Corrective Action Plans

Finding 1201601 (2025-001)

Material Weakness 2025

Southeast Coastal Ocean Observing Regional Association

SC

Subrecipient Monitoring Internal Control / Segregation of Duties

Corrective Action Plan (CAP) Award Information: NOAA Program Office: NOS Integrated Ocean Observations Systems (IOOS) Federal Award Numbers (FAIN): NA21NOS0120097, NA24NOSX012C0024, and NA23NOS0120243 Recipient Organization: Southeast Coastal Ocean Observing Regional Association Recipient UEI: EEL2L...

Corrective Action Plan (CAP) Award Information: NOAA Program Office: NOS Integrated Ocean Observations Systems (IOOS) Federal Award Numbers (FAIN): NA21NOS0120097, NA24NOSX012C0024, and NA23NOS0120243 Recipient Organization: Southeast Coastal Ocean Observing Regional Association Recipient UEI: EEL2LR5E2R85 Project Title: SECOORA: Delivering actionable coastal and ocean information from high-quality science and observations for the Southeast Project Period: 7/1/21-6/30/26 Criteria: During our single audit for the year ended June 30, 2025, we identified that required subawards were not reported in SAM.gov (previously in the FFATA Subaward Reporting System (“FSRS”)) within the 30-day FFATA reporting window, as required by 2 CFR Part 170 and NOAA award terms. This constitutes noncompliance with federal award requirements and may trigger remedies under 2 CFR § 200.339. Cause: The Association was subject to FFATA reporting requirements under its cooperative agreement with the Integrated Ocean Observing System (“IOOS”) Office within the National Oceanic and Atmospheric Administration (“NOAA”). The cause of the FFATA reporting lapses was an interpretation gap of requirements under a cooperative agreement versus a prime grant award, and management has agreed to promptly remediate and implement controls. The noncompliance resulted from a good-faith misunderstanding regarding the applicability of FFATA to cooperative agreements and did not stem from intentional misconduct or an overall deficient control environment. Immediate Corrective Actions Taken: The Association acknowledges lapses in timely reporting of first-tier subawards in the FSRS/SAM.gov and gaps in internal controls, including procedure documentation, tracking of subaward obligation dates, and staff training. The overdue FSRS/SAM.gov reports will be submitted, and NOAA/IOOS will be provided documentation of completion. Long-Term Corrective Actions / Preventive Measures: The Association is in the process of establishing written internal controls, including procedures and tracking mechanisms to ensure timely FFATA reporting, as well as provide training to grants management personnel responsible for FFATA submissions to ensure timely and accurate reporting. Management will continue to use standardized subaward agreements to clearly capture obligation dates and FFATA applicability. Subawards will not be fully executed in the system until the FFATA data fields are completed. There will be a separation of duties for distinct roles for preparer and reviewer/approver. The Association will evidence retention with a central archive of FSRS confirmations, checklists, and supporting documentation and maintain a tracking log with automated reminders for key reporting deadlines. Responsible Personnel: Chief Financial Officer: Megan Lee – Oversees, Reviews, and Approves FFATA reporting compliance and SAM.gov reporting. Ensures required reporting of subaward obligations for FFATA reporting on a monthly basis and ensures timely data submission. Pre/Post Award Grant Specialist– Prepares required reporting of subaward obligations for FFATA reporting on a monthly basis. Timeline for Completion Corrective Action Responsible Party Completion Date Submit overdue FFATA report Chief Financial Officer 06/30/2026 Update written procedures Chief Financial Officer 04/30/2026 Staff online training on FFATA requirements Chief Financial Officer 05/31/2026 Implement dual review of reporting Chief Financial Officer 04/30/2026 Internal Monitoring and Verification: The Association will perform quarterly internal reviews of a sample of subawards to verify: timeliness, data accuracy, documentation, and adherence to reporting process. Finally, the Chief Financial Officer and Pre/Post Award Grant Specialist will report to the Executive Director and escalate any issues identified and implement corrective training as needed. Certification: I certify that the information provided in this Corrective Action Plan is accurate and that the organization is committed to full compliance with the terms and conditions of the NOAA award and the Uniform Guidance (2 CFR Part 200), including remediation of noncompliance consistent with 2 CFR § 200.339.

View Audit 396152

Finding 1201592 (2025-003)

Material Weakness 2025

Army West Point Athletic Association, Inc.

NY

Reporting § 200.328

Audit Finding: Pursuant to 2 CFR 200.512 Report submission, Army West Point Athletic Association Inc. ("AWPAA") did not submit interim performance reports within 30 days after completion of the reporting period through the term of the agreement. Speciﬁcally, the interim performance report for one of...

