Corrective Action Plans

Finding 1180899 (2025-010)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

Corrective action plan: HHSC will conduct an end-to-end review of the sanctions process to identify and implement any needed changes to the business process, training, or system. Implementation date: May 31, 2026 Responsible person: Carrie Robertson, Manager, Strategy and Innovation–Business Integra...

Corrective action plan: HHSC will conduct an end-to-end review of the sanctions process to identify and implement any needed changes to the business process, training, or system. Implementation date: May 31, 2026 Responsible person: Carrie Robertson, Manager, Strategy and Innovation–Business Integration and Support

View Audit 392506

Finding 1180893 (2025-008)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.329

Corrective action plan: HHSC has taken steps to improve the consistency and reliability of financial reporting related to Maintenance of Effort (MOE) expenditures, specifically, amounts reported on the ACF 204, submitted by HHSC Budget and the ACF 196R, submitted by HHSC Federal Reporting (FR). To a...

Corrective action plan: HHSC has taken steps to improve the consistency and reliability of financial reporting related to Maintenance of Effort (MOE) expenditures, specifically, amounts reported on the ACF 204, submitted by HHSC Budget and the ACF 196R, submitted by HHSC Federal Reporting (FR). To address potential discrepancies and strengthen internal controls, HHSC Federal Reporting has implemented and documented a formal reconciliation process. This process involves the following key components: • Implementation and documentation of a formal reconciliation process that compares all MOE expenditures for HHSC, TEA, and TWC reported on the ACF 204 to those reported on the ACF 196R before report submission. The process outlines specific steps for data cross-referencing and validation to ensure completeness and accuracy. • Research, resolve, and correct any discrepancies identified during the reconciliation process before the reports are finalized and submitted for management review. • Reinforcement of management review and documentation of the reconciliation between the ACF-204 and ACF-196R will be incorporated into the approval process prior to report certification. Implementation date: February 28, 2026 Responsible person: Alan Flynn, Manager, Federal Reporting

View Audit 392506

Finding 1180880 (2025-019)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Corrective action plan: THECB ITS will: • Develop and implement a standardized process for all user access reviews, including a required template which documents review date, reviewer identity, scope, results, and remediation actions. • Maintain all documentation in a centralized location on our ITS...

Corrective action plan: THECB ITS will: • Develop and implement a standardized process for all user access reviews, including a required template which documents review date, reviewer identity, scope, results, and remediation actions. • Maintain all documentation in a centralized location on our ITS SharePoint site. • Implement regular monitoring to ensure reviews are performed time, and the proper documentation is retained. • We will seek to automate processes where possible. Implementation date: July 1, 2026 Responsible person: Layla Young, Brian Nolte, Joel Anguiano

View Audit 392506

Finding 1180877 (2025-015)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303 § 200.317 § 200.318 § 200.327

Corrective action plan: TCEQ will provide targeted training to program staff on federal procurement requirements, including the necessity of coordinating all purchases through the Procurements & Contracts Section and completing required vendor compliance checks. Training will emphasize procedures fo...

Corrective action plan: TCEQ will provide targeted training to program staff on federal procurement requirements, including the necessity of coordinating all purchases through the Procurements & Contracts Section and completing required vendor compliance checks. Training will emphasize procedures for sole source or limited source procurements and reinforce staff responsibilities under 2 CFR procurement and internal control standards. Regular refresher sessions and documented guidance will help ensure consistent understanding and adherence to required procurement practices across all program areas. Implementation date: May 31, 2026 Responsible person: Yolanda Davis, Deputy Director, Financial Administration Division

View Audit 392506

Finding 1180876 (2025-002)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Corrective action plan: ITS Management will establish a formal, documented user access review program applicable to both privileged and non-privileged network users. Key actions include: 1. Policy Updates: Revise information technology access control policies and procedures to re-quire periodic (at ...

