Corrective Action Plans

Finding 1174066 (2025-004)

Material Weakness 2025

Yellowstone-West Carbon County Special Services Cooperative

MT

Internal Control / Segregation of Duties

2025-004. SEGREGATION OF DUTIES Name of Contact Person: Roger Heimbigner Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to be involved in providing some of these control...

2025-004. SEGREGATION OF DUTIES Name of Contact Person: Roger Heimbigner Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to be involved in providing some of these controls. Proposed Completion Date: The governing board will implement the above procedure immediately.

View Audit 387729

Finding 1174064 (2025-007)

Material Weakness 2025

Community Unit School District No. 196

IL

Reporting

Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports ...

Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports before submitting. Management response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.

View Audit 387723

Finding 1174063 (2025-006)

Material Weakness 2025

Community Unit School District No. 196

IL

Reporting

Condition: The amounts used to record expenditures on the quarterly expenditure reports should match the general ledger accounts where the expenditures are recorded. Recommendation: We recommend reviewing the general ledger to the expenditure reports before submittin for more accurate reporting. Man...

Condition: The amounts used to record expenditures on the quarterly expenditure reports should match the general ledger accounts where the expenditures are recorded. Recommendation: We recommend reviewing the general ledger to the expenditure reports before submittin for more accurate reporting. Management response: The District will review the general ledger to the expenditure reports before submitting.

View Audit 387723

Finding 1174062 (2025-004)

Material Weakness 2025

Community Unit School District No. 196

IL

Reporting

Condition: The District's general ledgers totals are inconsistent with the ISBE reports due to timing errors, resultig in certain expenses being claimed late on the IDEA Flow Through. Recommendation: We recommend reconciling the general ledger totals to the expenditure reports before sumbitting. Man...

Condition: The District's general ledgers totals are inconsistent with the ISBE reports due to timing errors, resultig in certain expenses being claimed late on the IDEA Flow Through. Recommendation: We recommend reconciling the general ledger totals to the expenditure reports before sumbitting. Management Response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.

View Audit 387723

Finding 1174061 (2025-005)

Material Weakness 2025

Community Unit School District No. 196

IL

Reporting

Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports ...

Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports before submitting. Management response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.

View Audit 387723

Finding 1174060 (2025-001)

Material Weakness 2025

National Foundation for the Centers for Disease Control and Prevention

GA

Subrecipient Monitoring

Finding 2025-001: Subrecipient monitoring Name of contact person: Shavone Smith, Vice President of Finance, (404) 653-0790 Recommendation: The Foundation should ensure that established policies and procedures that are in place to ensure proper subrecipient monitoring activities are adhered to and if...

Finding 2025-001: Subrecipient monitoring Name of contact person: Shavone Smith, Vice President of Finance, (404) 653-0790 Recommendation: The Foundation should ensure that established policies and procedures that are in place to ensure proper subrecipient monitoring activities are adhered to and if there are delays in performing certain key tasks that a plan with a timeline be developed to address when missed tasks will be completed. Corrective action: The Foundation acknowledges that it did not obtain internal control surveys and audit certification forms for a portion of fiscal year 2025 due to reductions in force and other organizational changes which temporarily limited staff capacity to complete all monitoring activities. Internal control surveys and audit certification fully resumed in October 2025. At that time, we also went back to the period May-October 2025 to perform the procedures that were paused and completed monitoring for all subrecipient agreements that were still active. The procedures we performed retroactively did not indicate any heightened risks for the applicable subrecipients. Additionally, all current subrecipient agreements with end dates beyond October of 2025 have had monitoring completed or are scheduled to be completed (due to more recent start dates). To prevent recurrence, the Foundation has implemented procedural safeguards to ensure continuity of compliance monitoring (specifically internal control survey administration, audit certification and an audit review and follow-up) during periods of staffing or operational disruption. These safeguards include (1) reaffirming formal assignment of responsibility for internal control survey administration and audit certification/foll-up to designated roles rather than individual staff, (2) cross-training of additional personnel to perform these functions as needed, and (3) increased management review to confirm completion and timeliness of monitoring. The Foundation will proactively assess the potential impact of anticipated and unanticipated staffing changes on subrecipient monitoring and compliance activities. Management will identify critical functions (including internal controls surveys and audit certification collection) and will ensure appropriate coverage, cross-training, or alternative resources are in place to maintain compliance with federal requirements. These controls were designed to ensure continuity of compliance activities during periods of staffing transition or operational disruption. Management will monitor compliance with this process on an ongoing basis to ensure monitoring is consistently performed in accordance with policy. Proposed completion date: October 2025

