Corrective Action Plans

Finding 1211189 (2025-001)

Material Weakness 2025

Faneuil Hiv Housing Corporation 023-Hd-011

MA

HUD Housing Programs Cash Management

The necessary internal controls have been implemented and will follow appropriate procedures to ensure that there are no unauthorized withdrawals from the residual receipts account.

View Audit 400403

Finding 1211188 (2025-002)

Material Weakness 2025

Syntiro

ME

Reporting Allowable Costs / Cost Principles Material Weakness § 200.302 § 200.403 § 200.405

We agree with the finding and we will be reviewing and implementing the recommendations accordingly. We are committed to ensuring no duplication of costs across reporting periods and compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan ...

We agree with the finding and we will be reviewing and implementing the recommendations accordingly. We are committed to ensuring no duplication of costs across reporting periods and compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan will be implemented by June 30, 2026.

View Audit 400399

Finding 1211187 (2025-001)

Material Weakness 2025

Syntiro

ME

Allowable Costs / Cost Principles Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303 § 200.403 § 200.414

We agree with the finding and will review and implement the recommendations accordingly. We are committed to ensuring proper application of indirect costs, avoiding duplication of costs across reporting periods, and maintaining compliance with allocability requirements under Uniform Guidance on a pr...

We agree with the finding and will review and implement the recommendations accordingly. We are committed to ensuring proper application of indirect costs, avoiding duplication of costs across reporting periods, and maintaining compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan will be implemented by June 30, 2026.

View Audit 400399

Finding 1211186 (2025-002)

Material Weakness 2025

Iowa Falls Community School District

IA

Internal Control / Segregation of Duties

We understand the importance of maintaining strong internal controls and acknowledge the concerns related to segregation of duties. Given our limited staffing levels, full segregation is not always practical. However, we have established compensating controls, including enhanced supervisory oversigh...

We understand the importance of maintaining strong internal controls and acknowledge the concerns related to segregation of duties. Given our limited staffing levels, full segregation is not always practical. However, we have established compensating controls, including enhanced supervisory oversight, routine transaction reviews, and board-level monitoring when appropriate. Following a mid-year retirement, we reassessed and updated our internal procedures to strengthen controls and improve segregation of duties where feasible. We will continue to explore additional ways to address this challenge.

View Audit 400390

Finding 1211184 (2025-002)

Material Weakness 2025

Bridge House and Subsidiaries

CO

Allowable Costs / Cost Principles § 200.303

As of March 2026, management has implemented controls that properly support the distribution of personnel charges. In addition, documentation is being obtained and retained to substantiate these charges and a new procedure of documenting the review process to help ensure these errors are corrected b...

As of March 2026, management has implemented controls that properly support the distribution of personnel charges. In addition, documentation is being obtained and retained to substantiate these charges and a new procedure of documenting the review process to help ensure these errors are corrected before submission to the grantors has been implemented.

View Audit 400385

Finding 1211182 (2025-001)

Material Weakness 2025

International Fresh Produce Association

DC

Cash Management Internal Control / Segregation of Duties

While it may be impractical to request a cash reimbursement monthly due to the lag in receivingtimely invoices from sub-awardees and/or contractors, the review and computation of submitted hours confirmed and recalculated as specified within each of the different grant guidelines, Management will be...

While it may be impractical to request a cash reimbursement monthly due to the lag in receivingtimely invoices from sub-awardees and/or contractors, the review and computation of submitted hours confirmed and recalculated as specified within each of the different grant guidelines, Management will begin after 3/31/2026: 1) Request cash reimbursement monthly where practical and underlying support has been received timely and substantiated, staff hours submitted and approved; or 2) Request cash reimbursement no greater than quarterly for those same expenses as specified in #1.

View Audit 400376

Finding 1211169 (2025-003)

Material Weakness 2025

Wesleyan College

GA

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.512

The auditee will finalize and submit future Single Audit reporting packages within the Uniform Guidance deadlines and will periodically review compliance procedures as part of its internal control monitoring activities.

View Audit 400359

Finding 1211164 (2025-002)

Material Weakness 2025

Wesleyan College

GA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

All donor‑restricted balances were reviewed to identify instances where restrictions had been satisfied but not released timely. Required releases were recorded to correct net asset classifications in the general ledger. Where available, supporting documentation (e.g., expenditure reports, grant ter...