Corrective action plan: ITS Management will establish a formal, documented user access review program applicable to both privileged and non-privileged network users. Key actions include: 1. Policy Updates: Revise information technology access control policies and procedures to re-quire periodic (at least annual) reviews of all network user access. 2. Standardized Process and Documentation: Implement a consistent, documented review process and maintain records in a centralized repository to ensure accountability and auditability. 3. Monitoring and Oversight: Implement oversight procedures to track completion of access re-views and remediation of identified issues, with reporting to IT and information security leadership to support governance. Implementation dates: 1. Policy and procedure updates: Expected completion by April 30, 2026 2. Standardized process and repository implementation: Expected completion by May 31, 2026 3. First completed annual review under the revised process: Expected completion by June 30, 2026 Responsible persons: Tara Mitchell, Director of IT Operations Sean Peterson, Chief Information Officer

View Audit 392506

Finding 1180875 (2025-020)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Internal Control / Segregation of Duties § 200.303

Corrective action plan: TWC will establish a new policy of 3 defined roles (preparation, review, and approval) and a standardized process for each role on each report. TWC will establish a log to capture the name and date of the staff completing each role for each report, and we will use the log to ...

Corrective action plan: TWC will establish a new policy of 3 defined roles (preparation, review, and approval) and a standardized process for each role on each report. TWC will establish a log to capture the name and date of the staff completing each role for each report, and we will use the log to confirm that no individual performs more than one role on a given report. For all staff with any participation in the ETA reporting function, TWC will have training on the new policy, procedures and log. Implementation date: June 30, 2026 Responsible person: Terri Warren, Unemployment Insurance Administration & Operational Support Department Director

View Audit 392506

Finding 1180873 (2025-014)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Corrective action plan: A formalized process will be implemented, utilizing Standard Operating Procedures, to cover changes of hardware or software in relationship with network and infrastructure components. A change management tracking and approval system is under development that will be utilized ...

Corrective action plan: A formalized process will be implemented, utilizing Standard Operating Procedures, to cover changes of hardware or software in relationship with network and infrastructure components. A change management tracking and approval system is under development that will be utilized to track and provide audit logs of all network and infrastructure changes. Implementation date: August 31, 2026 Responsible person: Lars Hjaltman, CIO

View Audit 392506

Finding 1180872 (2025-016)

Material Weakness 2025

State of Texas C/o Comptroller of Public Accounts

TX

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

Corrective action plan: • IT will coordinate with HR on strengthening the separation process, to include HR running separation reports quarterly and sending to IT to cross check. Will perform regular scheduled meetings to discuss the separation process/issues. • IT is testing automatic scripts that ...

Corrective action plan: • IT will coordinate with HR on strengthening the separation process, to include HR running separation reports quarterly and sending to IT to cross check. Will perform regular scheduled meetings to discuss the separation process/issues. • IT is testing automatic scripts that will aid in the process and will be implemented this year. • IT will document quarterly access reviews which are already done. • IT will work on enhancing automation and controls; Will utilize AI to assist. Implementation date: May 2026 Responsible person: Chris Bunton, CIO, Texas Department of Agriculture

View Audit 392506

Finding 1180855 (2025-001)

Material Weakness 2025

Catawba County, North Carolina

NC

Significant Deficiency Internal Control / Segregation of Duties

Finding: 2025-001 Name of Contact Person: Karen Harrington, DSS Director Corrective Action/Management’s Response: Agency agrees with finding. Corrective Action taken/to be taken below: Corrective Action: The Department will strengthen internal controls related to workstation security to prevent unat...

Finding: 2025-001 Name of Contact Person: Karen Harrington, DSS Director Corrective Action/Management’s Response: Agency agrees with finding. Corrective Action taken/to be taken below: Corrective Action: The Department will strengthen internal controls related to workstation security to prevent unattended access to state systems. Effective immediately, all DSS employees with access to state eligibility systems are required to lock their workstation when away from their desk or log out of the system entirely. Implementation Steps: 1. Policy Reinforcement: DSS management will reissue written guidance to all staff reminding them of the requirement to lock or log out of workstations when unattended, consistent with the DSS Fiscal Manual and county IT security standards. 2. Mandatory Staff Acknowledgment: All DSS employees with state system access will complete a brief acknowledgment confirming understanding of workstation security requirements. 3. IT Controls: In coordination with the County IT Department, automatic screen-lock settings will be verified on all DSS workstations accessing state systems. 4. Monitoring and Verification: Supervisors will conduct periodic unannounced walkthroughs to verify compliance with workstation security requirements. Results will be documented and reviewed by DSS management. 5. Corrective Follow-Up: Any noncompliance identified will be addressed promptly through retraining and, if necessary, progressive disciplinary action. Responsible Party: DSS Director, DSS Program Managers, and County DSS Staff Anticipated Completion Date: Immediately upon issuance of this CAP; monitoring will be ongoing. Plan to Prevent Recurrence: Ongoing supervisory monitoring, documented compliance checks, and annual refresher training will be used to ensure continued adherence to workstation security requirements.