Audit Finding: Pursuant to 2 CFR 200.512 Report submission, Army West Point Athletic Association Inc. ("AWPAA") did not submit interim performance reports within 30 days after completion of the reporting period through the term of the agreement. Speciﬁcally, the interim performance report for one of two quarters selected during the period July 1, 2024 – June 30, 2025 was not submitted within 30 days after completion of the reporting period. Root Cause Analysis: The frequency of the reporting has not consistently aligned with material updates. Deadlines were not strictly monitored. Corrective Action Plan: Monitor Reporting Compliance and track submission of Interim Performance Reports to ensure submission by the due date(s). Estimated Completion Date: June 30, 2026 Point of Contact: Thomas Theodorakis, Athletic Director/CEO

View Audit 396151

Finding 1201591 (2025-001)

Material Weakness 2025

City of Cincinnati

OH

Period of Performance Significant Deficiency § 200.309

Planned Corrective Action: The City acknowledges the finding. Based on the recommendation, the City plans to do the following: • Establish separate program/project accounts within the financial system for each WIC grant award to ensure expenditures are recorded and tracked individually by grant peri...

Planned Corrective Action: The City acknowledges the finding. Based on the recommendation, the City plans to do the following: • Establish separate program/project accounts within the financial system for each WIC grant award to ensure expenditures are recorded and tracked individually by grant period. • Develop and implement written procedures requiring that all expenditures be reviewed and recorded based on the date incurred relative to the grant’s period of performance. • Perform monthly reconciliations of WIC expenditures by grant to verify that costs are accurately recorded and aligned with the appropriate funding period. • Implement period-end cutoff procedures to ensure expenditures near grant end dates are reviewed and properly assigned to the correct grant period. CHD Fiscal will begin implementing the plan by creating the program codes and will meet with WIC to establish roles for the written procedures. Anticipated Completion Date: 06/30/2026 Responsible Contact Person: Mark Menkhaus, Division Manager

View Audit 396143

Finding 1201590 (2025-001)

Material Weakness 2025

Seniorsplus

ME

Reporting § 200.508 § 200.510

Management will review and update processes and procedures over reporting and additional training will be provided as needed to ensure accurate grant reporting and compliance.

View Audit 396137

Finding 1201580 (2025-003)

Material Weakness 2025

Clarkson University

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding No.: 2025-003 – Disbursements Reporting Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster – Pell Grant Program and Federal Direct Loan (FDL) Program ALN Number: 84.063, 84.268 Federal Award Year: July 1, 2024 – June 30, 2025 Criteria Institutions...

Finding No.: 2025-003 – Disbursements Reporting Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster – Pell Grant Program and Federal Direct Loan (FDL) Program ALN Number: 84.063, 84.268 Federal Award Year: July 1, 2024 – June 30, 2025 Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data ED has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found For two (2) out of 69 Pell COD Reports selected for test work, the required Pell student payment data was reported to the Common Origination and Disbursement (COD) website 52 days after disbursement, which exceeds the 15-day timeframe required by federal regulations. For one (1) out of 69 Pell COD Reports selected for test work, the required Pell student payment data was reported to the Common Origination and Disbursement (COD) website 261 days after disbursement, which exceeds the 15-day timeframe required by federal regulations. For four (4) out of 69 Pell COD Reports and three (3) out of 113 FDL COD Reports selected for test work, the Cost of Attendance was misreported to the COD website. There was no follow-up by the University to correct the discrepancies. For ten (10) out of 69 Pell and ten (10) out of 113 FDL COD Reports selected for test work, the transaction number did not agree between the FASFA Submission Summary Form and the COD website. Cause The cause of the conditions found is insufficient review to ensure that accurate disbursement reporting is occurring on a timely basis, all records submitted to COD were accepted, and, for those that were rejected, that corrected data is submitted within the required timeframe. Possible Asserted Effect The possible effect of the condition found is that the University may not be reporting Pell and FDL disbursements to COD completely, accurately, and in a timely manner. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes; 2024-002 Views of Responsible Officials Management accepts this finding and notes several issues that affected the submissions including staffing onboarding and training, submission review, and deadline controls. Management continues to fill positions experiencing unexpected turnover and to improve training for current and newly hired staff in order to restore adequate staffing levels and ensure continuity of COD reporting responsibilities. From May through September 2025, management retained Blue Icon Advisors (BIA) to provide dedicated coaching and support for improved onboarding and compliance knowledge, including providing specialized training to the Loan Manager relative to federal regulations and proper loan record management. Management is implementing processes to improve the weekly review and update of Cost of Attendance (COA) information and CPS transaction numbers to further ensure institutional records are aligned with COD data and to reduce the risk of mismatched records. Management has also strengthened internal controls with improvements to processes which enhance the monitoring of submission deadlines, review of file acceptance reports, and identification and correction of electronic records issues prior to submission. These improvements include the increased and more effective utilization of COD-delivered reports (including Pell Reconciliation and Anticipated Disbursement Reports) and institutional and PeopleSoft reports and queries, with reviews conducted on a weekly basis to promptly identify record discrepancies requiring resolution. Anticipated Completion Date March 2026 - completed Responsible Person Nicole Adner, Director of Financial Aid

View Audit 396132

Finding 1201578 (2025-002)

Material Weakness 2025

Brattleboro Development Credit Corporation

VT

Reporting § 200.328

Audit Finding Reference: 2025-002 Improve Internal Controls and Compliance with Reporting Requirements Planned Corrective Action: BDCC has established a centralized compliance calendar with automated alerts to ensure all Department of Labor (DOL) financial and performance reports are submitted withi...