All donor‑restricted balances were reviewed to identify instances where restrictions had been satisfied but not released timely. Required releases were recorded to correct net asset classifications in the general ledger. Where available, supporting documentation (e.g., expenditure reports, grant terms, and donor agreements) was acquired and reviewed to substantiate the timing of releases. Management plans to enhance controls over donor restriction tracking by implementing clearer procedures for identifying restriction satisfaction, improving cross-department communication, and strengthening review controls to ensure timely and accurate recording of donor restriction releases. Auditor’s Evaluation of the Corrected Action Plan: Wesleyan College’s response was appropriate for immediate remediation for the current affected period. Furthermore, the plan for preventative actions appears to be appropriately focused to achieve timely and documented of releases related to satisfied purpose or time conditions.

View Audit 400359

Finding 1211159 (2025-001)

Material Weakness 2025

Wesleyan College

GA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

Wesleyan College management has completed all outstanding reconciliations for the affected periods. Reconciling items noted during the delayed reconciliations were reviewed, investigated, and resolved or appropriately aged and documented. Evidence of supervisory review has been added to completed re...

Wesleyan College management has completed all outstanding reconciliations for the affected periods. Reconciling items noted during the delayed reconciliations were reviewed, investigated, and resolved or appropriately aged and documented. Evidence of supervisory review has been added to completed reconciliations where missing. Management is in the process of developing and implementing remediation and preventative actions, including strengthening reconciliation policies, assigning clear ownership and escalation procedures, and implementing monitoring controls to ensure reconciliations are prepared and reviewed timely. These actions are expected to improve the effectiveness of controls over material account balance reconciliations. Auditor’s Evaluation of the Corrected Action Plan: Wesleyan College’s response was appropriate for immediate remediation for the current affected period. Furthermore, the plan for preventative actions appears to be appropriately focused to ensure reconciliations are prepared and reviewed timely.

View Audit 400359

Finding 1211154 (2025-003)

Material Weakness 2025

Planned Parenthood of Illinois

IL

Reporting

Finding 2025-003: Timely Submission of Single Audit Reporting and Data Collection Form to the Federal Audit Clearinghouse Finding: The Agency did not submit the Single Audit reporting package, including the Data Collection Form (DCF), to the Federal Audit Clearinghouse (FAC) by the required deadline...

Finding 2025-003: Timely Submission of Single Audit Reporting and Data Collection Form to the Federal Audit Clearinghouse Finding: The Agency did not submit the Single Audit reporting package, including the Data Collection Form (DCF), to the Federal Audit Clearinghouse (FAC) by the required deadline of March 31, 2026. Correction Actions Taken: Management submitted the Agency’s fiscal year 2025 Single Audit package, including the DCF, to the FAC on April 30, 2026. Management acknowledges that the Single Audit reporting package, including the Data Collection Form (DCF), was submitted after the required deadline. The delay resulted from a combination of internal and external factors, including delayed receipt of finalized data necessary to complete the audit and significant personnel turnover of internal and external professionals working on the single audit during the reporting period. In addition, a federal government shutdown impacted access to federal portals and the ability to confirm current submission requirements in a timely manner. Once the necessary information became available and federal systems were accessible, management worked with the auditors to complete and submit the reporting package promptly. Management has since strengthened internal coordination around audit data readiness. Contact Person: Tonya Tucker, Chief Financial Officer Anticipated Completion Date: Implemented as of the fiscal year ended June 30, 2026

View Audit 400357

Finding 1211153 (2025-002)

Material Weakness 2025

Planned Parenthood of Illinois

IL

Reporting

Finding 2025-002: Reporting – ALN 93.217 Finding: During the fiscal year ended June 30, 2025, the Agency did not timely submit three of four required quarterly Federal Financial Reports (FFRs) for the Family Planning Services program. Correction Actions Taken: Management acknowledges that three of f...

