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GALLAUDET UNIVERSITYHigher Education

EIN: 530199507

UEI: TQCJUED1WEF9

Audited by: Grant Thornton LLP

Cognizant agency: 84 [Department of Education]

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Data as of August 28, 2026

GALLAUDET UNIVERSITY10 audit years18 findings4 repeat
10
Audit Years
18
Total Findings
4
Repeat Findings
$174.7M
Federal Awards Expended (FY 2025)

FY 2025-09-30

LOW-RISK AUDITEE$174,674,851 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 31, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 31, 2027 (155 days from today).

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2025-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The University reported the recruitment and employment information required under the Education of the Deaf Act in its Annual Report; however, it did not retain sufficient supporting documentation to substantiate the reported disclosures. Specifically, the University was unable to provide the underlying source data supporting: (1) the number of recruitment activities by type and location for all educational levels and (2) employment openings and vacancies, grade level or type of job, and the number of individuals who applied and were hired. Effect or Potential Effect: As a result, the University could not demonstrate the completeness and accuracy of the reported information included in the Annual Report, and the audit team was unable to verify the reported metrics/data. The lack of appropriate processes to accumulate and maintain the relevant supporting documentation used to prepare the Annual Report increases the risk that inaccurate or incomplete information could be reported without detection and may result in noncompliance with the reporting requirements of the Education of the Deaf Act. Context: During testing of the University's Annual Report, required under the Education of the Deaf Act, the audit team tested all tables and disclosures subject to the reporting requirements. The exceptions identified affected two required reporting elements: (1) recruitment activities by type and location for all educational levels and, (2) employment openings/vacancies, grade level or job type, and applicant and hiring statistics. No supporting documentation was available to support the data presented for either disclosure. Cause: The University did not maintain the underlying source reports, supporting schedules, or other documentation used to compile certain information included in the Annual Report. As a result, the data used to prepare the disclosures could not be recreated or validated subsequent to the report's submission. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its procedures for accumulating, preparing and retaining support for Annual Report disclosures required under the Education of the Deaf Act. Specifically, management should retain the source reports, supporting schedules, calculations, and other relevant documentation used to compile reported information and implement a review process to verify that supporting documentation is maintained and readily available to substantiate all reported metrics/data. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Reporting, is presented in the Corrective Action Plan section of this report.

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FINDING 2025-001 Internal Control over Compliance and Compliance with Reporting (Significant Deficiency and Noncompliance) Federal Agency: U.S. Department of Education Federal Program: Federal Appropriations Assistance Listing Number: 84.910A Criteria: Pursuant to the Education of the Deaf Act, 20 U.S.C. § 4354(2), Gallaudet University is required to prepare and submit an Annual Report of Achievements (“Annual Report”) containing specified information regarding educational, recruitment, and employment activities. The required information includes: (1) the number of recruitment activities by type and location for all educational levels under 20 U.S.C. § 4354(2)(E), and (2) employment openings/vacancies by grade level or job type and the number of individuals who applied and were hired under 20 U.S.C. § 4354(2)(F). The University is responsible for maintaining sufficient records to support the completeness and accuracy of information reported in the Annual Report. Condition: The University reported the recruitment and employment information required under the Education of the Deaf Act in its Annual Report; however, it did not retain sufficient supporting documentation to substantiate the reported disclosures. Specifically, the University was unable to provide the underlying source data supporting: (1) the number of recruitment activities by type and location for all educational levels and (2) employment openings and vacancies, grade level or type of job, and the number of individuals who applied and were hired. Effect or Potential Effect: As a result, the University could not demonstrate the completeness and accuracy of the reported information included in the Annual Report, and the audit team was unable to verify the reported metrics/data. The lack of appropriate processes to accumulate and maintain the relevant supporting documentation used to prepare the Annual Report increases the risk that inaccurate or incomplete information could be reported without detection and may result in noncompliance with the reporting requirements of the Education of the Deaf Act. Context: During testing of the University's Annual Report, required under the Education of the Deaf Act, the audit team tested all tables and disclosures subject to the reporting requirements. The exceptions identified affected two required reporting elements: (1) recruitment activities by type and location for all educational levels and, (2) employment openings/vacancies, grade level or job type, and applicant and hiring statistics. No supporting documentation was available to support the data presented for either disclosure. Cause: The University did not maintain the underlying source reports, supporting schedules, or other documentation used to compile certain information included in the Annual Report. As a result, the data used to prepare the disclosures could not be recreated or validated subsequent to the report's submission. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its procedures for accumulating, preparing and retaining support for Annual Report disclosures required under the Education of the Deaf Act. Specifically, management should retain the source reports, supporting schedules, calculations, and other relevant documentation used to compile reported information and implement a review process to verify that supporting documentation is maintained and readily available to substantiate all reported metrics/data. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Reporting, is presented in the Corrective Action Plan section of this report.