Audit Finding Reference: 2025-002 Improve Internal Controls and Compliance with Reporting Requirements Planned Corrective Action: BDCC has established a centralized compliance calendar with automated alerts to ensure all Department of Labor (DOL) financial and performance reports are submitted within the required 45-day window. BDCC has implemented a mandatory secondary review for all quarterly reports. Before submission, the Director of Finance & Grant Management will perform a formal reconciliation of report data against the underlying general ledger to ensure accuracy and alignment with federal reporting standards. Planned Implementation Date of Corrective Action: April 1, 2026 Person Responsible for Corrective Action: Joshua Pacheco, Controller

View Audit 396131

Finding 1201573 (2025-002)

Material Weakness 2025

Urban College of Boston

MA

Student Financial Aid

Finding number: 2025-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 & 84.268 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding. The Business Office will re-emphasize and...

Finding number: 2025-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 & 84.268 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding. The Business Office will re-emphasize and reinforce current procedures for identifying and monitoring student credit balances, including reviews triggered by changes to student accounts such as late disbursements of Title IV aid, tuition and fee adjustments. Staff have recently gone through retraining of this process and are reminded of the importance of conducting timely and thorough reviews after all account activity that may result in a credit balance. To strengthen adherence, together with the Financial Aid office, the Business Office will enhance oversight by increasing supervisory review of credit balance processing and refund timelines. Existing tracking mechanisms will be more closely monitored to ensure that all Title IV-related credit balances are refunded within required time frames. Additionally, both the Finance Aid Office and the Business office will conduct periodic internal reviews to confirm that procedures are being followed and to identify any areas where further reinforcement may be needed. Timeline for Implementation of Corrective Action Plan: Continued oversight and implementation of further checks and balances will be effective April 1, 2026. Contact Person: Erline Tanice, Chief Financial Officer: Erline.Tanice@urbancollege.edu

View Audit 396129

Finding 1201572 (2025-005)

Material Weakness 2025

Urban College of Boston

MA

Student Financial Aid

Finding Number: 2025-005 Federal Agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award Year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and t...

Finding Number: 2025-005 Federal Agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award Year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective a deficiency in the submission of enrollment data to the Clearinghouse. The finding occurred because of gaps in the college’s internal processes for reporting enrollment status changes to NSLDS during a period when withdrawal processes were evolving. Specifically, there were no controls to ensure that the correct effective date was reported for unofficial withdrawals. These controls are necessary because updating the effective date is a manual process in the College’s student information system. As an attendance taking institution, the College should have reported each student’s last date of attendance as the effective date. Instead, there were students for whom the effective date was not manually updated to the last date of attendance. In addition, the prior reporting cadence did not allow sufficient time to identify and correct errors before data was transmitted to NSLDS, resulting in often late, incorrect, or missed reporting. To correct this issue, the College has revised its reporting processes and withdrawal procedures. As a result of last year’s audit, the College updated its National Student Clearinghouse reporting cadence to align with the Clearinghouse’s schedule for reporting to NSLDS. The College now reports enrollment data every 30 days instead of every 45 days, providing ample time for error resolution and ensuring students are reported to NSLDS within the required 60 days. The withdrawal process has also now been clearly established after recent changes, with the course withdrawal date defined as the student’s last date of attendance and training provided to the Registration Coordinator on the new process. To prevent recurrence, the Registrar’s Office now runs standardized reports on a regular cadence to identify enrollment status changes, withdrawal activity, and last dates of attendance and to catch any discrepancies prior to submission to the Clearinghouse. These reports are reviewed as part of a defined check and balance process to ensure the accuracy and timeliness of NSLDS reporting. Timeline for Implementation of Corrective Action Plan: Is already in practice effective Fall 2025 semester. Contact Person: Waqas Mirza, Registrar: Waqas.Mirza@urbancollege.edu

View Audit 396129

Finding 1201571 (2025-004)

Material Weakness 2025

Urban College of Boston

MA

Student Financial Aid Matching / Level of Effort / Earmarking

Finding number: 2025-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and t...

Finding number: 2025-004 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined this was an isolated incident. The student was incorrectly marked in the system as having attended a course she had not, therefore she did not pull on any of the systems drop or withdrawal reporting. It was later discovered that the student had not attended the course therefore making the Return to Title IV calculation submission and refund late. No other students in the semester were affected by the miscalculation of attendance. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue a different situation from the prior year’s late refund return. This year’s late return was due to a systems issue and not due to internal process and procedure. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 396129

Finding 1201570 (2025-003)

Material Weakness 2025

Urban College of Boston

MA

Student Financial Aid

Finding number: 2025-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected student and th...

