Criteria or Specific Requirement: Per 2 CFR 200.303 - Internal Controls and the OMB Compliance Supplement: Education Stabilization Fund, Reporting- The District is required to have internal controls, including segregation of duties, over reporting for quarterly expenditure claims. These internal controls should be effective in preventing, detecting, and correcting misstatements in the reports. Condition: Multiple individuals are responsible for the preparation and submission of the District's quarterly expenditure reports; however, the expenditure reports filed for September 30, 2024 included expenditures in the amount of $22,040 that were neither obligated nor liquidated by the date of the report. Questioned Costs: None. Context: The District's internal controls did not identify and correct a material misstatement in the Septmeber 30, 2024 expenditure report for the 2025 Covid-19 - Community Partnership grant - C3 program. Effect: The September 30, 2024 expenditure report was filed overstating expenditures by $22,040. Cause: The individual responsible for reviewing the expenditure report did not have adequate knowledge of the federal reporting requirements; consequently, errors on quarterly expenditure reports were not identified in the review. Recommendation: Personnel with adequate knowledge of reporting requirements should review all expenditure reports to ensure any errors are identified and corrected before the expenditure report is submitted. Management's Response: Management does not disagree with this finding, and competent personnel will review all future expenditure reports.
2025-002 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles – Significant Deficiency in Internal Control over Compliance and Noncompliance Federal Agencies: Department of Agriculture Federal Assistance Listing Numbers: 10.182 Programs: Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments Award/Pass-Through Entity Identifying Numbers: F4303 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. Per 2 CFR §200.403(e), costs must be in accordance with Generally Accepted Accounting Procedures (GAAP) to be allowable under federal awards. Condition: During the testing of non-payroll related costs for the year ended June 30, 2025, two of 20 transactions selected for testing within the program were incurred in the year ended June 30, 2024. This practice is not in accordance with GAAP, which requires that costs be recorded in the period in which they are incurred. Both transactions were incurred and reported within the grant’s period of performance. Cause: The Organization did not have adequate policies and procedures in place to ensure that federal expenditures are properly accrued and recorded in the fiscal year in which the costs are actually incurred. Effect or Potential Effect: Failure to accrue costs in accordance with GAAP may result in expenditures being materially misstated on the schedule of expenditures of federal awards that could lead to inaccurate reporting to the federal agencies. Questioned Costs: Known Questioned Costs: $5,095 Likely Questioned Costs: $31,125 Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Known questioned costs are $5,095 out of the total non-payroll related costs during the year ended June 30, 2025, which were $443,033. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend the Organization implement policies and procedures to accrue for federal expenditures in the period the costs were incurred to ensure costs are being recorded in accordance with GAAP and the schedule of expenditures of federal awards is representative of all federal expenditures incurred in the reporting year. Views of Responsible Officials: Management agrees with the finding. Management is formalizing and enhancing policies and procedures over cutoff and accruals.
2025-003 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles – Significant Deficiency in Internal Control over Compliance Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.239 Programs: Home Investment Partnerships Program Award/Pass-Through Entity Identifying Numbers: #165 59601114110 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: Internal controls failed to prevent or detect an incorrect unallowable cost from being allocated to the grant. The cost was able to be replaced with allowable costs. Cause: Employees responsible for determining the allowability of costs did not have adequate training on allowably costs.. Effect or Potential Effect: Without adequate controls to ensure that costs allocated to federal programs are allowable, the Organization could incorrectly charge expenditures to the federal program. Questioned Costs: None. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. The cost was replaced with allowable costs. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend the Organization ensure internal controls are designed and performed by individuals with sufficient training on federal awards and allowable costs. Views of Responsible Officials: Management agrees with the finding. Management is strengthening internal controls over allowable costs and providing additional training to staff working with federal awards.
2025-005 – Special Tests and Provisions, Wage Rate Requirements – Significant Deficiency in Internal Control over Compliance Federal Agencies: Department of Housing and Urban Development Federal Assistance Listing Numbers: 14.251 Programs: Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Award/Pass-Through Entity Identifying Numbers: B-23-CP-WA-1539 Criteria: The Uniform Guidance in 2 CFR §200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: The Organization did not implement internal controls to ensure certified payrolls were being submitted. During the testing of certified payrolls, it was identified that three of 21 contractor and subcontractor selections of certified payrolls were not being submitted timely. Cause: Internal controls were not designed to ensure the certified payrolls were being submitted timely and were received and reviewed by the nonfederal entity with each pay application from the contractor. Effect or Potential Effect: Certified payrolls could fail to be prepared and/or wages not in accordance with federal requirements could be allowed in error. Questioned Costs: None. Context: This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Total contractor costs were $1,162,720. Identification as a Repeat Finding: Not a repeat finding. Recommendation: We recommend the Organization provide training to staff on all applicable compliance requirements to the Organization and implement internal controls to ensure certified payrolls are received prior to payment of a pay application. Views of Responsible Officials: Management agrees with the finding. Management is establishing policies and procedures to ensure certified payrolls are received by contractors and subcontractors at regular intervals over the course of a project.
Federal Agency: Department of Education Federal Program Name: Wisconsin Charter Schools Program Waiver Cohort Assistance Listing Number: 84.282 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2025-138005-DPI-WCSPWC1-360 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria: According to 2 CFR, Part 200.303 of the Office of Management and Budget’s Uniform Grant Guidance, a non-Federal entity must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition: One City Schools, Inc. did not have a process in place to review funding claims prior to submission. Questioned costs: None Context: We sampled 5 cash management requests, noting that 3 were not reviewed prior to submission. Cause: Policies and procedures were put in place, but were not being followed. Effect: Incomplete or inaccurate information could be reported on funding claims. Repeat Finding: Yes (2024-004) Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Views of responsible officials: One City Schools, Inc. agrees with the finding and are working on implementing policies and procedures over reviewing claims prior to submission.