Corrective Action Plan

FINDING 2025-001 Internal Control over Compliance and Compliance with Reporting (Significant Deficiency and Noncompliance) Responsive to finding: We agree with the finding. Corrective Action Plan: Gallaudet University will strengthen its procedures for collecting, maintaining, retaining, and reviewing supporting documentation for performance metrics reported to the U.S. Department of Education. Going forward, every reported metric will be supported by source documentation that is retained, readily accessible, and available for review upon request. The University will implement the following corrective actions: • Develop and document procedures identifying the source documentation required to support each reported performance metric. • Establish a centralized electronic repository for performance-metric documentation. Staff submitting a metric write-up will be required to submit the associated raw data file with it, so the source documentation is captured at the point of submission rather than reconstructed later. • Implement a review process requiring verification of supporting documentation prior to submission of reports. • Provide training to personnel responsible for collecting, compiling, and reporting performance metrics regarding documentation and record-retention requirements. • Periodically review supporting documentation to ensure compliance with Department of Education reporting requirements and federal record-retention standards. Together, these actions will address the documentation gap identified in the finding and establish a sustainable process to support future reporting cycles. Individual(s) Responsible for Corrective Action Plan: Caroline Kobek Pezzarossi, Dean of Curriculum, Outreach, Resources and Effectiveness Khadijat Rashid, Provost Estimated Completion Date: September 30, 2026

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2025-002
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

During the audit, we tested five (5) vendors classified as micro-purchases. For each selected vendor, the University was unable to provide documentation evidencing that a cost or price reasonableness review was performed prior to vendor selection or contract execution. Specifically, the procurement files did not include pricing comparisons, competing quotes, market research, purchase history, documented experience, or other support demonstrating how the contract price was determined to be reasonable. Effect or Potential Effect: Without documented evidence of price reasonableness, the University cannot demonstrate that micro-purchase awards were made in accordance with Uniform Guidance procurement requirements. This increases the risk that federally-funded procurement transactions may not be supported by adequate documentation to demonstrate that prices paid were reasonable, and that procurement decisions may not be consistently supported, reviewed, and retained in accordance with federal requirements. Context: This is a condition based on testing the University’s compliance with specific requirements. The prevalence of this finding is detailed in the condition above. The samples were selected using a non-statistical method. Cause: The University did not consistently maintain documentation within its procurement files to evidence that price reasonableness was considered and supported prior to vendor selection or contract execution for micro-purchase transactions. Questioned Costs: No questioned costs were identified. The finding relates to insufficient documentation supporting the price reasonableness determination of certain procurements. Recommendation: We recommend that the University strengthen its procurement procedures for federally-funded micro-purchases to require documentation of price reasonableness prior to approval of the purchase or execution of the contract. We further recommend that the University require such documentation to be retained in a consistent manner and that procurement personnel review the documentation for completeness before approval. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Procurement, Suspension and Debarment, is presented in the Corrective Action Plan section of this report.

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FINDING 2025-002 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment (Significant Deficiency and Noncompliance) Federal Agency: Various Federal Agencies Federal Program: Research and Development Cluster Assistance Listing Numbers: 47.076, 93.243, and 47.010 (Direct Awards) Criteria: Uniform Guidance requires recipients and subrecipients to maintain and use documented procurement procedures for procurement transactions under a Federal award or subaward, and such procedures must be consistent with the procurement standards in 2 CFR § 200.317 through 200.327. In addition, 2 CFR § 200.320(a)(1)(ii) provides that micro-purchases may be awarded without soliciting competitive price or rate quotations only if the recipient or subrecipient considers the price reasonable based on research, experience, purchase history, or other information and maintains documentation to support its conclusion. Condition: During the audit, we tested five (5) vendors classified as micro-purchases. For each selected vendor, the University was unable to provide documentation evidencing that a cost or price reasonableness review was performed prior to vendor selection or contract execution. Specifically, the procurement files did not include pricing comparisons, competing quotes, market research, purchase history, documented experience, or other support demonstrating how the contract price was determined to be reasonable. Effect or Potential Effect: Without documented evidence of price reasonableness, the University cannot demonstrate that micro-purchase awards were made in accordance with Uniform Guidance procurement requirements. This increases the risk that federally-funded procurement transactions may not be supported by adequate documentation to demonstrate that prices paid were reasonable, and that procurement decisions may not be consistently supported, reviewed, and retained in accordance with federal requirements. Context: This is a condition based on testing the University’s compliance with specific requirements. The prevalence of this finding is detailed in the condition above. The samples were selected using a non-statistical method. Cause: The University did not consistently maintain documentation within its procurement files to evidence that price reasonableness was considered and supported prior to vendor selection or contract execution for micro-purchase transactions. Questioned Costs: No questioned costs were identified. The finding relates to insufficient documentation supporting the price reasonableness determination of certain procurements. Recommendation: We recommend that the University strengthen its procurement procedures for federally-funded micro-purchases to require documentation of price reasonableness prior to approval of the purchase or execution of the contract. We further recommend that the University require such documentation to be retained in a consistent manner and that procurement personnel review the documentation for completeness before approval. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Procurement, Suspension and Debarment, is presented in the Corrective Action Plan section of this report.

Corrective Action Plan

FINDING 2025-002 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment (Significant Deficiency and Noncompliance) Responsive to finding: We agree with the finding. Corrective Action Plan: Gallaudet University will enhance its procurement procedures to ensure that price reasonableness analyses are performed and documented prior to entering into agreements with vendors in accordance with Uniform Guidance procurement requirements. The University will implement the following corrective actions: • Continue to monitor and review procurement policies and procedures for changes in applicable federal requirements and institutional practices. Procurement policies, procedures, and related documentation tools will be updated as necessary, and the standardized procurement checklist will be periodically reviewed and revised to ensure alignment with current procurement policies and Uniform Guidance standards. • Require supervisory review of procurement transactions to ensure all required procurement documentation, including price reasonableness determinations, is completed and retained prior to final approval of vendor agreements. • Provide training to procurement and departmental personnel involved in federally funded procurements regarding Uniform Guidance requirements and documentation standards. • Conduct periodic monitoring of procurement files to verify ongoing compliance with procurement policies, procedures, checklist requirements, and applicable federal regulations. These corrective actions will strengthen the University's internal controls over procurement activities and help ensure compliance with Uniform Guidance requirements related to procurement documentation and vendor selection. Individual(s) Responsible for Corrective Action Plan: Randi Vandegrift, Strategic Sourcing Manager John Skjeveland, Controller Estimated Completion Date: September 30, 2026