View Audit 387721

Finding 1174055 (2025-001)

Material Weakness 2025

Elkhart and St. Joseph Counties Head Start Consortium

IN

Equipment & Real Property Management Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.313

Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the U...

Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the Unit did not perform any of the required federal compliance steps related to the flooring purchase (getting approval before making the purchase, adding the flooring purchase to the capital asset listing, and performing an inventory of the flooring). The Unit believed the flooring purchase did not require approval because it does not meet the criteria of a major renovation under Head Start guidelines. However, as noted in the criteria above, the flooring still qualifies as an equipment and real property purchase. Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: The Consortium management disagrees with the finding. Description of Corrective Action Plan: The Consortium plans to discuss this matter with ACF/HHS to determine if the finding is out of compliance. Anticipated Completion Date: June 30, 2026

View Audit 387707

Finding 1174004 (2025-001)

Material Weakness 2025

City of Woodburn

OR

Allowable Costs / Cost Principles § 200.302

Finding Description: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. The City has not developed written procedures for determining the allowability of costs for departments outside of transit. Corrective Actio...

Finding Description: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. The City has not developed written procedures for determining the allowability of costs for departments outside of transit. Corrective Action: Management will incorporate written procedures for determining the allowability of costs into the City's Financial Plan document, which already includes a section for City-wide policies related to grant administration. The Finance Director and City Manager are responsible for updating the Financial Plan, and the policy updates will be incorporated along with the adoption of the City's fiscal year 2026-2027 budget prior to June 30, 2026.

View Audit 387665

Finding 1174001 (2025-002)

Material Weakness 2025

Town of Seymour, Connecticut

CT

Reporting § 200.512

Recommendation: We recommend the Town evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the data collection form. Management’s Response:: The Town will implement internal ...

Recommendation: We recommend the Town evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the data collection form. Management’s Response:: The Town will implement internal controls to ensure the filing deadline is met. Jason Vieira of the Towns Finance Department is responsible for the corrective action plan.

View Audit 387663

Finding 1173999 (2025-001)

Material Weakness 2025

Pathways in Education - Illinois, Inc.

CA

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management § 200.303 § 200.508

Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and...

Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and Neglected Audit Finding Reference: 2025-001 ________________________________________ 1. Finding Summary The Single Audit identified a deficiency in the documentation and communication of federally funded position percentages and the alignment of Time & Effort attestations with the actual period of work performed. Specifically, the current CPS Federal Funds platform (Oracle) generates Time & Effort Attestation reports based on the month reimbursement claims are submitted, rather than the period during which the work was performed, creating a compliance gap. ________________________________________ 2. Root Cause ● Staff were not consistently informed of the exact percentage of their position funded by federal sources at the start of each semester. ● Time & Effort attestations were generated from the CPS Oracle system based on claim submission timing, not the actual work period. ● There was no formal internal SOP layer to supplement Oracle-generated reports with staff attestation aligned to Semester 1 and Semester 2 work periods. ________________________________________ 3. Corrective Actions Action 1: Internal Funding Percentage Notification System Description: PIE-IL will implement an internal tracking and notification system to ensure all staff funded in whole or in part with federal funds are formally notified of the exact percentage of their position supported by federal funding. Implementation Steps: ● Develop a standardized Federal Funding Allocation Notice template. ● Distribute notices to all applicable staff at the start of Semester 1 and Semester 2. ● Require staff acknowledgment (electronic or signed) confirming receipt and understanding. ● Maintain records centrally in the federal compliance folder. Responsible Party: Manager of Instructional Compliance Timeline: Implemented by the first day of each semester Monitoring: Semester-based review of acknowledgment logs ________________________________________ Action 2: Semester-Based Time & Effort Attestation Description: All federally funded staff will complete and sign a Time & Effort Attestation for both Semester 1 and Semester 2, certifying that time worked aligns with the funding source and percentage assigned. Implementation Steps: ● Issue Time & Effort forms at the end of each semester. ● Require staff to certify actual work performed during the semester. ● Collect supervisor verification signatures. ● Store completed attestations in the federal compliance repository. Responsible Party: Site Administrators / Federal Compliance Officer Timeline: Within 10 business days of semester end Monitoring: Quarterly internal compliance audits ________________________________________ Action 3: Internal SOP as Supplemental Documentation Layer Description: PIE-IL will implement a formal Standard Operating Procedure (SOP) for Time & Effort as a self-managed, internal documentation layer that supplements CPS Oracle-generated attestation reports. This SOP will ensure that Time & Effort documentation reflects the actual period of work performed, rather than the month in which reimbursement claims are submitted. Implementation Steps: ● Draft and approve a written SOP outlining: ○ Semester-based attestation requirements ○ Alignment between funding percentages and staff assignments ○ Reconciliation process between internal records and Oracle reports ● Train administrators and federally funded staff on SOP procedures. ● Maintain SOP as a controlled document with annual review and updates. Responsible Party: Federal Programs Director / Compliance Manager Timeline: SOP finalized within 30 days of audit response submission Monitoring: Annual SOP review and internal compliance testing ________________________________________ 4. Reconciliation Process with CPS Oracle System PIE-IL will perform a monthly reconciliation between: ● Oracle-generated Time & Effort Attestation reports (claim-based), and ● Internal Semester-Based Time & Effort attestations (work-period-based). Any discrepancies will be documented, corrected, and reviewed by the Federal Compliance Officer prior to reimbursement submission. ________________________________________ 5. Evidence of Implementation The following documentation will be maintained for audit and monitoring purposes: ● Federal Funding Allocation Notices with staff acknowledgments ● Signed Semester 1 and Semester 2 Time & Effort Attestation forms ● Approved Time & Effort SOP document ● Training sign-in sheets and materials ● Monthly reconciliation logs between Oracle and internal records ________________________________________ 6. Completion Dates Corrective Action Target Completion Date Funding Percentage Notification System [9/30/2026] Semester-Based Time & Effort Attestation Process [02/06/2026] SOP Finalization and Staff Training [02/28/2026] Monthly Reconciliation Process Ongoing ________________________________________

View Audit 387658

Finding 1173998 (2025-001)

Material Weakness 2025

Voices College Bound Language Academies

CA

School Nutrition Programs Subrecipient Monitoring Cash Management

The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.

View Audit 387654

Finding 1173997 (2025-005)

Material Weakness 2025

College of Southern Idaho

ID

Student Financial Aid

Finding 2025-005 Finding Summary: Under 34 CFR 690.63 and 685.200, institutions must calculate Pell grant and federal direct loan awards based on the student’s eligible enrollment status, cost of attendance, expected family contribution (EFC) or student aid index (SAI), satisfactory academic progres...

Finding 2025-005 Finding Summary: Under 34 CFR 690.63 and 685.200, institutions must calculate Pell grant and federal direct loan awards based on the student’s eligible enrollment status, cost of attendance, expected family contribution (EFC) or student aid index (SAI), satisfactory academic progress, and other Title IV eligibility requirements. Institutions are required to ensure award amounts are accurate and supported by the documentation in the student’s file. During our testing of 60 students, we found one student who received a subsidized direct loan; however, did not meet the requirements to receive the need-based aid. Corrective Action Plan: The institution is actively working to address this system limitation to prevent future occurrences. Corrective actions include: 1. Collaborating with internal teams and system support to update the configuration so that Cost of Attendance and other adjustments can be made for students receiving student loans only. 2. Implementing additional review procedures to identify and document any instances where system limitations may impact COA calculations. 3. Training relevant staff on the updated process once system changes are in place to ensure consistent and accurate awarding moving forward. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Jennifer Service – Director of Financial Aid Anticipated Completion Date: 12/31/202525

View Audit 387647

Finding 1173996 (2025-004)

Material Weakness 2025

College of Southern Idaho

ID

Special Tests & Provisions Student Financial Aid Reporting

Finding 2025-004 Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Instituti...