Finding number: 2025-003 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 & 84.007 Award year: 2025 Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected student and the college’s policies and procedures, has determined the error was a result of an isolated event due to human error. This was an oversight on the part of the processor. The processor failed to include break days of 5 days or more in the denominator of the Return to Title IV calculation resulting in an incorrect return amount. Urban College has applied institutional funding to the overpayment of funds. The Director of Financial Aid (DFA) has reviewed all Return to Title IV calculations for the Spring 2025 semester and confirms no other students were affected. The DFA is working with Global Financial Aid Services to include reviewing scheduled breaks as part of their quarterly audit review process. Timeline for Implementation of Corrective Action Plan: Implementation of new processes effective April 1, 2026 Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu

View Audit 396129

Finding 1201564 (2025-003)

Material Weakness 2025

The Kennedy Collective, Inc. and Affiliates

CT

Procurement, Suspension & Debarment Material Weakness § 200.318 § 200.326

Coronavirus State and Local Fiscal Recovery Funds 21.027 Recommendation: CLA recommends that management compose a procurement policy with the criteria as set out in 2 CFR sections 200.318 and 200.326. and review the conflict of interest policy and make necessary changes to comply with the criteria a...

Coronavirus State and Local Fiscal Recovery Funds 21.027 Recommendation: CLA recommends that management compose a procurement policy with the criteria as set out in 2 CFR sections 200.318 and 200.326. and review the conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR section 200.318. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will compose a procurement policy in line with compliance requirements and review and edit the conflict of interest policy to be in compliance. Name of the contact person responsible for corrective action: Maria Giaimo, CFO Planned completion date for corrective action plan: June 30, 2026

View Audit 396125

Finding 1201560 (2025-002)

Material Weakness 2025

The Kennedy Collective, Inc. and Affiliates

CT

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

Coronavirus State and Local Fiscal Recovery Funds 21.027 Recommendation: CLA recommends that management reinforce and consistently apply key control procedures requiring documented review and approval of all program invoices prior to payment. Management should ensure that reviews explicitly address ...

Coronavirus State and Local Fiscal Recovery Funds 21.027 Recommendation: CLA recommends that management reinforce and consistently apply key control procedures requiring documented review and approval of all program invoices prior to payment. Management should ensure that reviews explicitly address allowability, eligibility and within the period of performance under the program and that evidence of such review is retained in accordance with record retention requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will enforce the internal controls in place to ensure full compliance. Name of the contact person responsible for corrective action: Maria Giaimo, CFO Planned completion date for corrective action plan: June 30, 2026

View Audit 396125

Finding 1201556 (2025-001)

Material Weakness 2025

The Kennedy Collective, Inc. and Affiliates

CT

Allowable Costs / Cost Principles

Coronavirus State and Local Fiscal Recovery Funds 21.027 Recommendation: CLA recommends that management strengthen internal controls over compliance by implementing procedures to ensure that all expenditures are supported by complete and accurate documentation that is retained in accordance with fed...

Coronavirus State and Local Fiscal Recovery Funds 21.027 Recommendation: CLA recommends that management strengthen internal controls over compliance by implementing procedures to ensure that all expenditures are supported by complete and accurate documentation that is retained in accordance with federal record retention requirements. Management should also periodically review documentation for completeness to ensure that expenditures charged can be substantiated and verified as allowable, related to eligible activities, and within the period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will enforce the internal controls in place to ensure full compliance. Name of the contact person responsible for corrective action: Maria Giaimo, CFO Planned completion date for corrective action plan: June 30, 2026

View Audit 396125

Finding 1201552 (2025-009)

Material Weakness 2025

City of Checotah

OK

Reporting

Views of Responsive Officials and Planned Corrective Action: In the future, on all projects involving the use of federal funding, the City will pay careful attention to projects with multiple funding sources to ensure that all funds are accounted for by source to ensure accurate source allocation an...

Views of Responsive Officials and Planned Corrective Action: In the future, on all projects involving the use of federal funding, the City will pay careful attention to projects with multiple funding sources to ensure that all funds are accounted for by source to ensure accurate source allocation and accounting.

View Audit 396119

Finding 1201551 (2025-010)

Material Weakness 2025

City of Checotah

OK

Procurement, Suspension & Debarment

Views of Responsive Officials and Planned Corrective Action: In the future, the City will solicit Requests for Proposals and/or Qualifications for any contracts that exceed $250,000 in which federal funding is involved in accordance with 2 CFR Part 200.

View Audit 396119

Finding 1201547 (2025-002)

Material Weakness 2025

Beulah Heights University

GA

Student Financial Aid Internal Control / Segregation of Duties Subrecipient Monitoring

Finding 2025-002 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Work-Study Community Service Requirement Not Met and Failure to Report FWS Earnings (significant deficiency): Criteria – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-...