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2025-003
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The University reported the information in the key line items noted above in the FISAP, however, it did not retain sufficient supporting documentation to substantiate certain reported information. Specifically, the University was unable to provide the underlying source data supporting: (1) total tuition and fees for the award year July 1, 2024 to June 30, 2025; (2) information on eligible aid applicants enrolled for award year 2024-25; and (3) nonfederal share of funds to FSEOG recipients. In addition, the total Federal Pell Grant expenditures for the 2024-2025 award year reported by the University in the FISAP did not reconcile to the University’s final Federal Pell Grant closeout balances. Effect or Potential Effect: As a result, the University could not demonstrate the completeness and accuracy of the reported information included within the key line items noted above. The lack of appropriate processes to accumulate and maintain the relevant supporting documentation used to prepare the FISAP increases the risk that inaccurate or incomplete information could be reported without detection and may result in noncompliance with the FISAP reporting requirements. In addition, the total Federal Pell Grant expenditures for the 2024-2025 award year reported in the FISAP were overstated by $97,915. Context: During testing of the University's FISAP, the audit team tested key line items subject to the reporting requirements. No supporting documentation was available to support the: (1) total tuition and fees for the award year July 1, 2024 to June 30, 2025; (2) information on eligible aid applicants enrolled for the award year 2024-25; and (3) the nonfederal share of funds to FSEOG recipients. In addition, the total Federal Pell Grant expenditures for the 2024-2025 award year reported in the FISAP totaled $3,348,864 while the Federal Pell Grant expenditures for the 2024-2025 award year per the University’s records totaled $3,250,949. Cause: The University did not maintain the underlying source reports, supporting schedules, or other documentation used to compile certain information included in the FISAP. As a result, the data used to prepare the disclosures could not be recreated or validated subsequent to the report's submission. In addition, when the FISAP was being prepared, the University had recently implemented a new enterprise planning system and certain financial aid internal controls and reconciliation processes were still being established. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its procedures for accumulating, preparing and retaining support for the FISAP. Specifically, management should retain the source reports, supporting schedules, calculations, and other relevant documentation used to compile reported information and implement a review process to verify that supporting documentation is maintained and readily available to substantiate all reported information. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Reporting, is presented in the Corrective Action Plan section of this report.

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FINDING 2025-003 Internal Control over Compliance and Compliance with Reporting (Significant Deficiency and Noncompliance) Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Number: Federal Supplemental Educational Opportunity Grant (84.007A), Federal Pell Grant (84.063P), and Federal Work Study (84.033A) Criteria: The Fiscal Operations Report and Application to Participate (FISAP) is used by schools to apply for Campus-Based Program funding for the upcoming award year and to report Campus-Based Program expenditures for the previous award year (34 CFR 674.19, 34 CFR 675.19, 34 CFR 676.19 and 20 U.S.C 1094). Key line items on the FISAP include: Part II (Application), Section E, Line 22: Total tuition and fees; Part II (Application), Section E, Line 23: Total Federal Pell Grant expenditures; Part II (Application), Section F, Lines 25-39: Information on eligible aid applicants; Part IV (FSEOG), Section C, Lines 12-14: Funds to FSEOG recipients; and Part V (FWS), Section C, Lines 12-14: Total compensation for FWS. The University is responsible for maintaining sufficient records to support the completeness and accuracy of information reported in the FISAP. Condition: The University reported the information in the key line items noted above in the FISAP, however, it did not retain sufficient supporting documentation to substantiate certain reported information. Specifically, the University was unable to provide the underlying source data supporting: (1) total tuition and fees for the award year July 1, 2024 to June 30, 2025; (2) information on eligible aid applicants enrolled for award year 2024-25; and (3) nonfederal share of funds to FSEOG recipients. In addition, the total Federal Pell Grant expenditures for the 2024-2025 award year reported by the University in the FISAP did not reconcile to the University’s final Federal Pell Grant closeout balances. Effect or Potential Effect: As a result, the University could not demonstrate the completeness and accuracy of the reported information included within the key line items noted above. The lack of appropriate processes to accumulate and maintain the relevant supporting documentation used to prepare the FISAP increases the risk that inaccurate or incomplete information could be reported without detection and may result in noncompliance with the FISAP reporting requirements. In addition, the total Federal Pell Grant expenditures for the 2024-2025 award year reported in the FISAP were overstated by $97,915. Context: During testing of the University's FISAP, the audit team tested key line items subject to the reporting requirements. No supporting documentation was available to support the: (1) total tuition and fees for the award year July 1, 2024 to June 30, 2025; (2) information on eligible aid applicants enrolled for the award year 2024-25; and (3) the nonfederal share of funds to FSEOG recipients. In addition, the total Federal Pell Grant expenditures for the 2024-2025 award year reported in the FISAP totaled $3,348,864 while the Federal Pell Grant expenditures for the 2024-2025 award year per the University’s records totaled $3,250,949. Cause: The University did not maintain the underlying source reports, supporting schedules, or other documentation used to compile certain information included in the FISAP. As a result, the data used to prepare the disclosures could not be recreated or validated subsequent to the report's submission. In addition, when the FISAP was being prepared, the University had recently implemented a new enterprise planning system and certain financial aid internal controls and reconciliation processes were still being established. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its procedures for accumulating, preparing and retaining support for the FISAP. Specifically, management should retain the source reports, supporting schedules, calculations, and other relevant documentation used to compile reported information and implement a review process to verify that supporting documentation is maintained and readily available to substantiate all reported information. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Reporting, is presented in the Corrective Action Plan section of this report.