Finding 2025-002: Reporting – ALN 93.217 Finding: During the fiscal year ended June 30, 2025, the Agency did not timely submit three of four required quarterly Federal Financial Reports (FFRs) for the Family Planning Services program. Correction Actions Taken: Management acknowledges that three of four quarterly Federal Financial Reports were submitted after their respective deadlines during the fiscal year ended June 30, 2025. These delays occurred during a period of significant administrative transition, including the departure of key personnel directly responsible for federal reporting and the reassignment of duties mid cycle. Despite these challenges, the impacted reports were submitted within two and seven days of the required deadlines. At no time was there an absence of monitoring or an intent to delay compliance. Management has since implemented enhanced internal tracking of federal reporting deadlines, clarified role assignments during staff transitions, and initiated earlier internal review of quarterly reports to ensure timely submission going forward. Contact Person: Tonya Tucker, Chief Financial Officer Anticipated Completion Date: Implemented as of the fiscal year ended June 30, 2026

View Audit 400357

Finding 1211152 (2025-002)

Material Weakness 2025

Kayenta Unified School District No.27

AZ

Equipment & Real Property Management § 200.313

Finding Number: 2025‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Arlene Laughter, Business Coordinator Anticipated Completion Date: December 2026 Planned Corrective Action: The District plans to hire a GFA Specialist resp...

Finding Number: 2025‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Arlene Laughter, Business Coordinator Anticipated Completion Date: December 2026 Planned Corrective Action: The District plans to hire a GFA Specialist responsible for overseeing capital asset requirements. Duties will include completing the physical inventory, reconciling stewardship, and capital assets with the district’s general fixed assets list and maintaining records to support annual depreciation calculations and other required information. Reason Findings Were Not Corrected: The Business Office has experienced staffing shortages, particularly in Payroll and Grants Management, both of which have pressing deadlines. As a result, Fixed Assets was frequently deprioritized. Recognizing the importance of timely management in this area, the Business Office will establish a dedicated position focused exclusively on Fixed Assets.

View Audit 400355

Finding 1211151 (2025-001)

Material Weakness 2025

Kayenta Unified School District No.27

AZ

Reporting § 200.512

Finding Number: 2025‐001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Impact Aid 84.041 Education Stabilization Fund 84.425 Contact Person: Arlene Laughter, Business Coordinator Anticipated Completion Date: December 2026 Planned Corrective Action: The District intends to stre...

Finding Number: 2025‐001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Impact Aid 84.041 Education Stabilization Fund 84.425 Contact Person: Arlene Laughter, Business Coordinator Anticipated Completion Date: December 2026 Planned Corrective Action: The District intends to strengthen controls over all financial reporting and records retention to ensure that all documentation is properly prepared and accessible for the timely completion of financial reports. With the recent addition of an experienced Payroll Specialist and the ongoing recruitment for a GFA Specialist, the District will address all relevant areas, thereby facilitating compliance with required reporting deadlines. Reason Findings Were Not Corrected: The Business Office has experienced staffing shortages in key departments, including Payroll, Grants Management, and General Fixed Assets, each of which is responsible for meeting critical deadlines. Due to these staffing constraints, the District was unable to dedicate adequate resources to fulfill the required timelines and ensure that all documents were properly prepared and available for completion of the financial reports.

View Audit 400355

Finding 1211099 (2025-002)

Material Weakness 2025

Aberdeen School District No. 5

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Finding ref number: 2025-002 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations, 216 North G Street, Aberde...

Finding ref number: 2025-002 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations, 216 North G Street, Aberdeen, WA. 98520. (360) 538-2007 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for non-concurrence). The district will make sure all staff are listed on the Semi-Annual Certifications. Staff with braided funding will have a PAR with monthly verifications. Anticipated date to complete the corrective action: February 1, 2026

View Audit 400341

Finding 1211096 (2025-001)

Material Weakness 2025

Aberdeen School District No. 5

WA

Procurement, Suspension & Debarment School Nutrition Programs

Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Jaime Matisons, Food Service Manager, 900 Cleveland, Aberdeen, WA. 98520 ...

Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Jaime Matisons, Food Service Manager, 900 Cleveland, Aberdeen, WA. 98520 (360) 538-2256 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for non-concurrence). The cooperative provides all bid documents for the district representatives to review, this included suspension and debarment documentation. After review at a meeting of the cooperative membership, the members vote on accepting the bid. The cooperative keeps all documentation on file for review of the auditors. Documentation of this was provided to the auditor. Anticipated date to complete the corrective action: April 2026

View Audit 400341

Finding 1211091 (2025-003)

Material Weakness 2025

Jewish Family Service of Dallas, Inc.