Finding 2025-002 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Work-Study Community Service Requirement Not Met and Failure to Report FWS Earnings (significant deficiency): Criteria – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities unless the institution has received an approved waiver from the Department of Education. Per 34 CFR § 675.19(b), institution must maintain fiscal control and accountability over FWS funds and comply with all reporting requirements established by the Secretary. This includes accurately reporting FWS student earnings through required federal systems and maintaining documentation to support reported activity. Condition - Based on documentation provided for the 2024–2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, only $1,057 was identified as wages paid to students employed in community service activities. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from the U.S. Department of Education of not meeting the required 7 percent community service expenditure threshold. Additionally, during review of the institution’s 2024–2025 Federal Work-Study (FWS) activity, it was noted that FWS student earnings were not reported to the Common Origination and Disbursement (COD) System. The institution’s financial aid records and payroll registers indicate that students earned a total of $23,131 in FWS wages during the award year; however, no corresponding COD submissions or COD acknowledgment files were provided for review to demonstrate that these earnings were reported as required. Cause – The infraction appears to have resulted from failure to monitor compliance with the 7 percent FWS community service requirement and inadequate internal controls to ensure timely and accurate reporting of FWS earnings. Effect – The institution did not comply with the statutory community service spending requirement and FWS earnings were not reported through required federal reporting channels, limiting transparency and federal oversight. Questioned Costs - $0 Perspective – The Federal Work-Study Program includes explicit statutory spending and reporting requirements that are considered key compliance controls. In this instance, the institution expended approximately 4 percent of its authorized FWS allocation ($1,057 of $26,649) on community service wages, compared to the required 7 percent, resulting in a 43 percent shortfall from the required threshold. In addition, 100 percent of FWS earnings identified during testing ($23,131) were not reported to the COD System, as no submission or acknowledgment records were available. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen monitoring of community service requirements and establish formal FWS reporting controls and perform periodic internal audits of FWS expenditures and reporting to identify and correct issues prior to year-end and federal reporting deadlines. Management’s Response – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities. Based on documentation provided for the 2024-2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, $1,057 was identified as community service wages. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from ED was requested or approved

View Audit 396108

Finding 1201543 (2025-001)

Material Weakness 2025

Beulah Heights University

GA

Student Financial Aid Reporting Subrecipient Monitoring

Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. F...

Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Finding 2025-001 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs- Pell Grant Disbursement Reported in Incorrect Award Year (significant deficiency): Criteria – Per 34 CFR § 690.61, institutions must ensure that Pell Grant disbursements are made and reported for the correct award year and in accordance with program requirements. Institutions are required to report Pell Grant disbursements in the correct award year and submit all disbursement records by the published COD closeout deadline for the applicable award year Disbursements not reported by the closeout deadline may not be shifted to a subsequent award year to compensate for missed reporting. Condition - For the 2024–2025 award year, testing revealed that one (1) out of ten (10) students selected for testing became eligible for a Federal Pell Grant disbursement of $204 during the 2023–2024 award year. The institution failed to process and report the disbursement in COD prior to the 2023–2024 COD closeout deadline. To compensate, the institution incorrectly posted the $204 disbursement to the student’s account and reported the payment to COD under the subsequent 2024–2025 award year. Cause – The infraction appears to have resulted from failure to monitor and comply with COD Pell Grant closeout deadlines and inadequate controls to ensure disbursements are reported in the correct award year. Effect – Pell Grant disbursement activity was reported inaccurately to the Department of Education. Reporting the disbursement in the incorrect award year compromises the accuracy and integrity of federal Pell reporting. Misreported Pell activity increases the risk of required data corrections and program review findings. Questioned Costs - $204 Perspective – Accurate and timely reporting of Pell Grant disbursements by award year is a key Title IV compliance control, as Pell Grant funding is awarded, monitored, and closed out on an annual basis. In this instance, one (1) out of ten (10) students tested (10%) had a Pell Grant disbursement that was reported in an incorrect award year due to failure to meet the applicable COD closeout deadline. Although the dollar amount involved was limited, the error demonstrates that controls designed to ensure award-year accuracy and timely COD reporting did not operate effectively. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen closeout monitoring procedures, ensure award-year accuracy, and perform periodic internal reviews. Management’s Response – For the 2024–2025 award year, one (1) out of ten (10) students selected for testing became eligible for a Federal Pell Grant disbursement of $204 in the 2023-2024 award year. The institution failed to process the disbursement in COD prior to the 2023-2024 closeout deadline. To compensate, the institution incorrectly posted the $204 disbursement to the student’s account and reported the payment to COD under the subsequent 2024-2025 award year. Per 34 C.F.R. § 690.61 and the U.S. Department of Education’s Common Origination and Disbursement (COD) system requirements, institutions must report Pell Grant disbursements in the correct award year and by the published COD closeout deadline. A. Agree B. Conditions That Caused the Infraction a. Upon further review of the student’s account ledger, the institution identified that a $204 Pell Grant disbursement was incorrectly reflected for the Fall 2024 term. The student did not attend or enroll in Fall 2024; therefore, no Title IV funds should have been associated with that payment period. b. The Pell award was disbursed but was not properly aligned with the student’s actual enrollment timeline. Although the student attended Summer 2024 and Spring 2025, the institution did not submit a Student Bill Letter (SBL) for Spring 2025 because the student was enrolled in only one course. At the time, institutional practice did not require SBL submission for students enrolled less than half time or in a single course. As a result:  The Pell disbursement was not aligned with the correct payment period.  The $204 Pell award was incorrectly reflected as a Fall 2024 disbursement instead of being applied to the appropriate term.  This created a compliance issue related to Title IV disbursement timing and documentation.  Subsequent guidance from FA Solutions clarified that SBLs must be submitted for all enrolled students, regardless of enrollment intensity, to ensure proper alignment of Title IV funds with the correct payment period. C. The School’s Planned Corrective Action Plan (CAP)- The institution will implement the following corrective actions to address and prevent recurrence of this finding: a. Ledger Correction  The Student Accounts Office will revise the student’s ledger to accurately reflect the $204 Pell Grant disbursement as a Summer 2024 credit/refund, the term in which the student had eligible enrollment.  Any misapplied term references will be removed to ensure alignment with Title IV regulations. b. Policy and Procedure Update  Institutional procedures will be updated to require submission of Student Bill Letters (SBLs) for all enrolled students, including those enrolled in a single course or less than half time, when Title IV funds are involved.  This requirement will be documented in both Financial Aid and Student Accounts procedural manuals. c. Staff Training  Financial Aid and Student Accounts staff will receive training on updated SBL submission requirements and Title IV disbursement alignment.  Training will include review of payment period eligibility, enrollment intensity, and documentation standards. d. Cross Departmental Review Process  Financial Aid and Student Accounts will implement a secondary review process prior to Pell disbursement to confirm:  Enrollment for the applicable term  Presence of a submitted SBL  Correct payment period assignment D. Responsible Officials a. Dr. Gina Garlington, Financial Aid Administrator Responsible for Title IV compliance, staff training, SBL submission, and oversight of Pell disbursement procedures. b. CLA, Third Party Servicer and School’s Student Accounts Office Responsible for ledger corrections, and reconciliation of student accounts. E. Expected Timeline for Implementation a. All timelines have been complete F. Monitoring of Corrective Action Plan a. The CAP will be monitored through the following mechanisms:  Monthly reconciliation reviews between Financial Aid and Student Accounts  Random sampling of Pell disbursements to confirm correct payment period alignment.  Annual internal compliance review of SBL submissions and Title IV disbursements.  Documentation of corrective actions retained for audit and program review purposes.  Any discrepancies identified during monitoring will be addressed immediately and documented. G. Status of CAP Prior to This Finding a. This is the first occurrence of this finding for the institution. b. No prior corrective action plan existed addressing this specific issue. View of Responsible Officials- Officials agree with findings

View Audit 396108

Finding 1201539 (2025-004)

Material Weakness 2025

Drexel University

PA

Reporting Eligibility

Management agrees with this finding. The instance in which a Pell Grant disbursement was not reported to the U.S. Department of Education Common Origination and Disbursement (COD) System within the required 15 calendar days was due to the student not answering the high school completion question on ...

Management agrees with this finding. The instance in which a Pell Grant disbursement was not reported to the U.S. Department of Education Common Origination and Disbursement (COD) System within the required 15 calendar days was due to the student not answering the high school completion question on the Free Application for Federal Student Aid (FAFSA), which relates to Ability to Benefit (ATB) eligibility. To address this issue and prevent recurrence, we have implemented an additional control. We now identify students who have been awarded a Pell Grant but have not answered the FAFSA high school completion question. For these students, an ATB requirement is posted on RRAAREQ, which prevents the Pell Grant from disbursing until the FAFSA question has been resolved. This process change ensures that Pell Grant funds will not disburse until the FAFSA high school completion question is completed, allowing the Pell Grant record to successfully extract to COD within the required reporting timeframe. This system update corrects the condition identified in the audit finding and strengthens our internal controls to ensure compliance with federal reporting requirements.

View Audit 396098

Finding 1201536 (2025-003)

Material Weakness 2025

Drexel University

PA

Student Financial Aid

Management agrees with this finding. The Office of the University Registrar has reviewed the findings and has implemented the following processes to ensure greater accuracy of reporting student enrollment data to the NSLDS. 1.The following process has already been implemented from the findings of th...