Federal Agency: Department of Education Federal Program Name: Wisconsin Charter Schools Program Waiver Cohort Assistance Listing Number: 84.282 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Number(s): 2025-138005-DPI-WCSPWC1-360 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter Criteria: According to 2 CFR, Part 200.303 of the Office of Management and Budget’s Uniform Grant Guidance, a non-Federal entity must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition: One City Schools, Inc. did not have controls in place to ensure period of performance requirements were adhered to. Questioned costs: None Context: We identified 3 expenditures not recorded correctly as they were not incurred by year-end and were subsequently removed from the SEFSA. Cause: Policies and procedures were put in place, but were not being followed. Effect: This could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: We recommend that the Organization maintain effective internal controls over period of performance requirements. Views of responsible officials: One City Schools, Inc. agrees with the finding and are working on implementing internal controls over period of performance.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via the National Student Loan Data System (NSLDS) within the timeframe prescribed by the Secretary. Unless the institution plans to submit its next updated enrollment report to the Secretary within 60 days, a school must notify the Secretary within 30 days after the date that the school discovers a change. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days to ensure attendance changes for students are reported within 60 days of the change. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half -time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Internal controls 2 CFR 200.303(a) states the non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition During our audit we found one (1) of forty (40) students selected for testing whose enrollment status was not timely transmitted to NSLDS. KPMG notes that for this exception, the student’s enrollment status was never reported to NSLDS although the College was aware of their enrollment status. Because the College did not have a significant number of students impacted by the specific cause for the exception noted, the noncompliance is not a reportable finding. However, the College did not have a control in place to identify errors in enrollment status transmissions and this control deficiency is considered to be a significant deficiency. Cause The condition resulted from the College’s internal controls not being designed at a level of precision to ensure all enrollment status changes are accurately and timely transmitted to NSLDS. Possible Asserted Effect Not identifying inaccurate, delayed, or lack of submission of student enrollment status information could have impacted the determinations that lenders and services of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government’s payment of interest subsidies. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding The conditions found do not constitute a repeat finding from the prior year. Recommendation We recommend that the College review its processes to ensure that appropriate controls are put in place to identify any errors in the reporting of enrollment changes. Views of College Officials Recommendation accepted. Please refer to corrective action plan.
Finding 2025-004: Payroll Processing Controls Criteria: In accordance with 2 CFR §200.303, management is responsible for establishing and maintaining effective internal control over federal awards, including controls to ensure payroll transactions are processed accurately and timely. Condition: During control testing over a major federal program, three instances were identified where payroll changes were not entered into the payroll system in a timely manner; however, the Organization subsequently processed appropriate retroactive adjustments. Cause: The Organization lacks procedures to ensure payroll changes are entered timely and reviewed for accuracy. Effect: Employees may not be compensated accurately or timely, and payroll expenses could be recorded in an incorrect period. Although corrections may be made, errors may not be identified or resolved in a timely manner. Recommendation: Management should implement procedures to ensure all approved payroll changes are entered timely into the payroll system and reviewed for accuracy.
Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 – School Breakfast Program; 10.555 – National School Lunch Program Federal Award Number: 255GA32N1199 (Year: 2025) Questioned Costs: None Identified Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that expenditures are reviewed and approved prior to payment. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture, and GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $1,582,957.71 were expended and reported on the Screven County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2025. Criteria: As a recipient of federal awards, the School District is required to establish, document, and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Condition: Auditors performed a review of various expenditure activity associated with the CNC programs to determine if appropriate internal controls were implemented and applicable compliance requirements were met. The following deficiencies were identified: • A sample of 40 expenditures was randomly selected for testing using a nonstatistical sampling approach. Evidence of review and approval was not reflected for seven of the expenditures tested. • A sample of 40 procurement transactions was randomly selected for testing using a non-statistical sampling approach. Evidence of review and approval was not reflected for five of the transactions tested. Cause: The School District did not follow its policies and procedures that govern the approval of expenditure for federal programs. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance related to the CNC programs. Failure to ensure that expenditures are appropriately approved exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds for unallowable purposes and/or with unqualified vendors. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures. Recommendation: The School District should evaluate and improve internal control procedures to ensure that expenditures are reviewed and approved prior to payment. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding
Criteria or Specific Requirement: Per 2 CFR 200.303 - Internal Controls and the OMB Complaince Supplement: Child Nutrition Cluster, Reporting - The District is required to have internal controls, including segregation of duties, over reporting of monthly reimbursement claims. Condition: The same individiual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval before submission. Questioned Costs: The condition has resulted in no identified questioned costs. Context: Currently one individual is responsible for preparing and submitting the monthly reimbursement claims. Effect: Meal claims could be submitted to the Illinois State Board of Education that do not accurately reflect the number of meals served. Consequently, the District could be over- or under-reimbursed by this program. Cause: Abscense of formal internal control procedures resulted in one person performing all reporting functions. Recomendation: Implement segregation of duties by requiring one person to prepare the monthly claim and a second person (e.g., supervisor) to review and approve the claim before submission. The review should be suppported with signatures or electronic approval logs. Management's Reponse: A corrective action plan will be developed and implemented. A secondary review of the meal claim to the supporting documents will be performed before the meal claim is submitted.
Criteria or Specific Requirement: Per 2 CFR 200.303 a grant recipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District's internal controls did not affectively monitor the grant budget. Questioned Costs: None. Context: The District did not compare actual expenditures in each grant line item with available remaining budget amounts. Effect: The District claimed expenditures in grant lines that had already been fully expended. Cause: When expenditures were reviewed and approved they were not compared to the remaining budget. Recommendation: The District should accurately track the actual expenditures compared to the remaining budget for each grant line. Management's Response: The District agrees with the finding and a corrective action plan and proper internal controls will be implemented.
Criteria or Specific Requirement: Per 2 CFR 200.303 a grant recipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: Management reviewed expenditure reports prior to submission, however this review did not detect or correct errors in the expenditure report. Questioned Costs: None. Context: The District submitted innacurate expenditure reports which did not agree with the accounting records. Effect: The District reported expenditures that could not be supported by the accounting records. Cause: When the expenditure reports were reviewed they were not accurately compared to the accounting records. Recommendation: Management's review of the expenditure reports should include a comparison of the functions and objects reported on the report to the accounting records. Management's Response: The District agrees with the finding and a corrective action plan and proper internal controls will be implemented.
2025-001 Procurement Suspension and Debarment U.S. Department of Education: Innovative Approaches to Literacy, Promise Neighborhoods, Full-Service Community Schools, And Congressionally Directed Spending for Elementary and Secondary Education Community Projects (ALN 84.215K) Grant Number and Award Year: S215K240115 (09/06/2024 – 03/21/2025) Statistically Valid Sample: No, and it was not intended to be Prior Year Finding: Not a repeat finding Finding Type: Material Weakness and Noncompliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Covered transactions include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Additionally, in accordance with 2 CFR section 200.303, the Organization shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Effective internal controls should include procedures to ensure when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition and Context: The Organization received federal grant funds from the U.S. Department of Education and a portion of these funds were contracted to a third-party vendor through a sole-source procurement transaction, given the specialized nature of the services to be procured, in which management of the Organization adequately documented its rationale for the sole-source procurement in accordance with federal rules and regulations Because of the dollar value of the funds provided, the Organization entered into a covered transaction with this third-party vendor. The Organization did not verify that the third-party vendor was not suspended or debarred prior to entering into the covered transaction. However, it was determined that the third-party vendor was not suspended or debarred at the time the Organization entered into the covered transaction upon checking the third-party vendor’s status on the SAM Exclusions maintained by the GSA on the SAM.gov website. Cause: The Organization did not have a formal process in place to include a suspension and debarment check prior to entering into covered transactions and therefore a check was not performed. Effect: Funds could have been provided to an entity who was suspended or debarred. Questioned Costs: No questioned costs were noted as the third-party vendor was ultimately determined not to be suspended or debarred at the time the covered transaction was entered into by the Organization. Recommendation: We recommend the Organization review its current policies and procedures to ensure that a suspension and debarment check is performed for all covered transactions prior to entering into the covered transaction. Views of Responsible Officials: Management agrees with the finding as the Organization did not perform a suspension and debarment check on the vendor prior to entering into a covered transaction. The Organization will ensure that a suspension and debarment check is performed for all covered transactions prior to entering into the covered transaction.