TX

Reporting Matching / Level of Effort / Earmarking Material Weakness

Finding 2025-003: Preparation of the schedule of federal expenditures (SEFA) – material weakness in internal controls over reporting. Management Response: Management acknowledges the finding and agrees that improvements are needed in the preparation and review of the Schedule of Expenditures of Fede...

Finding 2025-003: Preparation of the schedule of federal expenditures (SEFA) – material weakness in internal controls over reporting. Management Response: Management acknowledges the finding and agrees that improvements are needed in the preparation and review of the Schedule of Expenditures of Federal Awards (SEFA). The audit identified that controls over the accuracy, completeness, and reconciliation of the SEFA to the general ledger and financial statements were not consistently performed or documented. This condition developed during a period of organizational transition, including changes in financial leadership, as well as increased complexity in federal funding and reporting requirements. These factors contributed to gaps in oversight and consistency in the SEFA preparation process. To address this finding, management is implementing the following corrective actions: • Establishing a formal, documented SEFA preparation process, including standardized templates and procedures • Implementing quarterly and year-end reconciliation processes to ensure grant activity is accurately recorded and aligned with the general ledger • Strengthening review controls, including secondary review by the Controller and CFO prior to finalization Enhancing grant tracking mechanisms to ensure expenditures, revenues, and matching requirements are properly classified • Providing targeted training to staff responsible for grant accounting and SEFA preparation Responsible party: Brenda Colon, CFO Expected Completion Date: October 2026

View Audit 400338

Finding 1211090 (2025-002)

Material Weakness 2025

Jewish Family Service of Dallas, Inc.

TX

Allowable Costs / Cost Principles Material Weakness

Finding 2025-002: Allowable Costs and Activities – Material Weakness in Internal Controls over Compliance Management Response: Management acknowledges the finding and agrees that improvements are necessary in the design and execution of internal controls related to allowable costs and activities for...

Finding 2025-002: Allowable Costs and Activities – Material Weakness in Internal Controls over Compliance Management Response: Management acknowledges the finding and agrees that improvements are necessary in the design and execution of internal controls related to allowable costs and activities for federal programs. The audit identified inconsistencies in how grant expenditures were reviewed, approved, and supported, as well as gaps in ensuring costs charged to grants were fully aligned with applicable requirements. This condition arose during a period of organizational transition, including changes in financial leadership, combined with increased volume and complexity of federal funding. These factors contributed to inconsistencies in control execution, documentation, and oversight. To address this finding, management is implementing the following corrective actions: • Enhancing policies and procedures governing allowable costs to ensure alignment with federal grant requirements • Strengthening pre- and post-expenditure review processes to verify that all costs charged to grants are allowable, properly supported, and accurately recorded • Implementing formal, documented reconciliation procedures for grant expenditures on a monthly basis • Establishing secondary review controls involving both the Controller and CFO to ensure compliance and accuracy • Providing targeted training to program and finance staff on allowable cost principles and grant compliance requirements • Improving documentation standards to ensure all approvals and supporting evidence are complete and audit-ready. Responsible party: Brenda Colon, CFO Expected Completion Date: October 2026.

View Audit 400338

Finding 1211089 (2025-001)

Material Weakness 2025

Jewish Family Service of Dallas, Inc.

TX

Allowable Costs / Cost Principles Cash Management Material Weakness

Finding 2025-001: Allowable Costs and Activities – Material Weakness in Internal Controls over Compliance Management Response: Management acknowledges the finding and agrees that improvements are required in internal controls over compliance related to allowable costs and activities. This condition ...

Finding 2025-001: Allowable Costs and Activities – Material Weakness in Internal Controls over Compliance Management Response: Management acknowledges the finding and agrees that improvements are required in internal controls over compliance related to allowable costs and activities. This condition arose during a period of organizational transition and increased complexity in funding sources and compliance requirements, which impacted consistency in control execution. Under the direction of the CFO, the organization is implementing the following corrective actions for the upcoming fiscal year: • Strengthening review and approval processes over grant expenditures and payroll allocations • Implementing formal, documented monthly reconciliations for all grant-related accounts • Establishing secondary review controls between the Controller and Accounting Clerk to ensure accuracy and compliance • Providing targeted training under the direction of the CFO for staff involved in financial reporting and grant compliance • Enhancing documentation standards to ensure all control activities are properly evidenced and audit-ready The organization has also reinforced financial leadership capacity to ensure appropriate oversight, adherence to GAAP, and alignment with federal compliance requirements. Responsible party: Brenda Colon, CFO Expected Completion Date: October 2026.