Management agrees with this finding. The Office of the University Registrar has reviewed the findings and has implemented the following processes to ensure greater accuracy of reporting student enrollment data to the NSLDS. 1.The following process has already been implemented from the findings of the audit. a.Any student enrollment record update that occurs past the point in time of the lastenrollment file submitted to the National Student Clearinghouse (NSC) will be manuallyreported when the student record is updated within the student database to ensure thedata is reported in a timely manner. i.NLSDS reporting will be spot checked for the update of the data submitted to theNSC to ensure they are reporting the data to NSLDS within the requiredtimeframe of Department of Education standards and practices. The Office of the University Registrar will work with our colleagues in theFinancial Aid Office to receive view access to the NSLDS reporting portal toexpedite the review of the updates.

View Audit 396098

Finding 1201534 (2025-002)

Material Weakness 2025

Drexel University

PA

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

Management agrees with this finding. During the merger process, the U.S. Department of Education required that Salus University’s academic year for federal loans be closed out in order to complete the institutional consolidation. During this closed period, several students withdrew from the Summer t...

Management agrees with this finding. During the merger process, the U.S. Department of Education required that Salus University’s academic year for federal loans be closed out in order to complete the institutional consolidation. During this closed period, several students withdrew from the Summer term, which made it difficult to complete the R2T4 process within the standard timeline. This situation was the result of the unique operational constraints associated with the merger and is considered an anomaly rather than a reflection of Salus and Drexel University’s standard procedures. Now that Salus University and Drexel University are fully consolidated, we do not anticipate this circumstance occurring again. Drexel University maintains a written R2T4 policy that includes established procedures, system edit checks, and clearly defined staff responsibilities. Financial Aid team members are fully trained on R2T4 requirements and are responsible for monitoring student withdrawals and completing R2T4 calculations within the required timeframes to ensure compliance with federal regulations.

View Audit 396098

Finding 1201526 (2025-001)

Material Weakness 2025

Drexel University

PA

Internal Control / Segregation of Duties

Management agrees with this finding and s currently working to implement an electronic consent (e-Consent) process for students to ensure compliance and improve documentation of student consent for electronic communications related to financial aid.Two processes are being implemented to address this...

Management agrees with this finding and s currently working to implement an electronic consent (e-Consent) process for students to ensure compliance and improve documentation of student consent for electronic communications related to financial aid.Two processes are being implemented to address this requirement: 1.Incoming Students:For new students, the e-Consent process will be incorporated into the confirmation section ofSlate (University incoming student CRM, Customer Relationship Mangement System). This willallow incoming students to review and complete the e-Consent electronically during theadmissions and enrollment confirmation process. 2.Continuing Students:For currently enrolled students, the e-Consent acknowledgment will be incorporated into theStudent Financial Obligation and Tuition Repayment Agreement (SFO). This ensures thatcontinuing students provide consent as part of the annual financial responsibility agreement process. In addition, information about the e-Consent policy will be published on the Drexel University website within the Terms and Conditions section so students have clear access to the policy and understand the requirements for electronic communication. These updates will ensure that students formally acknowledge and consent to electronic communications regarding financial aid and student account information, strengthening institutional compliance and internal controls. We anticipate having this in place for the start of the 26-27 academic year processing.

View Audit 396098

Finding 1201518 (2025-001)

Material Weakness 2025

Muhlenberg College

PA

Student Financial Aid Reporting Significant Deficiency

Establish a formal reconciliation process between the general ledger and amounts reported in the FISAP; require documented review and approval of all FISAP data by the Controller or CFO prior to submission; Enhance the year-end closing timeline to ensure all relevant financial data is finalized befo...

Establish a formal reconciliation process between the general ledger and amounts reported in the FISAP; require documented review and approval of all FISAP data by the Controller or CFO prior to submission; Enhance the year-end closing timeline to ensure all relevant financial data is finalized before FISAP preparation; Develop and maintain written procedures for FISAP prepartion and review to ensure continuity during staffing transitions; Provide cross-training for key personnel involved in federal reporting to mitigate risks associated with turnover

View Audit 396095

Finding 1201514 (2025-001)

Material Weakness 2025

Family Planning Association of Maine, Inc. Dba Maine Family Planning

ME

Eligibility Internal Control / Segregation of Duties

A. Remediation of Identified Files For participants who are no longer active in the WIC program, no further action will be taken, as the certification period has concluded. For participants who remain active and whose files lack a signed WIC Agreement of Rights and Responsibilities, an “alert” will ...

A. Remediation of Identified Files For participants who are no longer active in the WIC program, no further action will be taken, as the certification period has concluded. For participants who remain active and whose files lack a signed WIC Agreement of Rights and Responsibilities, an “alert” will be placed in the WIC system to ensure the required signature is obtained at the participant’s next scheduled appointment. The signed agreement will be retained in the participant’s certification file in accordance with documentation requirements. B. Staff Reinforcement and Training The WIC Director meets with staff weekly and will formally address the requirement to obtain and retain a signed WIC Agreement of Rights and Responsibilities annually. Staff will be reminded that a certification file is not considered complete unless all required eligibility documentation, including the signed agreement, is present. C. Strengthened Supervisory Review Control (Monitoring Control) Beginning immediately, the WIC Director (or designated supervisory staff) will implement a documented monitoring control to ensure completeness of eligibility documentation: 1. On a monthly basis, supervisory staff will select a sample of newly certified and recertified participant files. 2. The review will verify that all required eligibility documentation is present, including: o Categorical determination o Proof of residency o Income documentation o Nutritional risk documentation o Signed WIC Agreement of Rights and Responsibilities 3. Evidence of supervisory review (e.g., initials, checklist, or review log) will be retained. 4. Any deficiencies identified during internal monitoring will be corrected promptly, and trends will be discussed with staff. This monitoring control is designed to ensure ongoing compliance with federal and state eligibility documentation requirements and to prevent recurrence of the deficiency.