Federal Agency: US Department of Education Federal Program Name: Higher Education Institutional Aid Assistance Listing Number: 84.031X Federal Award Identification Number and Year: P031X230004 - 2025, P031X200017 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.430(g)(1)(vi), Charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and nonfederal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not have proper documentation of Time and Effort reporting. Questioned costs: None. Context: During our testing of 40 payroll transactions, we identified four employees’ time and effort reports that were not documented properly to track hours worked on federal grants. Cause: The College did not have proper procedures in place to track time and effort for all personnel on federal grants. Effect: The College could potentially expend incorrect amounts to federal grants. Repeat Finding: No Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.18(g) require institutions to use at least 7% of the sum of its initial and supplemental Federal Work Study allocation for an award year to compensate students employed in community service activities unless a waiver is obtained from the Department of Education. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not meet the community service requirement for its Federal Work Study program. Questioned costs: None. Context: The College did not use at least 7% of its Federal Work Study (FWS) funds for students employed in community service activities. Cause: Due to several staff turnovers in the Financial Aid Office, the community service waiver request was discovered to not have been completed by the submission deadline. Effect: If the College fails to meet any of the FWS community service requirements, then they will be required to return FWS federal funds in an amount equal to the difference between the amount a school should have spent for community service and the amount it actually spent. The College could also be denied future participation in the FWS Program and possibly other FWS programs. Repeat Finding: No Recommendation: We recommend the College review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement.
Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Common Origination and Disbursement (COD) reporting, we noted one instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we noted, one Pell disbursement was not reported within the required 15 days. Cause: The College did not have proper control or procedures in place to verify disbursements were reported to COD within the required 15 days after disbursement. Effect: A lack of timely reporting may prevent the College and other schools from having the most accurate student information which may lead to over awards. Repeat Finding: No Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR 690.62) The Code of Federal Regulations (34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College under-awarded funds for the Pell Grant. Questioned costs: $909 Context: During our testing, we identified one out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 2024-2025 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Student Aid Index and the enrollment status of the student. Cause: The College did not have proper procedures in place to capture student enrollment in summer to be packaged for Pell. Effect: Failure to properly determine and disburse Title IV funds based on eligibility for each type of aid in accordance with federal regulations may result in students receiving incorrect funds. Repeat Finding: Yes, 2024-005 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: None Context: During our testing of 40 students, we identified four students that had Program enrollment effective dates that did not match institutional records and one student that was reported after the 60- day reporting requirement. Cause: The College didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately and submitted timely. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding: Yes, 2024-002 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: US Department of Education Federal Program Name: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268, 84.033, 84.007 Federal Award Identification Number and Year: P063P24032 - 2025, P268K252032 - 2025, P033A243410 - 2025, P007A243410 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: Compliance, Other Matter Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College incorrectly calculated Return to Title IV (R2T4) calculations. Questioned costs: ALN 84.063 $615 ALN 84.268 $2,722 Context: During our testing of 17 R2T4 calculations, we identified that 2 had a mechanically incorrect calculation. Cause: The College did not maintain proper documentation of withdrawal date for R2T4 calculations. Effect: The College could return incorrect amounts based off their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: Yes, 2024-001 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Program: COVID-19 CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: N/A - Direct Award Award No.: B20UW060501, B24UC060502 Award Year: 2021, 2025 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: As a result of our audit procedures, we noted that for three (3) out of three (3) first tier subawards tested there was no documented review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions. Cause: The County’s procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: We tested the entire population of three subawards obligations during the year. Repeat Finding from Prior Years: No Recommendation: We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Written Policies and Procedures Related to Federal Awards - Condition: The Town does not have written policies and procedures to ensure compliance with federal award requirements. Specifically, written procedures are missing for: Allowability of Costs (2 CFR 200 Subpart E), Procurement Standards (2 CFR 200.318), Financial Management (2 CFR 200.302). Criteria: 2 CFR §200.303(a) requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing the award in compliance with federal statutes, regulations, and the terms of the award. Cause of Condition: The organization lacked dedicated administrative staff or training to develop these documents, relying on informal processes.Effect: Without written policies, the Town cannot ensure that costs are consistently treated as allowable, reasonable, and allocable in accordance with federal requirements, potentially leading to questioned costs or disallowance. Recommendation: The Town should develop and formally adopt comprehensive, written, and up-to-date policies and procedures that explicitly address 2 CFR 200 requirements for procurement, allowable costs, and financial reporting. Views of Responsible Officials and Planned Corrective Actions: We will reach out to MTAS to help the Town write and implement a policy for the Federal Award Program.
Federal agency: U.S. Small Business Administration Federal program name: Congressional Grants Inclusive Ventures Small Business Program Assistance listing number: 59.059 Pass-through agency: Anne Arundel County, Maryland Pass-through number: SBAHQ23I0140 Award Period: September 1,2023 through August 31, 2028 Compliance Requirement: Procurement and Suspension and Debarment Type of Findings: Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or specific requirement: Compliance: Nonfederal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.327. 2 CFR section 200.318 states the grant recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in sections 200.317 through 200.327. Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The Corporation did not follow their written procurement procedures which reflect applicable State, local, and tribal laws and regulations which also conform to the applicable federal law and standards identified in the Uniform Guidance. The Corporation could not provide documentation that it ensured contractors were not suspended or debarred before executing contracts with the entities. Questioned Costs Amounts paid to the two contractors for the fiscal year ended June 30, 2025 was $175,000. Context Supporting documentation for the procurement, suspension and debarment status for two of the two contractors selected for testing was not documented. Cause The Corporation has not historically received federal funding so the procurement, suspension and debarment documentation was not deemed necessary. Effect A lack of documented procurement standards for the Corporation could increase the risk of goods and services being procured through a method which is not in accordance with applicable State, local, and tribal law as well as federal regulations including the Uniform Guidance. If the suspension and debarment status is not verified when entering into covered transactions, it is possible that a subaward could be issued to an ineligible entity. Repeat Finding No Recommendation We recommend that management follow their written procurement policies and controls to ensure it maintains documentation of procurement, suspension and debarments checks and that the documentation is available for audit. Views of Responsible Officials Management agrees with finding. See corrective action plan for additional information.