View Audit 400338

Finding 1211082 (2025-001)

Material Weakness 2025

Rowan College of South Jersey

NJ

Student Financial Aid

Corrective Action Plan FINDING NO. 2025-001 PROGRAM U.S. Department of Education - Student Financial Aid Cluster (ALN 84.268) REQUIREMENT 34 CFR § 668.165(a) CRITERIA OR SPECIFIC REQUIREMENT Under 34 CFR § 668.165(a), institutions are required to notify borrowers in writing ( or electronically) of t...

Corrective Action Plan FINDING NO. 2025-001 PROGRAM U.S. Department of Education - Student Financial Aid Cluster (ALN 84.268) REQUIREMENT 34 CFR § 668.165(a) CRITERIA OR SPECIFIC REQUIREMENT Under 34 CFR § 668.165(a), institutions are required to notify borrowers in writing ( or electronically) of the anticipated date and amount of each Direct Loan disbursement, as well as the borrower's right to cancel all or a portion of the loan. This notification must be sent within a required time frame of crediting the student's account. CONDITION The College did not provide required notifications to students (or parents, where applicable) regarding the disbursement of Federal Direct Loans for the Spring semester during the award year. RECOMMENDATION The College should implement and document procedures to ensure that all required Direct Loan disbursement notifications are generated and delivered to students (or parents, where applicable) in a timely manner for all payment periods during the award year. VIEW OF RESPONSIBLE OFFICIALS The College concurs with the finding and recommends and presents the following correctiveaction plan to be implemented. PLANNED CORRECTIVE ACTION The College will implement a standardized and automated process within its financial aid system to ensure that disbursement notifications are generated and delivered to all Direct Loan recipients (or parents, where applicable) for each payment period within the required timeframe. Notifications will include the anticipated disbursement date, amount, and the borrower's right to cancel all or a portion of the loan. Additionally, the College will establish documented procedures requiring staff to: • Verify that notifications are generated for each disbursement period • Maintain system-generated records evidencing the date and method of notification • Perform periodic reconciliations between disbursement records and notification logs to ensure completeness The procedures will be incorporated into the Financial Aid Policies and Procedures Manual, and staff will receive training on the updated requirements. RESPONSIBLE PARTY Associate Vice President, Student Aid & Records ANTICIPATED COMPLETION DATE August 31, 2025, with full implementation beginning in the Fall 2025 term Signed Michael Chando, Associate Vice President

View Audit 400334

Finding 1211081 (2025-003)

Material Weakness 2025

Ana G. Mendez University, Inc.

FL

Student Financial Aid Reporting

Due to challenges related to the implementation and reporting functionality of the Anthology Student system, AGMU temporarily experienced difficulties in identifying enrollment status changes and reporting the changes to NSLDS. Errors and delays related to enrollment reporting were primarily due to ...