View Audit 392499

Finding 1180848 (2025-001)

Material Weakness 2025

Pace University

NY

Equipment & Real Property Management § 200.313

Management is currently in the process of conducting a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero in accordance with 2 CFR sections 200.313(c) through (e). The inventory process will be reviewed by management to ensure timely, accu...

Management is currently in the process of conducting a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero in accordance with 2 CFR sections 200.313(c) through (e). The inventory process will be reviewed by management to ensure timely, accurate completion. Going forward, the University will tag all new assets acquired using federal funds. In addition, a revised policy has been established relating to an annual physical inventory of federally purchased equipment to facilitate compliance and increase related inventory controls. The revised policy includes, among other details, standard requirements for inventory tagging and related monitoring.

View Audit 392494

Finding 1180827 (2025-003)

Material Weakness 2025

La Roche University

PA

Student Financial Aid

Condition The Federal Pell Grant for one student out of 27 sampled was calculated incorrectly, and the student received excess aid. Corrective Action Plan La Roche University concurs with the finding. The Office of Financial Aid has implemented enhanced controls to ensure accurate Federal Pell Grant...

Condition The Federal Pell Grant for one student out of 27 sampled was calculated incorrectly, and the student received excess aid. Corrective Action Plan La Roche University concurs with the finding. The Office of Financial Aid has implemented enhanced controls to ensure accurate Federal Pell Grant calculations in accordance with Title IV regulations and U.S. Department of Education Pell Grant payment and disbursement guidance. Immediate Correction of Identified Error The affected student’s Pell Grant award was recalculated using the correct Scheduled Pell amount and enrollment intensity. The overaward was resolved in accordance with federal overpayment and reconciliation requirements, and the Common Origination and Disbursement (COD) system was updated accordingly. Pell Calculation Verification Control A mandatory secondary review process has been implemented for all Pell-eligible students prior to disbursement to prevent future occurrences noted in this finding. This control collectively mitigates the risk of recurrence and strengthen institutional compliance with federal eligibility and disbursement requirements. Name(s) of Contact Person(s) Responsible for Corrective Action • Lawrence Britton, Executive Director of Financial Aid • Ron Elmore, Associate Director of Financial Aid Anticipated Completion Date All corrective actions were implemented as of February 9, 2026.

View Audit 392486

Finding 1180826 (2025-002)

Material Weakness 2025

La Roche University

PA

Student Financial Aid HUD Housing Programs Matching / Level of Effort / Earmarking

Condition The federal aid disbursed resulted in a credit balance for one of the 25 students tested were not returned within 14 days of the date the credit balance occurred. Corrective Action Plan La Roche University concurs with the finding. The University’s procedures did not allow for timely payme...

Condition The federal aid disbursed resulted in a credit balance for one of the 25 students tested were not returned within 14 days of the date the credit balance occurred. Corrective Action Plan La Roche University concurs with the finding. The University’s procedures did not allow for timely payment of the funds to the student due to holidays that occurred. The Office of Student Accounts has implemented enhanced controls to ensure that credit balances are reviewed and issued refunds in a timely manner. Name(s) of Contact Person(s) Responsible for Corrective Action • Frank Corona, Controller • Dayna Tinkey, Director of Student Accounts Anticipated Completion Date All corrective actions were implemented as of February 12, 2026.