Federal Agency: National Science Foundation, U.S. Department of Transportation, U.S. Department of Energy, U.S. Department of Commerce Federal Program Name: Research & Development Assistance Listing Number: 11.469, 20.000, 47.083 and 81.089 Federal Award Identification Number and Year: 1946093 - 2025, 692Ml5-20-T-00029 - 2025, DEFE0031776 - 2025, NA23NWS4690009 – 2025 Pass-Through Agency: Iowa State University Pass-Through Number: 692M15-20-T-00029 PASS THRU 023063C Award Period: July 1, 2024 to June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR Section 200.305(b)(3)) requires that when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: Oklahoma State University Stillwater (OSU STW) did not make payments to subrecipients within 30 days after receipt of invoices. Questioned costs: None. Context: During our testing we identified 7 subrecipient payments from OSU STW out of 40 payments that did not process payment requests from the subrecipients timely. Cause: OSU STW did not process payment requests from the subrecipient timely. Effect: Subrecipients on federal awards do not receive timely payment for federal contract work. Repeat Finding: No Recommendation: We recommend OSU STW review and update policies and procedures to allow for more timely payment to subrecipients for work the University contracts them to perform. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Research & Development Assistance Listing Number: 93.859 Federal Award Identification Number and Year: 5P20GM109097 - 2025 Award Period: July 1, 2024 to June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: Uniform Grant Guidance, 2 CFR 200.313(d)(2), procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: Oklahoma State University Center for Health Sciences (OSU CHS) did not properly maintain physical inventory of property purchased with federal funds. Questioned costs: None. Context: During our testing, we identified 1 out of 40 equipment items sampled that were purchased with federal funds did not have documentation of a completed physical inventory and could not be physically observed, as the equipment was reported to be misplaced. Cause: OSU CHS did not have effective controls in place to ensure that equipment purchased with federal funds was subject to a timely physical inventory and appropriately tracked, including procedures to ensure equipment could be located for observation. Effect: As a result, OSU CHS was unable to demonstrate the existence and proper safeguarding of equipment purchased with federal funds, increasing the risk that equipment may not be properly monitored, safeguarded, or used in accordance with federal requirements. Repeat Finding: No Recommendation: We recommend that OSU CHS implement and consistently perform procedures to ensure that all equipment purchased with federal funds is subject to a physical inventory at least once every two years, with results properly documented and reconciled to equipment records. We further recommend that OSU CHS strengthen controls over tracking equipment locations to ensure that federally funded equipment can be readily identified and physically located when required. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: U.S. Department of Transportation and U.S. Treasury Federal Program Name: Research & Development and Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 20.000 and 21.027 Federal Award Identification Number and Year: 692Ml5-20-T-00029-2025 and SLFRP4646-2025 Pass-Through Agency: Iowa State University Pass-Through Number: 692M15-20-T-00029 PASS THRU 023063C Award Period: July 1, 2024 to June 30, 2025 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.318(i), the recipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: Oklahoma State University Stillwater (OSU STW) and Oklahoma State University Center for Health Sciences (OSU CHS) did not go through procurement procedures prior to entering into a contract with the vendor. Questioned costs: None. Context: During our testing of the Research & Development Cluster, we identified 1 transaction from OSU STW out of 40 transactions that did not go through the proper procurement procedures. During our testing of the Coronavirus State and Local Fiscal Recovery Funds Program, we identified 1 transaction from OSU CHS out of 6 transactions that did not go through the proper procurement procedures. Cause: OSU STW and OSU CHS did not have an effective control in place to ensure that the purchases went through the procurement procedures. Effect: OSU STW and OSU CHS were not in compliance with the regulation to go through the procurement procedures prior to entering a contract. Repeat Finding: No Recommendation: We recommend that OSU STW and OSU CHS review policies and procedures for procurement to ensure that every applicable transaction is going through the proper procurement procedures. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Federal Government Federal Program Name: Research & Development and Economic Development Cluster Assistance Listing Number: Multiple Federal Award Identification Number and Year: Multiple Pass-Through Agency: Multiple Pass-Through Number: Multiple Award Period: July 1, 2024 to June 30, 2025 Type of Finding: - Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.403: Factors affecting allowability of costs; 2 CFR 200.413: Direct costs; 2 CFR 200.414: Indirect costs, OSU Policy 4-0135. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: Oklahoma State University’s (OSU) policies were not consistently followed related to Professional Engineering Service (PES) rates charged by Oklahoma Aerospace Institute for Research and Education (OAIRE), a department within OSU. Questioned costs: Up to $2,853,832 of which approximately $935,974 occurred in FY2025. Of this $2,853,832, $1,333,596 was related to cost-reimbursable agreements, $1,159,037 to time and materials agreements, $221,613 to fixed price agreements, and $139,586 to undefined agreements. Context: OAIRE developed (PES) rates, which are the types of hourly rates typically used by contractors in time-and-materials type federal agreements. In some instances, OAIRE charged these fixed hourly rates for PES work in cost-reimbursable federal agreements, which resulted in OAIRE charging more than its actual costs incurred for such PES work. In addition, the PES rates were not consistent with OSU’s facilities and administration (F&A) rate agreement in that they included costs typically charged as indirect in its direct cost labor rates without justification and defining special circumstances when bidding contract rates. Certain labor rates were also calculated based on an understated number of available hours, which resulted in an overstated PES rate. Cause: Professional services rates were developed without documented review or attestation by subject matter experts in research administration or sponsored programs. Effect: Failure to adhere to costing principles may result in questioned costs and overbilling to sponsors. Repeat Finding: No Recommendation: We recommend that OSU should notify the applicable sponsors and federal agencies regarding the calculated questioned costs and make any necessary repayments or adjustments. Further, OSU should develop and document a process to ensure the PES rates are developed and billed in accordance with OSU Policy, applicable federal regulations, and the requirements of OSU’s Federal Agreements. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Criteria or specific requirement: Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Schools was unable to provide evidence of timesheet approval for 2 of 40 payroll samples tested. Context: Forty timesheets were selected for testing and the following exceptions were noted: • For 2 of 40 timesheets selected for testing, Schools was unable to provide documentation evidencing the timesheets were properly approved. Questioned costs: Not applicable. Cause: Schools’ procedures and controls were not sufficient to ensure that time and effort reporting was accurately performed and documented, nor that employee time was properly allocated and approved. Effect: There is an increased risk of charging unallowed payroll costs to the program. Recommendation: Schools should reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. Schools should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit.