Finding 2025-004 Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. During testing of compliance for Enrollment Reporting, there were 3 instances out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time limit of 60 days from the effective date of the student’s change in enrollment status. Corrective Action Plan: Enrollment reporting has been centralized under a single point of contact, thereby mitigating risk, ensuring consistency, accountability, and regulatory compliance. This structure was formally implemented last summer with the hiring of an Academic Records Compliance Specialist, significantly strengthening oversight and operational controls. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Noah Briscoe – Assistant Registrar Anticipated Completion Date: 12/31/2025

View Audit 387647

Finding 1173995 (2025-003)

Material Weakness 2025

College of Southern Idaho

ID

Student Financial Aid Material Weakness Reporting

Finding 2025-003 Finding Summary: 34 CFR 690.83 and the FSA Handbook states that an Institution must report accurate and timely data. During testing of compliance for COD Reporting, there were 6 instances out of 60 where the College did not report a student’s disbursement information to COD accurate...

Finding 2025-003 Finding Summary: 34 CFR 690.83 and the FSA Handbook states that an Institution must report accurate and timely data. During testing of compliance for COD Reporting, there were 6 instances out of 60 where the College did not report a student’s disbursement information to COD accurately. Corrective Action Plan: The institution has taken and has fixed this issue by: • The system is now functioning correctly after addressing the issue with the vendor. • To prevent future issues, a more robust tool has been developed to identify discrepancies promptly should they arise. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Jennifer Service – Director of Financial Aid Anticipated Completion Date: 12/31/2025

View Audit 387647

Finding 1173994 (2025-002)

Material Weakness 2025

College of Southern Idaho

ID

Special Tests & Provisions Student Financial Aid Material Weakness

Finding 2025-002 Finding Summary: 34 CFR 668.164(h)(2)(i,ii) states that A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than—Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a...

Finding 2025-002 Finding Summary: 34 CFR 668.164(h)(2)(i,ii) states that A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than—Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. During our testing of compliance for HEA Credit balances, there were 5 instances out of 60 where the College did not refund a student’s within the required time frame of 14 days from the first day of class or 14 days after the credit balance was created. Corrective Action Plan: The institution has taken and has fixed this issue by: • Dedicated Staffing: A full-time position has been approved and filled to manage stipend processing, ensuring consistent oversight and timely disbursement. • Process Documentation: Stipend processing procedures have been documented to ensure continuity, accountability, and clarity of responsibilities. • System Review and Planning: The system is up and running as it should have been. • Ongoing Monitoring: Leadership will continue to monitor stipend processing timelines and staffing capacity to ensure compliance and timely student support. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Bethany Parmer – Assistant Dean of Enrollment Services Anticipated Completion Date: 12/31/2025

View Audit 387647

Finding 1173976 (2025-002)

Material Weakness 2025

Vermont Land Trust, Inc.

VT

Reporting

Management acknowledges this finding. As a result of limitations in the SEFA preparation and reconciliation process during the prior fiscal year, certain FY2024 fourth-quarter expenditures were not properly accrued and were instead recorded in FY2025. In connection with the transition of key finance...

