Corrective Action Plans

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FINDING 2022-005 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Ralph Shrader/Jim Beyer CONTACT PHONE NUMBER: 765-762-3364 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: School Corporation will advertise and attain sealed bids for projects as req...
FINDING 2022-005 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Ralph Shrader/Jim Beyer CONTACT PHONE NUMBER: 765-762-3364 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: School Corporation will advertise and attain sealed bids for projects as required by Federal guidelines. Detailed contracts and invoices will be required by the bidder before payment is made. ANTICIPATED COMPLETION DATE: March 2023
View Audit 29924 Questioned Costs: $1
FINDING 2022-002 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: All claims/invoices will be reviewed by the Food Service Director and va...
FINDING 2022-002 CONTACT PERSON RESPONSIBLE FOR CORRECTIVE ACTION: Lacey Sturgeon/Melissa Bell CONTACT PHONE NUMBER: 765-762-2500 VIEWS OF RESPONSIBLE OFFICIAL: We concur with the finding. DESCRIPTION OF CORRECTIVE ACTION PLAN: All claims/invoices will be reviewed by the Food Service Director and validated by the Assistant Food Service Director for correct contractual prices. ANTICIPATED COMPLETION DATE: March 2023
Contact Person - Paul Grams, Superintendent. Corrective Action Plan - The District will review their procedures to ensure that all expenditures are eligible expenditures. Completion Date - January 31, 2023.
Contact Person - Paul Grams, Superintendent. Corrective Action Plan - The District will review their procedures to ensure that all expenditures are eligible expenditures. Completion Date - January 31, 2023.
AGING CLUSTER ? Assistance Listing No. 93.AGING Recommendation: We recommend the Council review its payroll procedures over hourly employees to ensure all hours are properly accounted for by pay code in the final payroll. Explanation of disagreement with audit finding: There is no disagreement with ...
AGING CLUSTER ? Assistance Listing No. 93.AGING Recommendation: We recommend the Council review its payroll procedures over hourly employees to ensure all hours are properly accounted for by pay code in the final payroll. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Fiscal staff will review timesheet formats and search for possible improvements to the existing templates. Since this incident occurred, the Council has split the former Fiscal Coordinator position into two separate roles. This allows each employee to spend additional time on a fewer number of employees during payroll and review each timesheet with a high level of detail. Fiscal staff will continue to focus on precautions to reduce risk of error and employees will be encouraged to review their paystubs after each pay period. Name(s) of the contact person(s) responsible for corrective action: Becky Walter, Fiscal Manager Planned completion date for corrective action plan: December 31, 2023
Community Development Block Grants ? Assistance Listing No. 14.228 Recommendation: We recommend that the Council record federal expenditures on the SEFA under the program in the year upon which the loan disbursement occurs. Explanation of disagreement with audit finding: There is no disagreement wit...
Community Development Block Grants ? Assistance Listing No. 14.228 Recommendation: We recommend that the Council record federal expenditures on the SEFA under the program in the year upon which the loan disbursement occurs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Council has revised their procedures so that loan disbursements will be recorded on the SEFA in the year in which they are disbursed. Name(s) of the contact person(s) responsible for corrective action: Anita Cameron, NLF Director, and Becky Walter, Fiscal Manager Planned completion date for corrective action plan: December 31, 2023
Community Development Block Grants ? Assistance Listing No. 14.228 Recommendation: We recommend preparing the required reports under the CDBG program to be ready for uploading to the portal once it is accessible to ensure reporting requirements are met. Explanation of disagreement with audit finding...
Community Development Block Grants ? Assistance Listing No. 14.228 Recommendation: We recommend preparing the required reports under the CDBG program to be ready for uploading to the portal once it is accessible to ensure reporting requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Program Director will work with the Fiscal Office to ensure all reporting requirements are met prior to the deadline, regardless of ability to submit. This plan will ensure past, current, and future reporting requirements are met. Name(s) of the contact person(s) responsible for corrective action: Anita Cameron, NLF Director and Becky Walter, Fiscal Manager Planned completion date for corrective action plan: December 31, 2023
Finding 35396 (2022-004)
Significant Deficiency 2022
2022-004 Reporting Requirements for Federally Funded Projects - U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds, (Assistance Listing #21.027). Name of Contact Person Responsible...