Inadequate Internal Controls Over Compliance Related to Identification and Reporting of Assistance Listing Numbers (ALNs) in Schedule of Expenditures of Federal Awards Federal Program State Energy Program ALN 81.141 Energy Efficiency and Conservation Block Grant ALN 81.128 Name of Federal Agency U.S. Department of Energy Compliance Requirement Reporting Type of Finding Internal control over compliance/non-compliance Category Significant deficiency on internal controls over compliance and Other Matter. Criteria Title 2 CFR §200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, 2 CFR §200.510(b) requires the Schedule of Expenditures of Federal Awards (SEFA) to include the correct Assistance Listing Number (ALN) for each Federal program. Proper identification of ALNs is essential, as different ALNs may be subject to different compliance requirements under the Uniform Guidance and program-specific terms and conditions. Condition During our review of the Schedule of Expenditures of Federal Awards (SEFA), we noted that Federal funds received under the U.S. Department of Energy were not consistently identified and documented under the correct Assistance Listing Numbers. Specifically, expenditures related to ALNs 81.141 and 81.128 were not clearly distinguished or were incorrectly classified. The entity did not have sufficient internal controls in place to ensure that Federal awards were properly identified by ALN at the time funds were received and subsequently recorded and reported on the SEFA. Cause The condition resulted from inadequate internal controls over compliance related to: •The identification of Federal awards upon receipt of funds; •The documentation and tracking of ALNs throughout the grant lifecycle; and •The preparation and review of the SEFA to ensure accurate classification by ALN. Management relied on informal processes and did not implement a formal review or reconciliation procedure to verify that Federal expenditures were recorded under the correct Assistance Listing Numbers. Effect Failure to correctly identify and document the applicable ALN may result in noncompliance with Federal requirements, as different ALNs can carry different compliance requirements, including but not limited to: •Allowable costs and activities. •Period of performance •Reporting requirements •Special tests and provisions; and •Subrecipient monitoring requirements. Misclassification of expenditures by ALN increases the risk that the entity may apply incorrect compliance requirements to a Federal award, potentially leading to unrecognized instances of noncompliance and inaccurate reporting on the SEFA. Additionally, incorrect ALN reporting may affect the determination of major programs and the scope of Single Audit testing. Context Two (2) out of a total of fifteen (15) Federal programs were not consistently identified and documented under the correct Assistance Listing Numbers. Questioned Costs None. Identification as a Repeated Finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that management strengthen internal controls over compliance by: 1. Implementing formal procedures to identify and document the correct ALN at the time Federal funds are received. 2. Maintaining detailed grant tracking records that clearly link expenditures to the appropriate ALN. 3. Establishing a supervisory review process over the preparation of the SEFA to verify the accuracy and completeness of ALN classifications prior to submission. Views of responsible officials and planned corrective actions Management of the Department agrees with this finding. Refer to the corrective action plan on pages 114-119.
Criteria: Health centers receiving federal funding under the Health Center Program (93.224) and Ryan White Part C (93.918) are required to maintain and consistently apply a sliding fee discount program in accordance with federal regulations and program guidance. Specifically, 42 CFR §51c.303(f) requires health centers to have a schedule of fees and discounts based on patients’ ability to pay and to apply the schedule consistently. The HRSA Health Center Program Compliance Manual, Chapter 9, mandates documented eligibility determinations, defined timeframes for eligibility reassessment, proper application of the sliding fee scale, and retention of documentation. Similarly, the Ryan White HIV/AIDS Program Part C Manual requires eligibility determinations and fee assessments consistent with approved policies and program requirements. Additionally, federal standards under 2 CFR §200.303 require non-federal entities to establish and maintain effective internal controls over federal awards, 2 CFR §200.302(b) requires financial management systems to adequately identify and document eligibility determinations, and 2 CFR §200.328 requires accurate programmatic reporting and monitoring. Condition: During testing of the sliding fee discount program for the fiscal year ended June 30, 2025, we identified multiple instances of noncompliance with established policies and federal program requirements. Specifically, patient financial information was updated over prior evaluations, which eliminated historical tracking and resulted in files not being properly closed in accordance with the health center’s policies. Effect: As a result of these deficiencies, NeoMed Center Inc. is at increased risk of improper fee discounts being applied to patients who may not meet eligibility requirements, noncompliance with federal and program-specific requirements, inaccurate financial reporting related to patient service revenue, lack of proper and accurate collection of services provided and potential loss of federal funds awards. Cause: The noncompliance is caused by inadequate implementation of internal controls policies and procedures designed over the sliding fee program. Also, it caused by lack of appropriate staff training and missing standardized monitoring policies and procedures, as well as inadequate supervisory review of eligibility determinations and documentation. Recommendations: We recommend that the Institution implement the following corrective actions: 1. Review current policies and procedures to improve and establish robust internal controls to ensure that patient financial information is updated without overwriting prior evaluations, preserving historical tracking and maintaining properly closed files. 2. Provide training to staff responsible for eligibility determinations and fee assessments to ensure consistent application of the sliding fee scale and compliance with federal program requirements. 3. Implement standardized monitoring and supervisory review procedures to verify that eligibility determinations, fee assessments, and documentation are accurate, complete, and retained in accordance with program requirements. 4. Implement and perform, on a recurrent basis, audit and/or review of patient files to ensure ongoing compliance, timely reassessment, and proper application of the sliding fee discount program. 5. Maintain clear records and documentation to support all eligibility determinations and fee discounts, ensuring the entity can demonstrate compliance during internal reviews or external audit
Federal Agency: 84 – Department of Education Federal Program Title: Higher Education Institutional Aid Assistance Listing Number: 84.031 Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: In accordance with 2 CFR §200.328, non‑Federal entities must submit required performance reports in accordance with the terms and conditions of the Federal award and include all information required by the Federal awarding agency. Performance reports must be submitted in the form, manner, and frequency prescribed in the award agreement. Additionally, 2 CFR §200.303 requires non‑Federal entities to establish and maintain effective internal control over Federal awards, including controls to ensure required reports are reviewed, approved, documented, and submitted in accordance with award requirements. Condition/Context: During our testing of Reporting, we selected a sample of 5 Higher Education Institutional Aid performance reports. This major program includes 5 award agreements, of which 2 agreements have quarterly reporting requirements, 2 agreements have semi‑annual reporting requirements, and 4 agreements have annual reporting requirements. The following exceptions were noted: • For 2 of the 5 reports tested, the reports were prepared; however, evidence supporting submission was not provided, and documentation could not be provided to demonstrate that the reports were reviewed and approved prior to submission. As a result, evidence of management review and report submission could not be verified. Questioned Costs: None. Effect: Failure to retain documentation supporting report submission and management review limits the UEC’s ability to demonstrate compliance with Federal reporting requirements and increases the risk that required reports are not reviewed or submitted in accordance with award terms. Cause: The UEC’s internal controls were not designed or implemented to consistently ensure that required performance reports are reviewed, approved, and submitted in accordance with Federal award requirements, and that documentation is retained to support evidence of review and submission. Repeat Finding: No. Recommendation: We recommend the UEC strengthen its reporting procedures to ensure required performance reports are reviewed and approved prior to submission and that documentation is retained to support evidence of management review and report submission in accordance with Federal award requirements. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: 11 – Department of Commerce, 12 – Department of Defense, 15 – Department of the Interior, 16 – Department of Justice, 43 – National Aeronautics and Space Administration, 47 – National Science Foundation, 81 – Department of Energy, 84 – Department of Education, 93 – Department of Health and Human Services Federal Program Title: R&D Cluster and TRIO Cluster Assistance Listing Number: R&D and 84.TRIO Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: In accordance with 2 CFR §200.403(a), costs charged to Federal awards must be necessary, reasonable, and allocable to the Federal award. Additionally, 2 CFR §200.309 requires costs to be incurred during the approved period of performance of the Federal award. Further, 2 CFR §200.302(a) requires non‑Federal entities to maintain financial management systems that provide for accurate, current, and complete disclosure of the financial results of each Federal award, and 2 CFR §200.303 requires non‑Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: The population sizes below are presented only for programs in which exceptions were identified for the applicable compliance test. Cash Disbursement Testing – TRIO Cluster (Control Finding Only): • For 2 of the 40 TRIO samples tested, the related expenses were allowable and incurred within the awards’ approved periods of performance; however, the expenses were improperly recorded in fiscal year 2025. Specifically, 1 expense related to fiscal year 2024, and 1 expense represented a prepayment for a fiscal year 2026 cost. The resulting misstatement to the Schedule of Expenditures of Federal Awards (SEFA) totaled $5,260, which is less than program materiality. Payroll Testing – R&D Cluster (Control Finding Only): • For 10 of the 40 R&D samples tested, timesheets were not submitted timely, resulting in variances between the payroll register and the recalculated gross wages for the applicable pay periods. No unallowable payroll costs were identified; however, controls over timely payroll documentation and reconciliation did not operate effectively. • For 1 of the 40 R&D samples tested, the timesheet was not signed by the supervisor, indicating that payroll review controls were not consistently applied. Questioned Costs: None. Effect: Although the costs tested were allowable and incurred within the approved periods of performance, improper period recognition and untimely or incomplete payroll documentation increase the risk that Federal expenditures are not recorded in the proper fiscal period and that Federal financial reporting is not accurate. Cause: The UEC’s internal controls were not designed or implemented to consistently ensure that expenditures are recorded in the proper fiscal period and that payroll documentation is submitted, reviewed, and approved timely. Repeat Finding: No. Recommendation: We recommend the UEC strengthen its controls over expenditure recognition to ensure costs are recorded in the appropriate fiscal period and enhance payroll review procedures to ensure timesheets are submitted and reviewed timely to support accurate payroll reporting. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: 11 – Department of Commerce, 12 – Department of Defense, 15 – Department of the Interior, 16 – Department of Justice, 43 – National Aeronautics and Space Administration, 47 – National Science Foundation, 81 – Department of Energy, 84 – Department of Education, 93 – Department of Health and Human Services Federal Program Title: R&D Cluster, Child Care Access Means Parents in School, TRIO Cluster, and Higher Education Institutional Aid Assistance Listing Number: R&D, 84.335, 84.TRIO, and 84.031 Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: In accordance with 2 CFR §200.305(b), when using the reimbursement method, Federal drawdowns must be limited to allowable costs that have been incurred and supported. Additionally, 2 CFR §200.302(a) requires non Federal entities to maintain financial management systems that provide for accurate, current, and complete disclosure of the financial results of each Federal award. Condition/Context: During our testing of Cash Management, we selected a sample of 85 reimbursement requests, consisting of 40 R&D Cluster samples, 12 Child Care Access Means Parents in School samples, 23 TRIO Cluster samples, and 10 Higher Education Institutional Aid. The following exceptions were noted: R&D Cluster, TRIO Cluster, and Higher Education Institutional Aid: For 4 of the 40 R&D samples tested, 9 of the 23 TRIO samples tested, and 1 of the 10 Higher Education Institutional Aid samples tested, instances of noncompliance were identified. • For 4 of the 4 R&D samples, 8 of the 9 TRIO samples, and 1 of the 1 Higher Education Institutional Aid samples with instances of noncompliance noted, a portion of the reimbursement drawn down during fiscal year 2025 related to expenses incurred outside to the current fiscal year. Additionally, 1 of the 4 R&D samples included expenses incurred as far back as October 2020. • For 1 of the 9 TRIO samples with instances of noncompliance noted, supporting documentation (such as invoice support, indirect cost recalculations, or payroll registers) was not provided for a portion of the expenses included in the reimbursement requests. As a result, we were unable to determine the period to which the funds drawn down related. Child Care Access Means Parents in School (Control Finding Only): • For 1 of the 12 samples tested, the UEC was ultimately in compliance with cash management requirements; however, internal controls did not operate effectively. Specifically, there was an approximate six‑month delay between the incurrence of program costs and the submission of the reimbursement request. Questioned Costs: $68,759 Effect: Reimbursement requests that include costs incurred outside the applicable fiscal period or costs that are not supported increase the risk that Federal expenditures are not recorded in the proper accounting period and that Federal financial reporting is not accurate. Additionally, delays in submitting reimbursement requests increase the risk that expenditures are not timely reported in accordance with Federal requirements. Cause: The UEC’s internal controls were not designed or implemented to consistently ensure that costs included in reimbursement requests are recorded in the appropriate fiscal period, supported by adequate documentation, and submitted timely in accordance with Federal cash management and financial reporting requirements. Repeat Finding: No. Recommendation: We recommend the UEC strengthen its cash management and financial reporting procedures to ensure reimbursement requests include only costs incurred in the appropriate fiscal period, are supported by adequate documentation, and are submitted timely. The UEC should also enhance review controls to verify proper period recognition of costs prior to submission of reimbursement requests. Views of Responsible Officials: Management agrees with the finding and has developed a plan to correct the finding. Further, 2 CFR §200.303 requires non Federal entities to establish and maintain effective internal control over Federal awards to ensure transactions are recorded in the proper accounting period and in accordance with applicable Federal requirements.
2025-003 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P248567 – 2025, P268K258567 – 2025, P268K256514 - 2025 Award Periods: July 1, 2024 through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. Condition: The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned Costs: None Context: During our testing of 17 students, we identified 1 student whose enrollment status change was not reported, 2 students with incorrect status changes reported for program-level reporting, 2 students with an incorrect effective date reported, and 9 students whose status changes were not reported in a timely manner. We also identified that for all 17 of the selected students, enrollment status was not certified every 60 days. Additionally. the University did not document any evidence of review over enrollment reporting. Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat findings: 2024-004 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials: There is no disagreement with the audit finding.