Due to challenges related to the implementation and reporting functionality of the Anthology Student system, AGMU temporarily experienced difficulties in identifying enrollment status changes and reporting the changes to NSLDS. Errors and delays related to enrollment reporting were primarily due to AGMU’s delay in identifying withdrawn students (discussed in Finding 2025-2) and identifying the withdrawal date used in the R2T4 calculation so that the date could be reported to NSLDS. AGMU agrees with the auditor’s recommendation that implementing additional processes and controls around enrollment reporting will improve compliance. To resolve this issue and prevent recurrence, AGMU is completing the corrective actions described below. Corrective Action 1: Confirming and reporting withdrawal dates for award years 2023-24 and 2024-25 As part of the withdrawn students file review described in the corrective actions for Finding 2025-2, AGMU is confirming the withdrawal date for students who did not complete the payment period. Once the withdrawal dates have been confirmed (and/or previous withdrawal dates are confirmed), enrollment statuses for impacted students will be updated in NSLDS as appropriate. Corrective Action 2: Monitoring for enrollment status changes To identify enrollment status changes timely, AGMU developed a report (“Customized Enrollment Status Change” report) that identifies students with enrollment status changes, the effective date of enrollment status changes, and potential Title IV adjustments related to enrollment status changes (e.g., Pell Grant recalculations). AGMU generates this report weekly to ensure that any student with an enrollment status change is reviewed, and timely Title IV award revisions are completed, if applicable. Corrective Action 3: Validation of the Enrollment Reporting Roster To validate the accuracy of the Enrollment Reporting Roster, AGMU will be developing a report to identify students with enrollment status changes and the effective date of enrollment status changes. AGMU is determining if it could use the existing report (“Customized Enrollment Status Change” report) for this process. Once AGMU has finalized its process and report, AGMU plans to generate this report monthly to confirm accurate information regarding student enrollment status is being extracted from the Anthology Student system and correctly transmitted to NSLDS via the Enrollment Reporting Roster. Corrective Action 4: Timely identification of ISIR comment codes Although AGMU had policies and procedures related to determining student eligibility, the procedures required revisions due to the Anthology Student implementation. To identify students for whom ISIR comment codes appear after Title IV aid is awarded and/or disbursed (i.e., on a subsequent ISIR), AGMU developed a report (“Customized Ineligible Funds” report) that identifies potentially impacted students, Title IV funds awarded and disbursed, and ISIR comment codes. AGMU generates this report weekly to ensure any student with an ISIR comment code is reviewed and any funds that must be returned are identified timely. Corrective Action 5: Review and revision of policies and procedures related to enrollment reporting. AGMU is in the process of revising its existing policies and procedures related to enrollment reporting to ensure they correctly describe processes in the Anthology system. Corrective Action 6: Ongoing monitoring by and support from system office personnel SUAGM central office financial aid personnel will perform and assist with quality assurance activities related to AGMU’s enrollment reporting such as: 1. Creating reports related to official and unofficial withdrawals to verify that enrollment status changes are identified on a timely basis and accurately reflected in student records in NSLDS. 2. In coordination with the Registrar, creating an enrollment reporting manual. 3. Developing NSLDS enrollment reporting training and requiring that all staff with enrollment reporting responsibilities attend the training. Corrective Action 7: Enrollment reporting file review AGMU is in the process of planning a comprehensive file review of enrollment reporting for the 2023-24 and 2024-25 award years. At this time, AGMU is prioritizing the withdrawn students file review so that unearned funds can be returned to the U.S. Department of Education as soon as possible. Once the withdrawn students file review is completed, AGMU will begin work on the enrollment reporting file review.

View Audit 400332

Finding 1211078 (2025-002)

Material Weakness 2025

Ana G. Mendez University, Inc.

FL

Student Financial Aid

Due to challenges related to the implementation and reporting functionality of the Anthology Student system, AGMU temporarily experienced difficulties in identifying students who officially or unofficially withdrew from the payment period. Although the compliance issues identified in this finding ar...

