

Finding 1216460 (2025-005)

Material Weakness 2025

Casita Park Housing Development Fund Corporation

NY

Reporting

New Director of Accounting will ensure books are closed timely and reporting is submitted for year-end audits.

View Audit 402962

Finding 1216459 (2025-004)

Material Weakness 2025

Casita Park Housing Development Fund Corporation

NY

Eligibility HUD Housing Programs

EIV’s should not be an issue moving forward as the HUD issue was resolved. For the tenants who certified late they didn’t provide their documentation on time to close it out. We will continue to follow up with residents in between their 30-60-90 days to ensure their recertification is completed befo...

EIV’s should not be an issue moving forward as the HUD issue was resolved. For the tenants who certified late they didn’t provide their documentation on time to close it out. We will continue to follow up with residents in between their 30-60-90 days to ensure their recertification is completed before the deadline.

View Audit 402962

Finding 1216458 (2025-003)

Material Weakness 2025

Casita Park Housing Development Fund Corporation

NY

Tenant securities are being sent to the respective security deposit account.

View Audit 402962

Finding 1216457 (2025-002)

Material Weakness 2025

Casita Park Housing Development Fund Corporation

NY

HUD Housing Programs

Funds are being reimbursed, and we are submitting a BBRI increase to plead with HUD to increase the income to this project so that it can afford to repay in a timely manner.

View Audit 402962

Finding 1216456 (2025-007)

Material Weakness 2025

Municipality of Yauco

PR

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

We will improve our internal control procedures related to record keeping and adjustments in order to ensure compliance with the March 31 federal requirement.

View Audit 402958

Finding 1216448 (2025-006)

Material Weakness 2025

Municipality of Yauco

PR

Subrecipient Monitoring § 200.328 § 200.329

Management established corrective measures immediately upon identifying the deficiency related to the untimely submission of the required reports. The Municipality implemented formal procedures to monitor reporting deadlines and ensure the timely submission of reports required by ACUDEN. Management ...

Management established corrective measures immediately upon identifying the deficiency related to the untimely submission of the required reports. The Municipality implemented formal procedures to monitor reporting deadlines and ensure the timely submission of reports required by ACUDEN. Management will continue monitoring compliance with these corrective measures to ensure the timely submission of reports in future periods.

View Audit 402958

Finding 1216446 (2025-002)

Material Weakness 2025

Boardman Local School District

OH

Eligibility School Nutrition Programs Matching / Level of Effort / Earmarking

The Food Service Supervisor will verify that PaySchools contains the correct income eligibility guidelines provided by ODEW for the current school year. These income determination charts will be verified twice annually, prior to application submissions and again midway through the school year. In ad...

The Food Service Supervisor will verify that PaySchools contains the correct income eligibility guidelines provided by ODEW for the current school year. These income determination charts will be verified twice annually, prior to application submissions and again midway through the school year. In addition, the District will randomly sample 10% of portal applications entered in PaySchools to ensure eligibility determinations were processed correctly in accordance with program income eligibility requirements. The annual verification process conducted in November will further confirm the accuracy of selected applications. Documentation of these reviews will be maintained in spreadsheet format and printed, signed, and dated by the Food Service Supervisor by November 15 of each school year.

View Audit 402957

Finding 1216443 (2025-001)

Material Weakness 2025

Zero to Five Montana

MT

Significant Deficiency

Corrective Action Plan: Zero to Five Montana (ZtF) has implemented updated policies and procedures governing program expenditures to strengthen internal controls. Employees in managerial or director roles are no longer permitted to approve their own submitted expenditures. All expenditures, includin...

Corrective Action Plan: Zero to Five Montana (ZtF) has implemented updated policies and procedures governing program expenditures to strengthen internal controls. Employees in managerial or director roles are no longer permitted to approve their own submitted expenditures. All expenditures, including purchase orders, must be approved by the next level of managerial authority. Similarly, employee timecards cannot be self-approved by individuals in managerial roles who have system access to approve time entries. The expense management and timekeeping systems have been reconfigured to prevent approvals when the approver and requestor are the same individual. Contact Person Responsible for Corrective Action: • Caitlin Jensen, Executive Director Anticipated Completion Date: May 15, 2026

View Audit 402954

Finding 1216442 (2025-009)

Material Weakness 2025

Ajo Unified School District No. 15

AZ

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

2025-009: ALLOWABLE COSTS/COST PRINCIPLES Program: Education Stabilization Fund Federal Assistance Listing Number: 84.425U Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESIII-111427-01A Questioned Costs: $909.10 Type of Finding: ...

2025-009: ALLOWABLE COSTS/COST PRINCIPLES Program: Education Stabilization Fund Federal Assistance Listing Number: 84.425U Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESIII-111427-01A Questioned Costs: $909.10 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: B. Allowable Costs/Cost Principles Condition: During testing of payroll disbursements charged to the Education Stabilization Fund (ESSER III) program, we noted that for two of 9 transactions tested, the District was unable to provide documentation demonstrating that extra duty stipends were properly approved and allowable under the grant. The total amount associated with these transactions was $909.10. Action planned in response to finding: The District will implement procedures to ensure all payroll expenditures charged to federal programs are properly authorized, supported, and allowable prior to processing, including requiring documented approval for all stipends and maintaining adequate supporting documentation. The District will also strengthen oversight over grant management by assigning responsibility for reviewing grant expenditures and monitoring grant budgets on an ongoing basis to ensure costs are appropriate, within approved budgets, and charged to the correct program. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Roman Soltero, Superintendent

View Audit 402951

Finding 1216441 (2025-002)

Material Weakness 2025

Highlands County, Florida

FL

Cash Management Material Weakness Reporting § 200.303

Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Assistance Listing No. 97.036 Recommendation: We recommend the County establish and implement formal procedures requiring supervisory review and approval of all reports submitted to grantors. Evidence of review should be docum...

Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Assistance Listing No. 97.036 Recommendation: We recommend the County establish and implement formal procedures requiring supervisory review and approval of all reports submitted to grantors. Evidence of review should be documented and retained, including the reviewer’s signature or electronic approval, the date of review, and the date of submission, to support compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County has established a review and approval process for quarterly reports. Reports will be reviewed and signed by a member of management to ensure accuracy and completeness of the data being submitted. Name of the contact person responsible for corrective action: Tanya Cannady, Business Services Director Planned completion date for corrective action plan: June 2026

View Audit 402949

Finding 1216437 (2025-001)

Material Weakness 2025

Highlands County, Florida

FL

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.303

Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Assistance Listing No. 97.036 Recommendation: We recommend the County implement a formal review and reconciliation process to ensure that employees' hours reported on Activity Logs are verified against the reimbursement reques...

Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Assistance Listing No. 97.036 Recommendation: We recommend the County implement a formal review and reconciliation process to ensure that employees' hours reported on Activity Logs are verified against the reimbursement request prior to submitting it to the grantor. This review should be performed by personnel knowledgeable of the grant requirements and documented to evidence the review was completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will establish a process to maintain effective internal controls to ensure that the documentation is complete and accurately reflected in the reimbursement requests. An internal review and reconciliation process for employee activity logs will be performed prior to submitting to the grantor. Name of the contact person responsible for corrective action: Tanya Cannady, Business Services Director Planned completion date for corrective action plan: June 2026

View Audit 402949

Finding 1216432 (2025-006)

Material Weakness 2025

Richland Community College

IL

Student Financial Aid Special Tests & Provisions Material Weakness

2025-006 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Criteria: 3...

2025-006 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Criteria: 34 CFR 690.83 (b)(2) which states the institution shall submit “in accordance with deadline dates established by the Secretary, through publication in the Federal Register, other reports and information with Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.” 34 CFR 685.309(b)(1-2) which states a school shall “upon receipt of a student status confirmation report from the Secretary, complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within the next 60 days, notify the Secretary with 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of student…” Condition: The College did not correctly report enrollment status changes for 21 out of 40 students tested (52.5%). We consider this condition to be a material weakness of the Special Tests and Provisions compliance requirement and is a repeated finding shown in Section IV of this report as prior year finding 2024-004. Statistical sampling was not used in making sampling selections. Responsible Person: Director, Financial Aid and Veteran Affairs, Director, Admission and Registration, and Administrative Information Systems (AIS) Corrective Action Plan: The Director of Financial Aid and Veteran Affairs will work with the Director of Admissions and Registration to review and update enrollment procedures, evaluate system configuration and reporting process related to the recent transition to Jenzabar One and Jenzabar Financial Aid, and establish a secondary review process to verify enrollment status changes prior to and after submission through the National Student Clearinghouse. Periodic internal monitoring will also be conducted to ensure compliance and strengthen internal controls. Implementation Date: May 2026

View Audit 402942

Finding 1216428 (2025-005)

Material Weakness 2025

Richland Community College

IL

Student Financial Aid Special Tests & Provisions

2025-005 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Criteria: 3...

2025-005 - Student Financial Aid Cluster - (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Pell Grant Program (d) Federal Direct Student Loans, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2025 Criteria: 34 CFR 668.22 (a)(1) states “When a recipient of title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with paragraph (e) of this section.” 34 CFR 668.22 (e)(2) states, “The percentage of title IV grant or loan assistance that has been earned by the student is - (i) Equal to the percentage of the payment period or period of enrollment that the student completed (as determined in accordance with paragraph (f) of this section) as of the student's withdrawal date, if this date occurs on or before - (A) Completion of 60% of the payment period or period of enrollment for a program that is measured in credit hours; or…” 34 CFR 668.22(j) notes, “(1) An institution must return the amount of title IV funds for which it is responsible under paragraph (g) of this section as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew as defined in paragraph (l)(3) of this section. The timeframe for returning funds is further described in § 668.173(b).” Condition: We tested 19 drop students and found one incorrect refund calculation (5.3%). We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions and is not a repeated finding. Statistical sampling was not used. Responsible Person: Director, Financial Aid and Veteran Affairs Corrective Action Plan: The responsible party will thoroughly review each Return to Title IV (R2T4) calculation to ensure that it was accurately completed. Additionally, the responsible party will review current R2T4 procedures, implement a secondary review process for R2T4 calculations, and will conduct periodic reviews to ensure each R2T4 calculation was accurately completed. Lastly, the Financial Aid and Veteran Affairs Office will evaluate whether the recent transition to Jenzabar Financial Aid and Jenzabar One can strengthen compliance and internal controls. Implementation Date: May 2026

View Audit 402942

Corrective Action Plans

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