Management acknowledges this finding. As a result of limitations in the SEFA preparation and reconciliation process during the prior fiscal year, certain FY2024 fourth-quarter expenditures were not properly accrued and were instead recorded in FY2025. In connection with the transition of key finance staff, these expenditures were inadvertently included on the first draft of the Schedule of Expenditures of Federal Awards as a part of a federal award that had been fully expended and closed out the in the prior fiscal year. The error was identified and corrected during the audit. Vermont Land Trust has taken targeted steps to address the specific circumstances that resulted in this finding. Management performed a detailed review and reconciliation of active federal awards, including the award affected by fourth-quarter accrual activity, to confirm proper period recognition and award closeout status. As a result, the fully expended award was appropriately removed from the SEFA during the audit. To prevent similar issues during periods of staff transition or year-end close, management has implemented additional review procedures focused on fourth-quarter federal expenditures and accruals.These procedures include verification of award status prior to SEFA preparation and reconciliation of SEFA amounts to the general ledger and grant tracking records. Management believes these targeted actions appropriately address the conditions identified in the finding, and based on subsequent review, no similar issues have been identified. Planned Implementation Date of Corrective Action: Implemented during FY2025 Person Responsible for Corrective Action: Tracy Zschau, President & CEO

View Audit 387626

Finding 1173975 (2025-001)

Material Weakness 2025

Latino Network

OR

Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.328

Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as ...

Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as an attachment. The required Progress Report was filed timely and accepted by HUD, however the required Federal Financial Report was omitted from the submission. Recommendation: The entity should implement and document internal controls to ensure all required reports are prepared, reviewed, and submitted in accordance with federal award requirements. Action Taken: To address the root cause and ensure strict adherence to federal reporting standards moving forward, the Finance Department has implemented the following internal controls, effective immediately: 1. Implementation of a Pre-Submission Checklist: A mandatory "Federal Reporting Checklist" has been developed. This document requires the preparer to physically check off that all required attachments—including narrative progress reports and financial reports (SF-425)—are present and accurate prior to upload. 2. Staff Training: Relevant staff members involved in the grant reporting process have been retrained on the specific submission requirements for HUD awards to ensure clarity on all deliverable components. Responsible Official: Rambod Behnam, Director of Finance Planned Completion Date: June 30, 2026.

View Audit 387609

Finding 1173974 (2025-001)

Material Weakness 2025

City of Missoula

MT

Cash Management Reporting Significant Deficiency § 200.302 § 200.327 § 200.329

The City concurs with the finding. Audit testing identified no reporting errors, no noncompliance, and no questions costs; however, the City acknowledges that documentation of independent supervisory review was not formally required or retained prior to submission of federal reports and reimbursemen...

The City concurs with the finding. Audit testing identified no reporting errors, no noncompliance, and no questions costs; however, the City acknowledges that documentation of independent supervisory review was not formally required or retained prior to submission of federal reports and reimbursement requests. To strengthen documentation of internal control over compliance, the City will implement a formalized and documented secondary review process for all federal financial reports, performance reports, and reimbursement requests, to be retained in grant files in accordance with CFR §200.334 record retention requirements.

View Audit 387608

Finding 1173970 (2025-002)

Material Weakness 2025

City of Tustin

CA

Subrecipient Monitoring § 200.332

Corrective Action Plan: Management agrees with the finding. The City had a preexisting agreement with the subrecipient for a project that was already in progress when the federal grant was awarded. The subrecipient had in-depth involvement during the federal grant application process and is aware of...

Corrective Action Plan: Management agrees with the finding. The City had a preexisting agreement with the subrecipient for a project that was already in progress when the federal grant was awarded. The subrecipient had in-depth involvement during the federal grant application process and is aware of specific compliance requirements under the Uniform Guidance (2CFR Part 200). We will make sure that all future subrecipients of pass-through federal grants are notified in writing of the responsibility to adhere to federal administrative, cost, and audit requirements.

View Audit 387586

Finding 1173969 (2025-002)

Material Weakness 2025

Harvard Community Unit School District No. 50

IL

School Nutrition Programs

Corrective Action Plan Finding Number 2025-002 Condition: At June 30, 2025, the District maintained fund balances in excess of three months’ average expenditures. Management Response/Plan: The District has created a Spend Down Plan for the food service program based off guidance from the Illinois St...