Corrective Action Plan

FINDING 2025-003 Internal Control over Compliance and Compliance with Reporting (Significant Deficiency and Noncompliance) Responsive to finding: We agree with the finding. Corrective Action Plan: Gallaudet University will continue to enhance its procedures for the preparation, reconciliation, review, and retention of supporting documentation related to the Fiscal operations Report and Application to Participate (FISAP) to ensure that all reported information is complete, accurate, adequately supported, and retained in accordance with federal requirements. The University will implement the following corrective actions: • Continue to refine FISAP preparation procedures by clearly identifying the source reports, calculations, reconciliations, review requirements, and supporting documentation necessary for key reporting line items to promote consistency, accuracy, and supportability of reported information. • Enhance documentation retention practices by maintaining a centralized electronic repository for FISAP-related source reports, supporting schedules, reconciliations, calculations, and review documentation to ensure supporting records are readily available for review and audit purposes. • Continue to strengthen reconciliation procedures by requiring documented reconciliation of key FISAP data elements, including Pell Grant expenditures, tuition and fee information, eligible applicant data, and campus-based program expenditures, to supporting financial aid records, federal reporting records, and the general ledger prior to submission. • Enhance supervisory review procedures to verify the completeness, accuracy, and supportability of information reported in the FISAP before certification and submission to the U.S. Department of Education. • Conduct periodic monitoring of FISAP preparation and documentation retention practices to verify compliance with established procedures and identify opportunities for continuous improvement. These corrective actions will further strengthen the University's internal controls over federal reporting and help ensure ongoing compliance with FISAP reporting requirements and documentation retention standards. Individual(s) Responsible for Corrective Action Plan: Amanda Jackson, Director of Financial Aid John Skjeveland, Controller Estimated Completion Date: September 30, 2026

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2025-004
Special Tests & Provisions
MATERIAL WEAKNESSOTHER MATTERS

During the audit, we tested twenty-five (25) students who had enrollment status changes during the fiscal year ended September 30, 2025. For four (4) of these students who graduated, the University did not report the graduation status within the required 60 days of the change. Effect or Potential Effect: Timeliness of reporting graduation status to the NSLDS could impact notification to loan servicers that a borrower has entered repayment status, the start of a borrower’s grace period, and/or deferment, repayment scheduling, and loan servicing. Context: This is a condition based on testing the University’s compliance with specific requirements. The prevalence of this finding is detailed in the condition above. The samples were selected using a non-statistical method. Cause: The University recently implemented a new enterprise planning system and certain reports used to identify enrollment status changes to be reported to NSLDS did not include all students who graduated. The system reports were not sufficiently reviewed to detect these omissions. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its procedures for identifying and reporting student enrollment status changes to the NSLDS to ensure that the submission of such enrollment information is accurate and timely. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Special Tests and Provisions – NSLDS reporting, is presented in the Corrective Action Plan section of this report.

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FINDING 2025-004 Internal Control over Compliance and Compliance with Special Tests and Provisions – NSLDS Reporting (Material Weakness and Material Noncompliance) Federal Agency: U.S. Department of Education Federal Program: Student Financial Assistance Cluster Assistance Listing Number: Federal Pell Grant (84.063P) and Federal Direct Loans (84.268) Criteria: Institutions are required to report enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035, 34 CFR 690.83(b)(2), 34 CFR 682.610, 34 CFR 685.309, and 34 CFR 674.19(f)). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. When a Direct Loan was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the institution and who received a loan under Title IV has changed his or her permanent address, the institution must report the change in its next updated Enrollment Reporting Roster file (due within 60 days of the change). Condition: During the audit, we tested twenty-five (25) students who had enrollment status changes during the fiscal year ended September 30, 2025. For four (4) of these students who graduated, the University did not report the graduation status within the required 60 days of the change. Effect or Potential Effect: Timeliness of reporting graduation status to the NSLDS could impact notification to loan servicers that a borrower has entered repayment status, the start of a borrower’s grace period, and/or deferment, repayment scheduling, and loan servicing. Context: This is a condition based on testing the University’s compliance with specific requirements. The prevalence of this finding is detailed in the condition above. The samples were selected using a non-statistical method. Cause: The University recently implemented a new enterprise planning system and certain reports used to identify enrollment status changes to be reported to NSLDS did not include all students who graduated. The system reports were not sufficiently reviewed to detect these omissions. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its procedures for identifying and reporting student enrollment status changes to the NSLDS to ensure that the submission of such enrollment information is accurate and timely. Views of Responsible Official: Management’s corrective action plan, including immediate remediation steps and enhancements to internal controls over Special Tests and Provisions – NSLDS reporting, is presented in the Corrective Action Plan section of this report.