View Audit 392486

Finding 1180825 (2025-001)

Material Weakness 2025

La Roche University

PA

Student Financial Aid Reporting

Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with status changes in the sample of 25 students selected. Corrective Action Plan La Roche University concurs with the finding. The Office of the Registrar has implemented a new sta...

Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 1 student with status changes in the sample of 25 students selected. Corrective Action Plan La Roche University concurs with the finding. The Office of the Registrar has implemented a new standard operating procedure regarding the reporting of students who have notified us of their withdrawal from the University at the end of spring term/early summer. Identified Error: La Roche University reports enrollment through the National Student Clearinghouse (NSC), which then reports to NSLDS. Because summer is not a mandatory reporting period, if a student is not enrolled they are not coded as withdrawn until they do not return in the fall; only on the first of fall enrollment report would they be coded as withdrawn. This does not meet the reporting timeline to NSLDS if we know a student is not planning to return. This only presents as an issue with the length of time between the end of spring and start of fall term; this is not an issue between the end of fall and start of spring term. New Procedure: If a student submits a Withdrawal form at the end of spring term through the first week of August, we must manually report them as withdrawn in NSC, as we know their intention to not return. Any forms submitted beginning in mid to late August will be picked up on the first of fall enrollment report as withdrawn and still fall within the reporting timeline. Name(s) of Contact Person(s) Responsible for Corrective Action • Katie Elverson, Registrar Anticipated Completion Date Implementation begins in May 2026 and will continue being implemented in all summers going forward.

View Audit 392486

Finding 1180821 (2025-002)

Material Weakness 2025

Stroudsburg Area School District

PA

Allowable Costs / Cost Principles Reporting § 200.510

Significant Deficiency 2025-002 (Internal Control Over Federal Award Reporting – ESSER III) Federal Program: Education Stabilization Fund - ARP-ESSER ALN: 84.425U Condition: Allowable ESSER III expenditures incurred during fiscal year 2023-24 were not identified or included on the Schedule of Expend...

Significant Deficiency 2025-002 (Internal Control Over Federal Award Reporting – ESSER III) Federal Program: Education Stabilization Fund - ARP-ESSER ALN: 84.425U Condition: Allowable ESSER III expenditures incurred during fiscal year 2023-24 were not identified or included on the Schedule of Expenditures of Federal Awards (SEFA) for that year. In addition, expenditures related to Federal Set-Aside awards were mistakenly included in the Final Expenditure Report for ESSER III, resulting from a misunderstanding of the structure of the federal awards. Recommendation: Strengthen internal controls Corrective Action: The District will provide targeted training to staff responsible for federal grant accounting to ensure a clear understanding of federal grant award structures, including the distinction between ESSER III and related Federal Set-Aside awards. This training will cover grant setup, expenditure coding, and reporting requirements. Person Responsible: Brenda VanBuskirk, Business Manager Proposed Completion Date: December 31, 2025

View Audit 392478

Finding 1180820 (2025-004)

Material Weakness 2025

Illinois State University

IL

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Management Response: The University agrees with the finding. The identified issue was isolated and only impacted fall graduates. This issue was fully addressed when the university filed its fall 2025 enrollment reporting. The university has conducted an internal audit to identify students that were ...

Management Response: The University agrees with the finding. The identified issue was isolated and only impacted fall graduates. This issue was fully addressed when the university filed its fall 2025 enrollment reporting. The university has conducted an internal audit to identify students that were reported incorrectly and has manually updated files to ensure dates were properly reflected. At current state, internal monitoring and manual edits are made if discrepancies appear. The university has been in contact with PeopleSoft software related to the issue. Should the software issue not be resolved, the university plans to continue with manual edits to ensure proper reporting. Contact Person: Stacy Ramsey, University Registrar srramse@ilstu.edu Completion Date: December 2025

View Audit 392475

Finding 1180817 (2025-005)

Material Weakness 2025

Benton Community School Corporation

IN

Matching / Level of Effort / Earmarking § 200.207 § 200.303

Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Ot...