Due to challenges related to the implementation and reporting functionality of the Anthology Student system, AGMU temporarily experienced difficulties in identifying students who officially or unofficially withdrew from the payment period. Although the compliance issues identified in this finding are primarily attributable to system implementation challenges, AGMU understands the importance of timely returns to the U.S. Department of Education related to withdrawn students and is engaged in a comprehensive effort to address deficiencies, prevent recurrence, and return any funds due from AGMU as soon as feasible. To resolve this issue and prevent recurrence, AGMU is completing the corrective actions described below. Corrective Action 1: Student eligibility and withdrawn students file review AGMU completed a file review of the 2023-24 and 2024-25 award years to identify students who (1) failed to begin attendance in a course or courses, and/or (2) had ISIR comment codes requiring resolution. As a result of this file review, AGMU has recalculated Title IV awards for impacted students. AGMU has also completed a file review of the 2023-24 and 2024-25 award years to confirm it has identified all students who officially and unofficially withdrew from the payment period. AGMU is now in the process of compiling system data to perform or re-perform R2T4 calculations for these students, as appropriate. Once AGMU has completed the R2T4 file review and confirmed if additional returns are required for the impacted students, AGMU will report the recalculated award amounts to COD and return funds via G5. Corrective Action 2: Development and enhancement of reports to facilitate the identification of withdrawn students and support the R2T4 calculation. AGMU developed new reports and enhanced existing reports that will aid the institution in timely identifying withdrawn students and performing accurate R2T4 calculations, including but not limited to the following reports that AGMU reviews weekly: • A report (“Customized Enrollment Status Change” report) that identifies students with enrollment status changes that may indicate the student ceased attending the payment period and thus a R2T4 is required. • Reports (“AGMU R2T4 Calculation Detail” and “AGMU R2T4 Review by Term” report) that extract data used in the R2T4 calculation from the student information system, such as term dates, module dates, and Title IV disbursements. • A report (“R2T4 Return of Funds” report) that track R2T4s performed in the system for which funds have not yet been returned via COD and potential post-withdrawal disbursements to student and parent borrowers. • A report (“Canvas Last Academic Activity” report) from the learning management system that confirms the student’s last date of academic engagement in an online course to assist in determining the student’s withdrawal date. AGMU uses the above reports jointly with reviewing live student data in the Anthology Student system when performing a R2T4 calculation, returning funds or disbursing or offering a post-withdrawal disbursement to a student or parent borrower. Corrective Action 3: Review and revision of policies and procedures related to student eligibility. AGMU is in the process of revising its existing policies and procedures related to student eligibility determinations to ensure they correctly describe processes in the Anthology system. AGMU is also in the process of revising its existing policies and procedures related to identifying withdrawn students, performing the R2T4 calculation, and returning funds via COD to ensure they correctly describe processes in the Anthology system. Corrective Action 4: Ongoing monitoring by and support from system office personnel SUAGM central office financial aid personnel perform and assist with quality assurance activities related to AGMU’s determination of student eligibility such as: 1. Reporting parameters are reviewed and refined collaboratively by Financial Aid, Registrar, and Information Technology (IT) staff to ensure that custom reports capture accurate, complete, and relevant data. This process includes validating data fields, logic, and calculation criteria used to support enrollment status changes and student eligibility analysis (i.e., the monitoring of ISIR comment codes). 2. Customized reports developed for enrollment status changes and student eligibility analysis are reviewed biweekly to identify changes in enrollment intensity, eligibility indicators, and potential ineligible disbursements. These reports support the timely review of aid adjustments and identification of cases requiring resolutions or returns. 3. Student record samples are selected and discussed at regularly scheduled validation meetings. These meetings include representatives from the Registrar, Financial Aid, Bursar, IT, and Compliance to confirm data accuracy, validate reporting results, and identify any necessary process or reporting adjustments. SUAGM central office financial aid personnel also perform and assist weekly with quality assurance activities related to AGMU’s identification of withdrawn students, performing the R2T4 calculation, and returning funds via COD, such as: 1. Reviewing reports generated by AGMU related to official and unofficial withdrawals, including validation of withdrawal dates, last date of academic activity, and enrollment status changes identified through registrar and financial aid data. 2. Reviewing R2T4 calculations prepared by AGMU to confirm accurate payment period dates and scheduled days for programs offered in modules, earned and unearned aid determinations, and amounts scheduled for return. 3. Monitoring the timely submission of returns through COD, including the review of refund activity reports and confirmation that returns are properly recorded and reconciled. Corrective Action 5: Ongoing training of AGMU personnel on key R2T4 concepts AGMU has mandated additional R2T4 training for personnel who interact with the R2T4 process in the financial aid office, registrar’s office, and bursar’s office. In addition to requiring that personnel attend training organized by SUAGM, AGMU employees have participated in webinars offered by Federal Student Aid, NASFAA, and third-party servicers, accounting firms, and law firms with expertise in R2T4 concepts.

View Audit 400332

Finding 1211075 (2025-003)

Material Weakness 2025

City of West Melbourne, Florida

FL

Procurement, Suspension & Debarment § 200.303

2025-003 Suspension and Debarment Recommendation: The City should put controls in place to verify SAM checks before authorizing a contract or a purchase order with a vendor for a covered transaction. Corrective Action: Management recognizes the importance of compliance with federal suspension and de...