Corrective Action Plan

FINDING 2025-004 Internal Control over Compliance and Compliance with Special Tests and Provisions – NSLDS Reporting (Material Weakness and Material Noncompliance) Responsive to finding: We agree with the finding. Corrective Action Plan: Gallaudet University will continue to enhance its procedures for identifying, monitoring, reviewing, and reporting student enrollment status changes to the National Student Loan Data System (NSLDS) to help ensure that enrollment information is submitted accurately and within required timeframes. • Continue to refine NSLDS reporting procedures to ensure that enrollment status changes, including graduations, withdrawals, and changes in enrollment status, are appropriately identified and reported in accordance with federal requirements. • Enhance system-generated reporting and validation procedures associated with the University’s enterprise planning system to help ensure that all students with enrollment status changes are captured in NSLDS reporting files. • Continue to strengthen reconciliation procedures by comparing enrollment status changes recorded in student records to information included in NSLDS reporting submissions and investigating any discrepancies identified. • Enhance supervisory review procedures to verify the completeness, accuracy, and timeliness of NSLDS enrollment reporting prior to submission. • Conduct periodic monitoring of enrollment reporting processes and submission timeliness to verify compliance with federal reporting requirements and identify opportunities for continuous improvement. These corrective actions will further strengthen the University's internal controls over NSLDS reporting and help ensure compliance federal reporting requirements and identify opportunities for continuous improvement. Individual(s) Responsible for Corrective Action Plan: Amanda Jackson, Director of Financial Aid Elice Patterson, Registrar Estimated Completion Date: Immediate

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FY 2024-09-30

LOW-RISK AUDITEE$170,363,408 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 30, 2025 — management decision was due December 30, 2025.

FY 2023-09-30

LOW-RISK AUDITEE$179,079,123 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 28, 2024 — management decision was due December 28, 2024.

FY 2022-09-30

LOW-RISK AUDITEE$176,246,749 federal awards expended

FAC accepted this audit on June 28, 2023 — management decision was due December 28, 2023.

2022-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Finding Reference: 2022-001 U.S. Department of Education Federal Appropriations (84.910A) Reporting (Significant Deficiency) Criteria: The University is required to prepare and submit an annual report to the Secretary and to the Committee on Education and Labor of the House of Representatives and Committee on Labor and Human Resources of the Senate, not later than 100 days after the end of each fiscal year. Condition and Effect: The Annual Report of Achievements (the ?Report?) submitted by the University for Fiscal Year 2021 included certain tables containing clerical errors. In particular: ? VIII. KDES Student Characteristics, Related Educational Services Received and Achievement ? AY2020-2021 Enrollment at KDES: ECE, Elementary (1-5), and Middle (6-8) ? The data that should have been reported in the ?Left Before Completing Program? row was inadvertently reported in the ?Completed Program? row, and vice versa. ? IX. MSSD Student Characteristics, Related Educational Services, and Outcomes ? MSSD 2020 Graduates? One-Year Outcomes by Race/Ethnicity ? Within the ?All Traditionally Underserved? column, the data that should have been reported in the ?Working and Enrolled in a Postsecondary Program? row was inadvertently reported in the ?Neither Working Nor Enrolled in a Postsecondary Program? row, and vice versa. Context: During our audit, we tested over 350 data points contained in eight (8) tables included in the Report. We noted the clerical errors described above impacted 30 data points in two (2) of those tables. Cause: In the preparation of the Report for Fiscal Year 2021, the University inadvertently transposed data in certain tables described above. The errors were not identified since the totals within the tables were accurately reported. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its review procedures over the preparation of the annual Report of Achievements such that it is submitted accurately. Views of Responsible Official: Refer to Corrective Action Plan.

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Finding Reference: 2022-001 U.S. Department of Education Federal Appropriations (84.910A) Reporting (Significant Deficiency) Criteria: The University is required to prepare and submit an annual report to the Secretary and to the Committee on Education and Labor of the House of Representatives and Committee on Labor and Human Resources of the Senate, not later than 100 days after the end of each fiscal year. Condition and Effect: The Annual Report of Achievements (the ?Report?) submitted by the University for Fiscal Year 2021 included certain tables containing clerical errors. In particular: ? VIII. KDES Student Characteristics, Related Educational Services Received and Achievement ? AY2020-2021 Enrollment at KDES: ECE, Elementary (1-5), and Middle (6-8) ? The data that should have been reported in the ?Left Before Completing Program? row was inadvertently reported in the ?Completed Program? row, and vice versa. ? IX. MSSD Student Characteristics, Related Educational Services, and Outcomes ? MSSD 2020 Graduates? One-Year Outcomes by Race/Ethnicity ? Within the ?All Traditionally Underserved? column, the data that should have been reported in the ?Working and Enrolled in a Postsecondary Program? row was inadvertently reported in the ?Neither Working Nor Enrolled in a Postsecondary Program? row, and vice versa. Context: During our audit, we tested over 350 data points contained in eight (8) tables included in the Report. We noted the clerical errors described above impacted 30 data points in two (2) of those tables. Cause: In the preparation of the Report for Fiscal Year 2021, the University inadvertently transposed data in certain tables described above. The errors were not identified since the totals within the tables were accurately reported. Questioned Costs: None identified. Recommendation: We recommend that the University strengthen its review procedures over the preparation of the annual Report of Achievements such that it is submitted accurately. Views of Responsible Official: Refer to Corrective Action Plan.

Corrective Action Plan

Finding Reference: 2022-001 U.S. Department of Education Federal Appropriations (84.910A) Reporting (Significant Deficiency) Views of Responsible Official ? Tracy Berman-Kagan, Controller (Tracy.berman-kagan@gallaudet.edu and 202-651-5294) and Planned Corrective Action: The University agrees that there were two sets of clerical errors related to the Clerc Center data reported in the Annual Report of Achievement (the ?Report?). Starting with the Report created in December 2022, for the Fiscal Year 2023 audit, the University implemented an extra step and review in the process of reviewing the tables in the Report again right before printing to ensure that errors are more likely to be found. For the Report that was audited, a final review before printing was not included as part of the process, and it is likely that the clerical errors occurred between the draft tables and the final creation of the Report.