Information on the federal program: Subject: Special Education Cluster (IDEA) –Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 23611-047-PN01, 22619-047-PN01, 22619-047-ARP, 23619-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, and Earmarking Audit Finding: Significant Deficiency, Other Matters Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the earmarking portion of the Matching, Level of Effort, Earmarking compliance requirement. Context: The School Corporation did not meet the earmarking requirements for the grants, which concluded during the audit period. Both the Special Education Grants to States and Special Education Preschool Grants required a proportionate share of their funding to be spent on non-public school students with disabilities. The 22611-047-PN01, 22611-047-ARP, 23611-047-PN01, 22619-047-PN01, 22619-047-ARP, and 23619-047-PN01 grant awards were fully expended during the audit period with minimum Non-Public Proportionate Share earmarking requirements of $27,189, $5,074, $26,124, $1,171, $453, and $1,929, respectively. There were not sufficient non-public school expenditures incurred to meet the non-public proportionate share requirement for any of the six grants. The non-public school expenditures fell short of the minimum requirement by $11,679, $3,176, $16,405, $1,171, $4, and $1,929, respectively. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. The cooperative has developed a written procedure for documenting expenditures related to the proportionate share earmarking requirement at the School Corporation level to address this issue going forward. The School Corporation will maintain the proper documentation to support the Non-Public Proportionate Share earmarking requirement and validate the earmarking requirement is met at the end of the grant’s period of performance or once fully expended. Responsible Party and Timeline for Completion: The corrective action plan has been put into place for the 2025-26 school year. Tracy Albertson, Director of Finance, and Sarah Claton, Director of Cooperative School Services, will oversee the corrective action plan.

View Audit 392466

Finding 1180811 (2025-004)

Material Weakness 2025

Benton Community School Corporation

IN

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.309 § 200.461

Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal ...

Information on the federal program: Subject: Special Education Cluster (IDEA) – Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-PN01, 22619-047-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Period of Performance compliance requirements. Context: During fiscal year 2023-24, the School Corporation was a member of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For Special Education Cluster awards, funds must be obligated during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. When testing transactions occurred in the liquidation period for the 22611-047-PN01, 22611-047-ARP, 22619-047-PN01 and 22619-047-ARP grant awards, two exceptions were identified in the sample of five transactions. For the above listed awards, costs must be obligated by September 30, 2023. For the two identified exceptions, an initial purchase order was made in September, but the ultimate transaction was paid to a separate vendor than the original purchase order, and this obligation was incurred in November 2023. This issue was isolated to fiscal year 2024. No costs incurred outside of the period of performance were identified in fiscal year 2025. Views of Responsible Officials and Corrective Action Plan: Management disagrees with part of the finding. The term “obligate” can be interpreted in various ways within our context. While we have a purchase order that was completed by September 30, we do agree that we changed vendors after September 30 and paid the non-public school directly. We agree with the finding that direct payment to a non-public school is not allowable. The purchase order is an internal written commitment to acquire the items/supplies, but it is not a binding written agreement to acquire “property” when we are purchasing supplies until it is provided to the vendor. The purchase order is authorization and approval to purchase the items/supplies. Once the purchase order is provided to the vendor, it is committed and is the binding written agreement. The invoice is an order to pay the obligation. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Sarah Claton, Cooperative School Services director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the cooperative on an ongoing basis.

View Audit 392466

Finding 1180807 (2025-003)

Material Weakness 2025

Benton Community School Corporation

IN

Allowable Costs / Cost Principles § 200.303 § 200.403

Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers...

Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-047-PN01, 22611-047-ARP, 22619-047-ARP, 24611-047-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster program and Activities Allowed or Unallowed and Allowable Costs compliance requirements. Context: During fiscal year 2023-2024, the School Corporation was a member of Cooperative School Services (Cooperative). The Cooperative operated the special education programs and spent the federal money on behalf of its member schools. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. For costs related to non-public schools, the practice of the Cooperative was to separate out the required amount for each member school from the Cooperative budget, and the member schools would work with the non-public schools to determine how to spend their proportionate share amount. Each member school would then request reimbursement from the Cooperative for non-public school expenditures incurred. This allowed both the Cooperative and member schools to maintain control of all Special Education funds, property, equipment and supplies. In the initial sample of 25 expenditures, there was no noncompliance identified. However, while performing a review of separate transactions for the Period of Performance compliance requirement, it was noted that non-public schools received direct reimbursements from the Cooperative for their proportionate share expenditures, which is not allowable under the grant award. The audit team reviewed the expenditure population in entirety and identified a total of 5 expenditures, totaling $17,857, that were made from Special Education funds directly to non-public schools by the cooperative during the audit period. The lack of controls and noncompliance was an isolated to the 22611-047-PN01, 22611-047-ARP, 22619-047-ARP and 24611-047-PN01 grant awards. This issue was isolated to fiscal year 2024. No direct payments to non-public schools were identified during fiscal year 2025. Views of Responsible Officials and Corrective Action Plan: Management concurs with the finding. During the required consultation meeting involving the Local Educational Agency (LEA), representatives from private schools, and the parents or legal guardians of nonpublic students with disabilities, the agenda will cover both allowable and un-allowed costs. The meeting agenda will clearly outline that all purchased items are the responsibility of the LEA, that gift cards are prohibited, and that all acquisitions must provide direct benefit to students with disabilities. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Sarah Claton, Cooperative School Services Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the cooperative on an ongoing basis.

View Audit 392466

Finding 1180803 (2025-002)

Material Weakness 2025

Benton Community School Corporation

IN

Procurement, Suspension & Debarment School Nutrition Programs § 200.303 § 200.318 § 200.320

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying ...

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Context: The School Corporation is a member of a purchasing cooperative, who handles the procurement process and establishes competitively awarded contracts for the majority of food service purchases. For one-time purchases such as food service equipment, the School Corporation is responsible for handling the procurement process. For one of the two small purchase method procurements sampled for testing, the school disbursed $67,000 for food service equipment maintenance in fiscal year 2024. The procurement for this item was handled at the school level. We noted the School Corporation did not obtain quotes from an adequate number of qualified sources. The School Corporation also did not properly perform a suspension and debarment check on the vendor. This finding is isolated to fiscal year 2024. There were no purchases in 2025 that required a simplified acquisition or small purchase procurement other than those procured by the food service cooperative. Views of Responsible Officials and Corrective Action Plan: Moving forward, we will implement a standardized procurement checklist to ensure that quotes are obtained from the required number of vendors in accordance with the small purchase method regulations. Child Nutrition Department will also review micropurchase vendors’ cumulative annual spending on a routine basis to determine whether purchases may exceed the micropurchase threshold and require use of the small purchase method. Documentation of all quotes received will be maintained for audit verification. In addition, staff responsible for procurement have received IDOE/USDA refresher training on federal procurement requirements, including thresholds and documentation standards, to ensure full compliance. Suspension and debarment checks will continue to be conducted and documented for all applicable vendors. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the procurement and suspension and debarment requirements on an ongoing basis.

View Audit 392466

Finding 1180800 (2025-001)

Material Weakness 2025

Benton Community School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties § 200.303

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying ...

Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of internal controls and compliance over eligibility determinations for free and reduced meals, we selected a sample of 15 applications and 45 direct certifications for testing. For 3 of the 15 applications, the School Corporation was not able to provide any documentation to support the eligibility determination due to turnover in the food service director position. Therefore, we were unable to determine whether the School Corporation complied with the eligibility requirements. The internal control and noncompliance was isolated to fiscal year 2024. Views of Responsible Officials and Corrective Action Plan: School Corporation has implemented procedures to ensure a complete record is maintained for every free and reduced-price meal application and any subsequent eligibility status change. All applications, supporting documentation, and determination records are retained as hard copy files. An electronic Benefit Issuance Document will also be retained during the year and printed as a hard copy record. Any change in eligibility status is documented with the effective date and supporting rationale to provide a clear audit trail. These procedures are now part of the School Corporation’s standard operating practices in school food service to ensure ongoing compliance and continuity moving forward. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. Missy Corns, Food Service Director, and Tracy Albertson, Director of Finance, will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.

View Audit 392466

Finding 1180797 (2025-002)

Material Weakness 2025

Easter Seals Ucp North Carolina & Virginia, Inc.