Corrective Action Plan Finding Number 2025-002 Condition: At June 30, 2025, the District maintained fund balances in excess of three months’ average expenditures. Management Response/Plan: The District has created a Spend Down Plan for the food service program based off guidance from the Illinois State Board of Education. The District is working on replacing equipment and renovating cafeterias. Anticipated Date of completion: June 2026 Name of Contact Person: Melissa Geyman Sell

View Audit 387572

Finding 1173964 (2025-001)

Material Weakness 2025

Food for the Hungry

AZ

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Significant Deficiency

Corrective Action Plan Description: Effective October 2025, FH will strengthen its documentation controls to ensure that only the final, approved version of each timesheet is maintained as support for payroll charges to federal awards. Any timesheet revised during the review and approval process wil...

Corrective Action Plan Description: Effective October 2025, FH will strengthen its documentation controls to ensure that only the final, approved version of each timesheet is maintained as support for payroll charges to federal awards. Any timesheet revised during the review and approval process will be clearly marked as “void,” and removed from the official support file. Payroll and grant personnel will be instructed on this updated procedure to ensure compliance with 2 CFR 200 documentation standards. FH will perform periodic reviews to confirm consistent application of the revised process. Responsible: GSC Grants Finance Officer Due Date: 02/28/2026

View Audit 387560

Finding 1173954 (2025-002)

Material Weakness 2025

Bates College

ME

Matching / Level of Effort / Earmarking Student Financial Aid Eligibility

Finding 2025-002 - Eligibility - Student Financial Assistance Cluster, ALN 84.268, June 30, 2025 Award Year, U.S. Department of Education Condition Calculation of Benefits: In addition to the requirements and limits, awards must be coordinated among the various programs and with other federal and no...

Finding 2025-002 - Eligibility - Student Financial Assistance Cluster, ALN 84.268, June 30, 2025 Award Year, U.S. Department of Education Condition Calculation of Benefits: In addition to the requirements and limits, awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). The determination of need-based SFA award amounts is based on financial need. Non-need based SFA awards are not limited to financial need but cannot exceed the student’s COA. To determine non-need based SFA awards (unsubsidized aid) one would use the following formula – COA minus OFA. (November 2025 OMB Compliance Supplement pages 5-3-10 and 5-3-11) Out of forty students tested, two students were under-awarded both Subsidized and Unsubsidized loans and one student was under-awarded Subsidized loans. This was not a statistic. Corrective Actions To address the finding, loan certification procedures have been revised to include step-by-step procedures for determining loan eligibility. A standardized template has been created for calculating subsidized and unsubsidized loan amounts, with clear instructions that subsidized loans must be maximized before awarding unsubsidized loans. Comprehensive training on the calculation of loan eligibility has been provided for new staff, including subsidized versus unsubsidized loan rules, and one-on-one coaching is being provided for staff members with knowledge gaps. A quality assurance program that includes a random sample review of loan awards will be performed between the fall and winter semesters to identify errors and ensure that loans are being certified in accordance with applicable rules and limits. Reviews and findings will be documented so that errors can be addressed immediately. Responsible Official: Wendy G. Glass, Director of Student Financial Services Completion Date: December 4, 2025

View Audit 387552

Finding 1173953 (2025-001)

Material Weakness 2025

Bates College

ME

Student Financial Aid

Finding 2025-001 - Reporting: Financial Reporting - Student Financial Assistance Cluster, ALN 84.268 and 84.063, June 30, 2025 Award Year, U.S. Department of Education Condition Institutions submit Direct Loan, Pell Grant, and TEACH Grant origination records to the Common Origination and Disbursemen...