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FY 2021-09-30

LOW-RISK AUDITEE$168,152,346 federal awards expended

FAC accepted this audit on June 26, 2022 — management decision was due December 26, 2022.

2021-001
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCY

Criteria: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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 is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Governmentwide System for Award Management (SAM) Exclusions maintained by the General Services Administration, (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). Condition and Effect: The University was unable to provide evidence suspension and debarment verification procedures were performed for certain transactions with vendors during 2021. Context: During fiscal 2021, the University was unable to provide evidence that either SAM Exclusion checks were performed, certifications from vendors were obtained, or a clause or condition was included in the respective contracts for the sixty-five (65) covered transactions haphazardly selected for testing. However, it was noted that none of the entities selected for testing were excluded or disqualified per review of the SAM Exclusions. Cause: The University has a procurement policy relating to expenditures of Federal funds that requires verification that contractors, consultants, and subrecipients are not listed in the SAM Exclusions. The University did not retain documentation providing evidence that such procedures were performed for the covered transactions within ALN 84.910B. Questioned Costs: None identified. Recommendation: We recommend that the University modify its policies and procedures to ensure that the University retains evidence that suspension and debarment verification procedures are performed in accordance with 2 CFR section 180.300. Views of Responsible Official: Refer to Corrective Action Plan.

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Criteria: Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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 is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Governmentwide System for Award Management (SAM) Exclusions maintained by the General Services Administration, (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). Condition and Effect: The University was unable to provide evidence suspension and debarment verification procedures were performed for certain transactions with vendors during 2021. Context: During fiscal 2021, the University was unable to provide evidence that either SAM Exclusion checks were performed, certifications from vendors were obtained, or a clause or condition was included in the respective contracts for the sixty-five (65) covered transactions haphazardly selected for testing. However, it was noted that none of the entities selected for testing were excluded or disqualified per review of the SAM Exclusions. Cause: The University has a procurement policy relating to expenditures of Federal funds that requires verification that contractors, consultants, and subrecipients are not listed in the SAM Exclusions. The University did not retain documentation providing evidence that such procedures were performed for the covered transactions within ALN 84.910B. Questioned Costs: None identified. Recommendation: We recommend that the University modify its policies and procedures to ensure that the University retains evidence that suspension and debarment verification procedures are performed in accordance with 2 CFR section 180.300. Views of Responsible Official: Refer to Corrective Action Plan.

Corrective Action Plan

Views of Responsible Official ? Tracy Berman-Kagan, Controller (tracy.berman-kagan@gallaudet.edu and 202-651-5294) and Planned Corrective Action: The University agrees that evidence that suspension and debarment verification procedures were performed in accordance with 2 CFR section 180.300 was not maintained. In June 2022, the University contracted with a third-party vendor, Verify Comply, which will result in Gallaudet uploading all of its vendors to an online portal to have the vendors reviewed monthly against the SAM Exclusions list. The search list will be saved as a report and downloaded and maintained within the University?s Finance Office, demonstrating that a regular review is occurring, and any potential issues are appropriately evaluated and documented.

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FY 2020-09-30

LOW-RISK AUDITEE$153,595,415 federal awards expendedNo findings recorded this year

FAC accepted this audit on June 8, 2021 — management decision was due December 8, 2021.

FY 2019-09-30

$146,766,737 federal awards expended

FAC accepted this audit on June 1, 2020 — management decision was due December 1, 2020.

2019-001
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

U.S. Department of EducationFinding Reference: 2019-001Reporting ? Common Origination and Disbursement System (Significant Deficiency)Federal Pell Grant Program (CFDA #84.063)Federal Award Number: P063P20010296 Federal Award Year: 2018-2019Criteria:Schools are required to submit Pell origination records and disbursement records to the Common Origination and Disbursement system (?COD?). Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. A school follows up with a disbursement record for that student no more than 15 days before a disbursement is to be paid (7 days in the case of a school using the just-in-time method). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the Pell Payment origination and disbursement data, the auditor should be most concerned with the data ED has categorized as accepted or accepted with corrections. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.Condition and Effect:Certain disbursement information was not reported to the COD timely.Context:From a total sample of forty (40) disbursements selected for testing, student payment information for four (4) disbursements was not reported within the 15 calendar days.Cause:The University?s Financial Aid Office was in a period of transition during fiscal 2019 due to the departure of its Director. As a result, the timely reporting of Pell disbursements to the COD was affected.Questioned Costs:None identified, as the student payment data was eventually reported.Recommendation:We recommend that the University strengthen its procedures over COD reporting and, devote the necessary resources, as appropriate, such that student payment data is submitted to ED through the COD System timely.Views of Responsible Official:Refer to Corrective Action Plan.