NC

Reporting Internal Control / Segregation of Duties

FINDING 2025-002 Name of Responsible Individual: Jessi Ayers Corrective Action: Management has applied the suggested changes to the schedule and will implement additional control procedures to include quarterly reconciliations and enhanced identification of federal awards at the initial stages of an...

FINDING 2025-002 Name of Responsible Individual: Jessi Ayers Corrective Action: Management has applied the suggested changes to the schedule and will implement additional control procedures to include quarterly reconciliations and enhanced identification of federal awards at the initial stages of an agreement. Anticipated Completion Date: June 30, 2026

View Audit 392464

Finding 1180796 (2025-002)

Material Weakness 2025

Quinnipiac University

CT

Student Financial Aid Special Tests & Provisions

Uniform Guidance Corrective Action Plan Year ended June 30, 2025 Federal Finding #2025-002 Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted ...

Uniform Guidance Corrective Action Plan Year ended June 30, 2025 Federal Finding #2025-002 Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Quinnipiac University agrees with the finding. An enrollment roster of students that graduated during the 2024-2025 academic year was reported to NSLDS outside the maximum 60-day window. As a result of this finding, Management implemented steps on January 5th, 2026, within the Registrar’s production calendar to run a graduate report along with monthly enrollment reports so that changes in enrollment status are reported on a timely basis. In addition, the Registrar’s office has adjusted the transmission with the National Student Clearinghouse to receive reminders of when file transmissions are coming due. If the Office of Management and Budget have questions regarding this plan, please reach out to Amy Terry, University Registrar, who is responsible for ensuring this corrective action plan is implemented, at 203-582-3933.

View Audit 392456

Finding 1180794 (2025-001)

Material Weakness 2025

Quinnipiac University

CT

Student Financial Aid

Uniform Guidance Corrective Action Plan Year ended June 30, 2025 Federal Finding #2025-001 Direct Loans are determined based on the criteria noted in 34 CFR 685.203(a),(b),(c). Students should be allocated the appropriate potion of subsidized loan funds before being awarded unsubsidized loan funds. ...

Uniform Guidance Corrective Action Plan Year ended June 30, 2025 Federal Finding #2025-001 Direct Loans are determined based on the criteria noted in 34 CFR 685.203(a),(b),(c). Students should be allocated the appropriate potion of subsidized loan funds before being awarded unsubsidized loan funds. Quinnipiac University agrees with the finding. In one instance, a student was under-awarded Subsidized Direct Loans. The student was awarded the appropriate annual amount of direct loans, however received only unsubsidized direct loans. The student should have been allocated a portion of subsidized loan funds before being awarded all unsubsidized loan funds. In another instance, a student was under-awarded Subsidized Direct Loans. Based on their demonstrated financial need, the student should have received additional subsidized loan funds before being awarded unsubsidized loan funds. As a result of this finding, Management implemented an exception report on December 9th, 2025, that will identify students who were awarded less than their maximum subsidized eligibility but have remaining need eligibility. This report will be run at least monthly to identify those students and will allow for their loans to be revised on a timely basis. In addition, the University is in the process of a software modernization project and while working with software consultants, the University plans to review all processes in accordance with best practice recommendations so that they are designed to meet current regulations. If the Office of Management and Budget have questions regarding this plan, please reach out to Kelly Osorio, University Director of Financial Aid, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7446.

View Audit 392456

Finding 1180792 (2025-004)

Material Weakness 2025

City of Croswell

MI

Reporting Subrecipient Monitoring Material Weakness

The City will establish procedures whereby the Clerk and Manager will prepare the Schedule of Expenditures of Federal Awards (SEFA) at each fiscal year end.

View Audit 392455

Finding 1180791 (2025-003)

Material Weakness 2025

City of Croswell

MI

Procurement, Suspension & Debarment

The City will adopt a policy and implement procedures to require its verification of contractors for debarment or suspension before a contractor bid is approved. The City will establish a policy to not award contracts to debarred or suspended contractors.

View Audit 392455

Corrective Action Plans

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