2025-004 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P248567 – 2025, P268K258567 – 2025, P268K256514 - 2025 Award Periods: July 1, 2024 through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: 34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the institution or disbursed directly to the student for the payment period. The institution must return those funds no later than 30 days after the date that the institution becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations. Questioned Costs: None Context: During our testing of 5 R2T4 calculations, we identified 2 students with no R2T4 calculation performed. These students attended more than 60% of the term and did not require returned funds. Additionally, we identified 3 R2T4 calculations that did not have documentation of review. Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned. Repeat findings: 2024-005 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials: There is no disagreement with the audit finding.
2025-005 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P248567 – 2025, P268K258567 – 2025, P268K256514 - 2025 Award Periods: July 1, 2024 through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program. (16 CFR 314.4(a)). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution's written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d)). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written Information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Additionally, we were unable to observe evidence that the WISP was formally reviewed and approved. Questioned Costs: None Context: The WISP was missing the element discussing the secure disposal of customer information. Additionally, there was not an observable formal review or authorization.. Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: There is a risk the University’s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Repeat findings: 2024-006 Recommendation: We recommend that the University review the GLBA requirements and ensure their WISP includes all required elements. Views of Responsible Officials: There is no disagreement with the audit finding.
2025-006 Eligibility Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P248567 – 2025, P268K258567 – 2025, P268K256514 - 2025 Award Periods: July 1, 2024 through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 34 CFR 690.62 states the Pell grant for an academic year is based upon the payment and disbursement schedule published by the Secretary for each award year. 34 CFR 690.80(b)(1)) states if the student’s enrollment status changes from one academic term to another within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance. Condition: The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, the University incorrectly disbursed Pell funds for 10 students. Questioned Costs: $12,949 Context: During our eligibility testing of 60 students, we identified that the University did not document evidence of review for controls over award packaging performed by their third party servicer. Additionally, out of 43 students receiving Pell, 10 were under awarded. Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements. Repeat findings: 2024-007 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Views of Responsible Officials: There is no disagreement with the audit finding.
2025-007 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P248567 – 2025, P268K258567 – 2025, P268K256514 - 2025 Award Periods: July 1, 2024 through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University was unable to provide documentation of review for controls surrounding credit balance disbursements. Questioned Costs: None Context: The University did not have documented review of controls to ensure credit balance funds that were not successfully disbursed to the student were returned to the Department of Education after 240 days. Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements. Repeat findings: No Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance over stale checks that need to be returned to the Department of Education after 240 days. Views of Responsible Officials: There is no disagreement with the audit finding.
2025-008 Cash Management Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P248567 – 2025, P268K258567 – 2025, P268K256514 - 2025 Award Periods: July 1, 2024 through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not have documentation that Direct Loan Reconciliations or Pell Reconciliations prepared by third-party servicer were reviewed. Additionally, we were unable to observe evidence that the University reviewed cash drawdowns prepared by the third party processor. Questioned Costs: None Context: During our testing, we reviewed 4 months of direct loan reconciliations that the University's third party servicer prepares; however, Urshan was unable to provide documentation of review for these reconciliations. Additionally, during our testing of 5 draws, we identified that all 5 draws did not have documented evidence of review. Cause: The University did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements. Repeat findings: 2024-009 Recommendation: We recommend that the University should implement formal review procedures to document that the Cash Management reconciliation and drawdown reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Views of Responsible Officials: There is no disagreement with the audit finding.
2025-009 Reporting Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P248567 – 2025, P268K258567 – 2025, P268K256514 - 2025 Award Periods: July 1, 2024 through June 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University used a third-party servicer to perform key controls, but did not have documented review of the work performed by their third-party servicer. Additionally, 1 disbursement was incorrectly reported to COD. Questioned Costs: None Context: During our testing of 60 COD disbursements, we noted 1 disbursement that was incorrectly reported. We also noted that the University did not have documentation of review for COD disbursements. Cause: This discrepancy resulted from the student being initially packaged by Campus Ivy using the 01 ISIR transaction, which reflected an SAI of -1500. Subsequent ISIR transactions that significantly impacted eligibility were not identified prior to packaging. These discrepancies were later identified during the University’s internal HCM2 reconciliation process in collaboration with FA Solutions, resulting in a mismatch between awarded aid and COD records. Effect: Without proper controls the University risks being out of compliance with federal laws and regulations, as well as program compliance requirements. Repeat findings: No Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
Finding 2025-001: Disbursement Documentation - Significant Deficiency. Program name: Substance Abuse and Mental Health Services Projects of Regional and National Significance. Assistance Listing: 93.243. Federal award number: 45CBB04530. Federal award year: 7/1/2024 - 6/30/2025. Federal awarding agency: U.S. Department of Health and Human Services. Criteria - The Organization is required to follow the Uniform Guidance requirements 2 CFR Part 200.303, which requires the Organization to establish, document and maintain effective internal controls over federal awards. The Organization verbally approved expenses but lacked the documentation to support the approval. Condition - A sample of expenses were selected to test internal control over compliance and compliance with allowable costs/cost principles. Out of the items selected for testing, we noted insufficient documentation to support approval on 2 out of 40 expenses selected for testing. The exceptions noted occurred prior to the full implementation of the corrective action plan on January 1, 2025. Cause - The Organization's fiscal policies and procedures did not require written approval, leading to reliance on verbal approvals which were not documented. Effect - The failure to document approvals for expenses could lead to unallowable costs to be disbursed on grant awards. Questioned costs - None identified. Identification of Repeat Findings - This is a repeat finding from the prior year (Finding 2024-002). As a result of the 2024 audit report, issued in March 2025, the Organization began the process of developing updated policies for compliance. In 2025, the Organization formally adopted new policies and procedures that align with the internal control standards per 2 CFR Part 200. Recommendation - We recommend that management update their fiscal policies and procedures to align with what is required by the Uniform Guidance. Management response - See corrective action plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Award Year: 2022 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1.For three (3) out of three (3) contracts selected for testing, the County did not include theapplicable provisions described in 2 CFR 200 Appendix II. 2.For one (1) out of three (3) contracts selected for testing, the County could not provide acopy of the approved contract. 3.For three (3) out of three (3) contracts tested, we noted that there was no evidence theCounty verified that the contracted entities were not suspended or debarred or otherwiseexcluded from participating in federal programs prior to entering into the contract. Cause: The County did not follow their policy documenting the approval of the procurement. The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County’s policy does not include the requirement to include each of the applicable provisions identified in 2 CFR 200 Appendix II in its contracts or purchase orders. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of ten (10) procurement contracts were tested. This represented a total of $184,840 in contracted services under the grant. Repeat Finding from Prior Years: Yes. Finding 2024-002 Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grantor: U.S. Department of Agriculture Passed-through: California Department of Public Health Award No.: 22-10307 Award Year: 2022 Compliance Requirement: Activities Allowable or Unallowed and Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awardsfor salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition: For one (1) of sixty-five (65) expenditures tested, we noted one timecard where the employee’s timecard was not approved by a supervisor. Cause: The County’s procedures did not consistently ensure that the review of timecards was documented. Effect: Lack of review for personnel hours could lead to unallowable activities and costs to be charged to the Federal program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of sixty-five (65) out of one thousand ninety-two (1,092) expenditures were tested, totaling $164,654 out of $4,553,367 of the federal program expenditures. Repeat Finding from Prior Years: Yes. Finding 2024-003. Recommendation: We recommend that the County modify and/or strengthen its current policies and procedures to ensure that all timecards consistently document evidence of supervisor approval. The procedures should also address the compensating controls for circumstances where obtaining the supervisor’s approval is not possible. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Direct Award Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, B-24-UC-06-0507 Award Year: 2024 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: For two (2) out of four (4) CDBG Cash on Hand PR29 and CDBG-CV Cash on Hand PR29 reports, the County did not retain evidence to document the individual who reviewed and approved the required reports. For three (3) out of three (3) Federal Funding Accountability and Transparency Act (FFATA) report submissions, we noted the County did not retain evidence to document the individual who reviewed and approved the required reports. Cause: The County’s procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A non-statistical sample of two (2) out of four (4) CDBG Cash on Hand reports were selected for testing. We tested the entire population of three (3) subawards obligations during the year. Repeat Finding from Prior Years: Yes. Finding 2024-007 and 2024-008. Recommendation: We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Direct Award Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, B-24-UC-06-0507 Award Year: 2024 Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) 40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326. 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: For one (1) of three (3) construction contracts selected for testing, we noted that the County did not obtain and review the contractors’ certified payroll submissions. Cause: The County’s procedures did not include verifying all weekly certified payrolls were obtained. Effect: Ineffective controls over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of three (25) certified payrolls were selected for testing. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed and documented by the County. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii Assistance Listing No.: 14.228 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Pass-Through California Department of Housing and Community Development Award No.: 17-MITPPS-21029, 18-DRWD-23003, 21-CDBG-HK-0010 Award Year: 2022, 2024 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: For two (2) out of five (5) CDBG-CV2, four (4) out of six (6) CDBG-MIT, and four (4) out of eight (8) VC Heal Activity reports, the County did not retain evidence to document the individual who reviewed and approved the required reports. Cause: The County’s procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A non-statistical sample of nineteen (19) out of thirty-one (31) reports were selected for testing. Repeat Finding from Prior Years: No. Recommendation: We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 5 H80CS00247-22-00 Award Year: 2024 Compliance Requirement: Special Tests and Provisions - Sliding Fee Discounts Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted three (3) out of sixty (60) where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). We also noted there was no review of the sliding fee discount by the County for two (2) out of sixty (60) sliding fee samples. Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of sixty (60) out of three thousand seven hundred forty-eight (3,748) participants were tested. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules, ensure that policies and procedures are strictly adhered to by County personnel and the County’s review is performed and documented. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listing No.: 93.323 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award No.: COVID-19ELC114 Award Year: 2021 Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502. In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition: During our audit procedures performed over the SEFA and expenditures reported for the ELC program, we noted the County initially reported expenditures totaling $408,471 that should have been reported on the FY 2024 SEFA, as the County incurred the expenditures prior to June 30, 2024. The June 30, 2025 SEFA was corrected for this reporting error. Cause: The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately. Effect: Prior to the correction, expenditures for the ELC program were overstated by $408,471. We noted the FY 2024 expenditures incorrectly reported on the FY 2025 SEFA did not have a direct and material effect on the FY 2024 SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Years: No. Recommendation: We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listing No.: 93.323 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award No.: COVID-19ELC114 Award Year: 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: For one (1) out of three (3) Quarterly Progress reports, the County did not retain evidence to document the individual who reviewed and approved the required reports. Cause: The County’s procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Quarterly Progress reports were selected for testing. The condition above was identified during our procedures over reporting testing. Repeat Finding from Prior Years: No. Recommendation: We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listing No.: 93.323 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award No.: COVID-19ELC114 Award Year: 2021 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Material Weakness and Instance of Noncompliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition: For three (3) out of three (3) contracts tested, we noted that there was no evidence the County verified that the contracted entities were not suspended or debarred or otherwise excluded from participating in federal programs prior to entering into the contract. Cause: The County did not have adequate internal controls in place to ensure vendor eligibility was verified and documented prior to contract execution, resulting in a lack of evidence supporting compliance with suspension and debarment requirements. Effect: As a result of this condition, the County was not able to demonstrate compliance with Uniform Guidance procurement requirements, increasing the risk that federal funds could be awarded to ineligible vendors. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of twelve (12) contracts were tested. Repeat Finding from Prior Years: No. Recommendation: We recommend the County enhance internal controls over procurement to ensure verification and documentation of vendor eligibility related to suspension and debarment are performed prior to contract execution, in accordance with Uniform Guidance requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
The District did not timely report required student information to the federal agency, risking students not being asked to repay financial assistance Cluster name: Student Financial Assistance Cluster Assistance Listings number(s) and name(s): 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program Award year(s): July 1, 2024 through June 30, 2025 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: None Condition Contrary to federal regulations and District policies and procedures, the District’s Financial Aid and Veteran Services Department (Department) did not timely report enrollment status changes to the National Student Loan Data System (NSLDS) as required. Specifically, the Department reported student enrollment status changes between 4 to 237 days later than the required 60 days for 19 of 35 students we tested participating in the Federal Pell Grant (Pell) program. Effect The District’s students may not be asked to repay student financial assistance grants or loans if or when required if the NSLDS does not accurately reflect students’ enrollment status. Also, the District is at risk that student enrollment status changes may be reported late for its over 1,000 students receiving federal Pell grants. Cause The District’s management reported that they transitioned to a new student information system in February 2025 and had issues syncing registrar information to the students receiving financial assistance to submit timely student enrollment status changes to the NSLDS. Further, the District did not update its policies to describe process changes due to the system’s implementation and did not assign a designated individual to verify that data was properly processed and reported to the NSLDS. Criteria Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students’ enrollment statuses and any enrollment status changes for the Pell program within 60 days of the students’ change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] §690.83[b][2] and District’s Enrollment Reporting Process). Further, federal guidelines require establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the District Report accurate student enrollment statuses and changes to the NSLDS within 60 days of the students’ change for all students receiving Pell. Update its enrollment reporting policies and procedures and train employees on new processes due to the implementation of the new student information system, including properly syncing registrar information to the students receiving financial assistance to submit timely student enrollment status changes to the NSLDS. Designate an individual to verify that data was properly processed and reported to the NSLDS. Views of responsible officials District management concurs with this finding. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials regarding these recommendations. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.