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U.S. Department of EducationFinding Reference: 2019-001Reporting ? Common Origination and Disbursement System (Significant Deficiency)Federal Pell Grant Program (CFDA #84.063)Federal Award Number: P063P20010296 Federal Award Year: 2018-2019Criteria:Schools are required to submit Pell origination records and disbursement records to the Common Origination and Disbursement system (?COD?). Origination records can be sent well in advance of any disbursements, as early as the school chooses to submit them for any student the school reasonably believes will be eligible for a payment. A school follows up with a disbursement record for that student no more than 15 days before a disbursement is to be paid (7 days in the case of a school using the just-in-time method). The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the school. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the Pell Payment origination and disbursement data, the auditor should be most concerned with the data ED has categorized as accepted or accepted with corrections. Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment to previously reported student payment data or expected student payment data. Schools may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner.Condition and Effect:Certain disbursement information was not reported to the COD timely.Context:From a total sample of forty (40) disbursements selected for testing, student payment information for four (4) disbursements was not reported within the 15 calendar days.Cause:The University?s Financial Aid Office was in a period of transition during fiscal 2019 due to the departure of its Director. As a result, the timely reporting of Pell disbursements to the COD was affected.Questioned Costs:None identified, as the student payment data was eventually reported.Recommendation:We recommend that the University strengthen its procedures over COD reporting and, devote the necessary resources, as appropriate, such that student payment data is submitted to ED through the COD System timely.Views of Responsible Official:Refer to Corrective Action Plan.

Corrective Action Plan

U.S. Department of EducationFinding Reference: 2019-001Reporting ? Common Origination and Disbursement System (Significant Deficiency)Federal Pell Grant Program (CFDA #84.063)Federal Award Number: P063P20010296 Federal Award Year: 2018-2019Views of Responsible Official ? Doryann Barnhardt, Director of Financial Aid (doryann.barnhardt@gallaudet.edu); 202-651-5290) and Planned Corrective Action: The University agrees that not all Pell disbursements were reported in a timely manner. We will strengthen our control process and report disbursements to COD on a regular basis throughout the semester. Disbursement files will be sent to COD every two weeks.

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2019-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

U.S. Department of EducationFinding Reference: 2019-002Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Significant Deficiency)Federal Direct Loan Program (CFDA #84.268)Federal Award Number: P268K171239 Federal Award Year: 2018-2019Student Financial Assistance ClusterCriteria:Institutions must report all loan disbursements and submit required records to the Direct Loan Servicing System (DLSS) via the COD within 15 days of disbursement (OMB No. 1845-0021). Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records. Since up to three Direct Loan program years may be open at any given time, schools may receive three SAS data files each month (34 CFR sections 685.102(b), 685.301, and 303).Condition and Effect:Certain disbursement information was not reported to the DLSS via the COD timely.Context:From a total sample of forty (40) disbursements selected for testing, student payment information for three (3) disbursements was not reported within the 15 calendar days.Cause:The University?s Financial Aid Office was in a period of transition during fiscal 2019 due to the departure of its Director. As a result, the timely reporting of Direct Loan disbursements to the COD was affected.Questioned Costs:None identified, as the student payment data was eventually reported.Recommendation:We recommend that the University strengthen its procedures over COD reporting and, devote the necessary resources, as appropriate, such that student payment data is submitted to ED through the COD System timely.Views of Responsible Official:Refer to Corrective Action Plan.

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U.S. Department of EducationFinding Reference: 2019-002Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Significant Deficiency)Federal Direct Loan Program (CFDA #84.268)Federal Award Number: P268K171239 Federal Award Year: 2018-2019Student Financial Assistance ClusterCriteria:Institutions must report all loan disbursements and submit required records to the Direct Loan Servicing System (DLSS) via the COD within 15 days of disbursement (OMB No. 1845-0021). Each month, the COD provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records. Since up to three Direct Loan program years may be open at any given time, schools may receive three SAS data files each month (34 CFR sections 685.102(b), 685.301, and 303).Condition and Effect:Certain disbursement information was not reported to the DLSS via the COD timely.Context:From a total sample of forty (40) disbursements selected for testing, student payment information for three (3) disbursements was not reported within the 15 calendar days.Cause:The University?s Financial Aid Office was in a period of transition during fiscal 2019 due to the departure of its Director. As a result, the timely reporting of Direct Loan disbursements to the COD was affected.Questioned Costs:None identified, as the student payment data was eventually reported.Recommendation:We recommend that the University strengthen its procedures over COD reporting and, devote the necessary resources, as appropriate, such that student payment data is submitted to ED through the COD System timely.Views of Responsible Official:Refer to Corrective Action Plan.

Corrective Action Plan

U.S. Department of EducationFinding Reference: 2019-002Special Tests and Provisions ? Borrower Data Transmission and Reconciliation (Significant Deficiency)Federal Direct Loan Program (CFDA #84.268)Federal Award Number: P268K171239 Federal Award Year: 2018-2019Student Financial Assistance ClusterViews of Responsible Official ? Doryann Barnhardt, Director of Financial Aid (doryann.barnhardt@gallaudet.edu); 202-651-5290) and Planned Corrective Action: The University agrees that not all Direct Loan disbursements were reported in a timely manner. We will strengthen our control process and report disbursements to COD on a regular basis throughout the semester. Disbursement files will be sent to COD every two weeks.