View Audit 396093

Finding 1201513 (2025-005)

Material Weakness 2025

Volunteers of America Western Washington and Subsidiary

WA

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 ...

2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 out of 21 contractor and subcontractor certified payrolls tested were not submitted timely. VOAWW recognizes that timely receipt and review of certified payrolls is essential to ensuring compliance with federal wage requirements. To strengthen internal controls and ensure certified payrolls are consistently obtained, reviewed, and retained, VOAWW will implement the following corrective actions: Implementation of Certified Payroll Submission Controls Before the end of FY26, VOAWW will implement internal controls requiring contractors and subcontractors to submit certified payrolls with each pay application. These controls will include: • A requirement that certified payrolls be submitted prior to payment • A standardized checklist for verifying receipt of certified payrolls • Documentation of the review and approval process • Follow up procedures for missing or incomplete payrolls These steps will ensure certified payrolls are consistently obtained and reviewed before payment is released. Training for Staff on Wage Rate Requirements Beginning in FY26, staff responsible for managing HUD funded construction projects will receive training on: • Davis-Bacon and related wage requirements • Certified payroll documentation standards • Review procedures and red flags • Requirements under 29 CFR Part 5 Contractor Communication and Expectations Before the end of FY26, VOAWW will update contractor communication materials to clearly outline certified payroll requirements, including: • Submission timelines • Required documentation • Consequences for noncompliance • Points of contact for questions or clarifications These expectations will be reinforced during project kick off meetings and throughout the contract period. Centralized Tracking of Certified Payrolls By the end of FY26, VOAWW will implement a centralized tracking log for all certified payroll submissions. This log will document: • Receipt dates • Review dates • Reviewer initials • Any follow up actions taken This will ensure a complete audit trail and consistent monitoring of compliance. These corrective actions will strengthen VOAWW’s internal controls over Wage Rate Requirements, ensure timely receipt and review of certified payrolls, and reduce the risk of noncompliance with federal labor standards. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

View Audit 396088

Finding 1201512 (2025-004)

Material Weakness 2025

Volunteers of America Western Washington and Subsidiary

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency § 200.414

2025-004 Indirect Cost Rate Application on Federal Invoices We acknowledge BDO’s observation regarding the indirect cost rate applied to federal invoices during the period in which VOAWW transitioned from its approved NICRA rate to the de minimis rate. During this transition, VOAWW applied the NICRA...

2025-004 Indirect Cost Rate Application on Federal Invoices We acknowledge BDO’s observation regarding the indirect cost rate applied to federal invoices during the period in which VOAWW transitioned from its approved NICRA rate to the de minimis rate. During this transition, VOAWW applied the NICRA rate of 17.2% while moving to the de minimis rate but did not complete the required true-up to 10% for a three-month period prior to the de minimis rate being increased to 15%. VOAWW has reviewed the circumstances that led to this error and determined that it occurred during an unusual and infrequent set of conditions. Transitions between indirect cost methodologies are rare and increases to the federal de minimis rate are also uncommon. As a result, this specific scenario is unlikely to recur. Nonetheless, VOAWW recognizes the importance of strengthening controls around indirect rate changes to ensure accurate application during any future transitions. To address this finding and strengthen controls over indirect cost rate application, VOAWW will implement the following corrective actions: • Formal Rate Transition Procedures – Before the end of FY26, the Finance Department will develop and document a standardized procedure for transitioning between indirect cost rates, including effective dates, interim rate requirements, required true-ups, and approval checkpoints to ensure accurate application during any future rate changes. • Centralized Indirect Rate Tracking – Before the end of FY26, the Finance Department will maintain a centralized indirect rate schedule that includes approval documentation, effective dates, and any required adjustments. This schedule will be referenced during invoice preparation and review to ensure consistent and accurate rate application across all federal awards. • Contract Kick-Off Meetings and Cross-Department Alignment – Before the end of FY26, Finance, Grants, and Contract Compliance will implement contract kick-off meetings for new awards and significant contract amendments to align on billing requirements, approved indirect cost rates, effective dates, and other critical compliance information and ensure consistent communication across departments. • Documentation of Important Communications – Before the end of FY26, VOAWW will implement guidance for documentation of important communications with funders that have a single audit impact. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

View Audit 396088

Corrective Action Plans

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