Finding 2025-001 - Reporting: Financial Reporting - Student Financial Assistance Cluster, ALN 84.268 and 84.063, June 30, 2025 Award Year, U.S. Department of Education Condition Institutions submit Direct Loan, Pell Grant, and TEACH Grant origination records to the Common Origination and Disbursement (“COD”) system. The disbursement record reports the actual disbursement date and the amount of the disbursement. Institutions must report student disbursement data within 15 calendar days after the institution makes the disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. (November 2025 OMB Compliance Supplement page 5- 3-24) Three out of forty disbursements tested were reported late to COD, one was 3 days late and two were 23 days late. Corrective Actions To address the finding, procedures have been revised to specifically address COD reporting during school closures, emergency situations, and off-cycle disbursements. As part of this effort, key dates have been noted on a shared calendar for staff to reference to ensure timely reporting under various circumstances. To maintain compliance going forward, staff will perform weekly reviews of all disbursements to ensure timely COD reporting, and monthly audits of COD reporting will be conducted to identify late submissions and address issues promptly. Responsible Official: Wendy G. Glass, Director of Student Financial Services Completion Date: December 4, 2025

View Audit 387552

Finding 1173951 (2025-001)

Material Weakness 2025

Hope House, Inc.

MO

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Significant Deficiency § 200.306

Matching – Assistance Listing No. 93.671 Recommendation: We recommend the Organization enhance its internal controls over the review of the payroll allocation to ensure matching contributions are accurately calculated and supported. Explanation of disagreement with audit finding: There is no disagre...

Matching – Assistance Listing No. 93.671 Recommendation: We recommend the Organization enhance its internal controls over the review of the payroll allocation to ensure matching contributions are accurately calculated and supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Senior Accountant or Director of Grants and Compliance will conduct the initial review to ensure that match costs are allowable, properly supported, and accurately calculated. The Chief Financial Officer will perform a secondary review and approval to validate completion of the initial review and confirm that reported match amounts reconcile to supporting documentation. Evidence of review will be documented through dated signatures or electronic approval within the grant billing file. Name of the contact person responsible for corrective action: Ashley Freivogel Planned completion date for corrective action plan: September 30, 2026

View Audit 387549

Finding 1173946 (2025-001)

Material Weakness 2025

Noblesville Schools

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.027X Federal Award Year (or Other Identifying Numbers): 22611-023-PN01, 22611-023-ARP, 23611-023-PN01 , 24611-...

Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.027X Federal Award Year (or Other Identifying Numbers): 22611-023-PN01, 22611-023-ARP, 23611-023-PN01 , 24611-023- PN01 , 25611-023-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Suspension and Debarment Audit Findings: Significant Deficiency Condition: An effective system of internal controls was not in place at the School Corporation to ensure the HamiltonBoone- Madison Special Education Cooperative's compliance with applicable requirements related to the Special Education Cluster (IDEA), specifically with respect to Suspension and Debarment requirements. No instances of noncompliance (entering a contract with a vendor that was suspended or debarred) were identified in the transactions selected for testing. The matter represents a deficiency in internal controls over the Suspension and Debarment process, rather than identified noncompliance with program requirements. Context: Suspension and Debarment As part of its internal control procedures, the Cooperative utilizes the System for Award Management (SAM.gov) to verify the eligibility status of vendors prior to engaging in financial transactions. This verification process is designed to ensure that vendors are not suspended, debarred, or otherwise excluded from participation in federal programs, in accordance with applicable procurement regulations. Three covered transactions that equaled or exceeded $25,000 were identified. Of the three transactions, all were selected for testing, totaling $141,578. The Cooperative did not verify the vendors' suspension and debarment status prior to payment for two of the three covered transactions. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will enhance oversight of the Hamilton-Boone-Madison Special Education Cooperative's procurement process to ensure all applicable procurement steps, including suspension and debarment checks, are completed and follow federal regulations for the program, prior to entering into a contract with the respective vendor. Responsible Party and Timeline for Completion: David Hortemiller, CFO and Susan Wilson, Director of Finance met with Steven Wornhoff, Director of HBM Cooperative and Kim Kuersteiner, HBM Technology Manager to establish a process to review all vendors for suspension and debarment. Training was provided in regard to the Sam.gov website. Since August 2024, the Hamilton-Boone-Madison Special Services Cooperative (the Cooperative) has used the System for Awards Management (SAM.gov) to verify the eligibility status of vendors prior to engaging in financial transactions. The Cooperative will continue to use this process for any transaction equaling or exceeding $25,000. Documentation of the verification process will be retained by the Cooperative.

View Audit 387537

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