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2019-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

U.S. Department of EducationFinding Reference: 2019-003Special Tests and Provisions ? Verification (Significant Deficiency)Federal Supplemental Educational Opportunity Grant (CFDA #84.007)Federal Award Number: P007A160837 Federal Award Year: 2018-2019Federal Work-Study Program (CFDA #84.033)Federal Award Number: P033A160837 Federal Award Year: 2018-2019Federal Pell Grant Program (CFDA #84.063)Federal Award Number: P063P161239 Federal Award Year: 2018-2019Federal Direct Loan Program (CFDA #84.268)Federal Award Number: P268K171239 Federal Award Year: 2018-2019Federal Perkins Loan Program (CFDA #84.038) Federal Award Year: 2018-2019Student Financial Assistance ClusterCriteria:An institution not participating under an ED-approved Quality Assurance Program (?QAP?) is required to establish written policies and procedures that incorporate the provisions of 34 CFR sections 668.51 through 668.61 for verifying student information. Such an institution shall require each student whose application is selected by ED to verify the information required for the Verification Tracking Group to which the student is assigned. Specified verification items and acceptable documentation are listed in the Federal Register. The institution shall also require students to verify any information used to calculate an applicant?s EFC that the institution has reason to believe is inaccurate, as noted per 34 CFR section 668.54(a). Acceptable documentation for the verification is listed in 34 CFR section 668.57.Condition and Effect:Evidence of approval of verification procedures for certain students within our testing sample was not provided.Context:From a selection of forty (40) students, for which verification procedures were noted to be performed by the University, we identified three (3) whose forms did not have evidence of approval.Cause:The University?s Financial Aid Office was in a period of transition during fiscal 2019 due to the departure of its Director. The previous Director performed and completed the three (3) verification forms noted above prior to the disbursement of aid to the respective students, but did not properly document evidence of approval.Questioned Costs:None identified, as verification procedures were completed priod to discbursement of aid.Recommendation:We recommend that the University strengthen its procedures over the verification process so evidence of approvals are maintained.Views of Responsible Official:Refer to Corrective Action Plan.

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U.S. Department of EducationFinding Reference: 2019-003Special Tests and Provisions ? Verification (Significant Deficiency)Federal Supplemental Educational Opportunity Grant (CFDA #84.007)Federal Award Number: P007A160837 Federal Award Year: 2018-2019Federal Work-Study Program (CFDA #84.033)Federal Award Number: P033A160837 Federal Award Year: 2018-2019Federal Pell Grant Program (CFDA #84.063)Federal Award Number: P063P161239 Federal Award Year: 2018-2019Federal Direct Loan Program (CFDA #84.268)Federal Award Number: P268K171239 Federal Award Year: 2018-2019Federal Perkins Loan Program (CFDA #84.038) Federal Award Year: 2018-2019Student Financial Assistance ClusterCriteria:An institution not participating under an ED-approved Quality Assurance Program (?QAP?) is required to establish written policies and procedures that incorporate the provisions of 34 CFR sections 668.51 through 668.61 for verifying student information. Such an institution shall require each student whose application is selected by ED to verify the information required for the Verification Tracking Group to which the student is assigned. Specified verification items and acceptable documentation are listed in the Federal Register. The institution shall also require students to verify any information used to calculate an applicant?s EFC that the institution has reason to believe is inaccurate, as noted per 34 CFR section 668.54(a). Acceptable documentation for the verification is listed in 34 CFR section 668.57.Condition and Effect:Evidence of approval of verification procedures for certain students within our testing sample was not provided.Context:From a selection of forty (40) students, for which verification procedures were noted to be performed by the University, we identified three (3) whose forms did not have evidence of approval.Cause:The University?s Financial Aid Office was in a period of transition during fiscal 2019 due to the departure of its Director. The previous Director performed and completed the three (3) verification forms noted above prior to the disbursement of aid to the respective students, but did not properly document evidence of approval.Questioned Costs:None identified, as verification procedures were completed priod to discbursement of aid.Recommendation:We recommend that the University strengthen its procedures over the verification process so evidence of approvals are maintained.Views of Responsible Official:Refer to Corrective Action Plan.

Corrective Action Plan

U.S. Department of EducationFinding Reference: 2019-003Special Tests and Provisions ? Verification (Significant Deficiency)Federal Supplemental Educational Opportunity Grant (CFDA #84.007)Federal Award Number: P007A160837 Federal Award Year: 2018-2019Federal Work-Study Program (CFDA #84.033)Federal Award Number: P033A160837 Federal Award Year: 2018-2019Federal Pell Grant Program (CFDA #84.063)Federal Award Number: P063P161239 Federal Award Year: 2018-2019Federal Direct Loan Program (CFDA #84.268)Federal Award Number: P268K171239 Federal Award Year: 2018-2019Federal Perkins Loan Program (CFDA #84.038) Federal Award Year: 2018-2019Student Financial Assistance ClusterViews of Responsible Official ? Doryann Barnhardt, Director of Financial Aid (doryann.barnhardt@gallaudet.edu); 202-651-5290) and Planned Corrective Action: The University agrees that evidence of approval was not properly documented. We will strengthen our control process by requiring an approver signature and date on our internal verification checklist. The checklist will be reviewed for completion by another financial aid team member before verification files are transmitted.

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FY 2018-09-30

$143,929,259 federal awards expended

FAC accepted this audit on March 25, 2019 — management decision was due September 25, 2019.

2018-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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FY 2017-09-30

LOW-RISK AUDITEE$136,020,811 federal awards expended

FAC accepted this audit on March 4, 2018 — management decision was due September 4, 2018.

2017-001
Reporting
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-002
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2016-001

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-001

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2017-003
Eligibility
MATERIAL WEAKNESSREPEAT OF 2016-003

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-003

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2017-004
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2016-09-30

LOW-RISK AUDITEE$154,101,904 federal awards expended

FAC accepted this audit on February 19, 2017 — management decision was due August 19, 2017.

2016-001
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2015-001OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2015-001

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2016-002
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2015-002OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2015-002

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2016-003
Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2016-004
Subrecipient Monitoring
OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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