2025-003 Suspension and Debarment Recommendation: The City should put controls in place to verify SAM checks before authorizing a contract or a purchase order with a vendor for a covered transaction. Corrective Action: Management recognizes the importance of compliance with federal suspension and debarment requirements. Management has implemented procedures to ensure compliance with suspension and debarment requirements for federally funded transactions. As part of the procurement process, vendors responding to solicitations for grant-funded projects will be required to provide evidence of active SAM registration and certify that they are not suspended or debarred. In addition, prior to execution of contracts or issuance of purchase orders for covered transactions, management will perform and document an independent SAM.gov verification as part of standard pre-award procedures to confirm vendor eligibility. Responsible Parties: B. Keith Smith, Finance Director Anticipated Correction Date: September 30, 2026

View Audit 400324

Finding 1211073 (2025-004)

Material Weakness 2025

City of West Melbourne, Florida

FL

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2025-004 Reporting Recommendation: The City should review the underlying data along with the report to ensure that report agrees with the support and the underlying data is correct. Corrective Action: Management recognizes the importance of accurate and complete reporting to the U.S. Treasury. While...

2025-004 Reporting Recommendation: The City should review the underlying data along with the report to ensure that report agrees with the support and the underlying data is correct. Corrective Action: Management recognizes the importance of accurate and complete reporting to the U.S. Treasury. While procedures were in place, the review of underlying data was not sufficient to ensure accuracy and completeness prior to submission. The issue was limited to a single report and was corrected in the subsequent U.S. Treasury reporting cycle in accordance with program requirements. To prevent recurrence, management has enhanced its review procedures over grant reporting to include reconciliation of underlying data and validation checks for inconsistencies prior to report submission. Additionally, a secondary level of review will be performed to ensure reports are complete and accurate before submission to the U.S. Treasury. Responsible Parties: B. Keith Smith, Finance Director Anticipated Correction Date: September 30, 2026

View Audit 400324

Finding 1211042 (2025-003)

Material Weakness 2025

Hui No Ke Ola Pono, Inc.

HI

Cash Management § 200.305

2025-003-Significant Advance Drawdown on Federal Fund for Six Months, United States Department of Health and Human Services, Native Hawaiian Health Care Systems 93.932, On January 20, 2025, we received the first Executive Order from President Trump, placing a hold on federal funding. We were advised...

2025-003-Significant Advance Drawdown on Federal Fund for Six Months, United States Department of Health and Human Services, Native Hawaiian Health Care Systems 93.932, On January 20, 2025, we received the first Executive Order from President Trump, placing a hold on federal funding. We were advised that the PMS (Payment Management System) would be down and drawdowns would not be available until further notice. From January 20th, 2025, we tried to complete a drawdown, and the PMS system was not available. On January 28, 2025, finally accessing the PMS system, we estimated our January expenses and completed a drawdown for $200,000. At the time, we needed the HRSA funding to cover January costs already spent. Due to the uncertainty of the HRSA funding availability, and when the PMS system would be available, we estimated another drawdown the following day, to cover at least 2 more months of HRSA expenses. The other Native Hawaiian Health Systems could not access the PMS system, which prompted us to complete another drawdown to cover HRSA expenses for the remainder of the fiscal year. We were able to expend all HRSA funding that was drawn down by fiscal year ending July 31, 2025.

View Audit 400320

Finding 1211041 (2025-002)

Material Weakness 2025

Hui No Ke Ola Pono, Inc.

HI

Reporting

2025-002-Incomplete and Inaccurate Schedule of Expenditures of Federal Awards (SEFA), Health Resources and Services Administration Native Hawaiian Health Care 93.932, During the fiscal year 2024, we experienced a high volume of funding sources due to the Lahaina wildfires. It was extremely difficult...

2025-002-Incomplete and Inaccurate Schedule of Expenditures of Federal Awards (SEFA), Health Resources and Services Administration Native Hawaiian Health Care 93.932, During the fiscal year 2024, we experienced a high volume of funding sources due to the Lahaina wildfires. It was extremely difficult to communicate to the grantor if the funding was a result of a federal award. As of January 2025, the Executive Director inquires with the funding source if the award is a result of federal funds. In many cases, the grantor is unable to provide these details.

View Audit 400320

Corrective Action Plans

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