2022-004 Reporting Requirements for Federally Funded Projects - U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds, (Assistance Listing #21.027). Name of Contact Person Responsible for Correction Action Plan: Sean Townsend, County Administrator Corrective Action Plan: The county has adopted a new Grant policy and procedures to ensure timely and accurate grant submissions. Anticipated Completion Date: Fiscal year 2023.
The District?s finding for not having adequate internal controls for ensuring compliance with wage rate requirements was solely because the district did not know about the federal requirement to monitor all certified payrolls paid by the contractors who provided the portable to the vendor the Distri...
The District?s finding for not having adequate internal controls for ensuring compliance with wage rate requirements was solely because the district did not know about the federal requirement to monitor all certified payrolls paid by the contractors who provided the portable to the vendor the District purchased from. Upon learning that the District is required to monitor certified payrolls paid by contractors and subcontractors who provide products to our vendors, the District will request certified payrolls from our vendors ensuring prevailing wages are paid from any corresponding contractor and subcontractor prior to final payment.
1. Excess indirect cost billing Three contracts identified with excess indirect cost billing will be corrected on the next invoice and prior to contract ending date. Assistance Listing (AL) No. 93.268 or 2103 CBO Contract and No. 93.391 or 2103 Health Equity Contract are ending by November 2023 and ...
1. Excess indirect cost billing Three contracts identified with excess indirect cost billing will be corrected on the next invoice and prior to contract ending date. Assistance Listing (AL) No. 93.268 or 2103 CBO Contract and No. 93.391 or 2103 Health Equity Contract are ending by November 2023 and May 2024 respectively. Hawaii Public Health Institute (HIPHI) will submit up to date billing with corrections. As recommended by the auditors, the HIPHI team will 1) create a written procedure that describes in detail the process to prepare and review program billings, and 2) implement guidelines on how to record indirect costs. For all federally awarded programs, the Director of Finance and Operations and the program's lead manager, with direct knowledge of the requirements for the grants, will review the billing prior to submission to the funder. The Finance and Accounting Manager and/or other trained Finance and Operations staff will prepare the billings, provide financial reports as requested, and include any supporting documentation used, for the reviewers.
View Audit 28427 Questioned Costs: $1
2022-003 Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods ? Assistance Listing No. 84.215J Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Also, we...
2022-003 Innovative Approaches to Literacy; Full-Service Community Schools; and Promise Neighborhoods ? Assistance Listing No. 84.215J Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Also, we recommend controls be put in place to ensure all wage rates are reviewed for accuracy prior to payroll being processed and charged to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In the interim the utilization of manual time sheets is taking place for individuals not designated 100 percent. We are also working on Implementation of Job costing for all Staff with PEO provider allowing restricted selections of projects and departments. Name of the contact person responsible for corrective action: Guadalupe Perez, HR Planned completion date for corrective action plan: 12/31/2023
2022-005 Controls Over Activities Allowed/Allowable Costs See Internal Control finding 2022-003.
2022-005 Controls Over Activities Allowed/Allowable Costs See Internal Control finding 2022-003.
2022-003 Controls Over Activities Allowed/Allowable Costs Recommendation: The Organization should review their established policies and procedures for effectiveness and ensure all employees adhere to all established procedures. Additionally, management should ensure all costs charged to the progr...
2022-003 Controls Over Activities Allowed/Allowable Costs Recommendation: The Organization should review their established policies and procedures for effectiveness and ensure all employees adhere to all established procedures. Additionally, management should ensure all costs charged to the program are allowable under the grant guidelines. Corrective Action Plan: United Way of Acadiana has welcomed a new Finance Director with experience in establishing internal controls. We are committed to implementing comprehensive internal controls that encompass enhancing financial reporting processes to ensure accuracy, transparency, and compliance with regulatory standards; budget oversight, risk management and expenditure and cash flow management.
Finding 2022-002 Name of Contact Person: Debra Hansen, Accounting Manager ? Grants and Gifts Corrective Action Plan: Effective May 2023, MMC ? Dickinson converted to the MCHS, Inc accounting systems and its accounting staff fully joined the MCHS, Inc centralized accounting team by August 2023, su...
Finding 2022-002 Name of Contact Person: Debra Hansen, Accounting Manager ? Grants and Gifts Corrective Action Plan: Effective May 2023, MMC ? Dickinson converted to the MCHS, Inc accounting systems and its accounting staff fully joined the MCHS, Inc centralized accounting team by August 2023, such that the MCHS system of controls now extend to MMC-Dickinson. Specifically with these changes, grant accounting duties are also transitioning to the MCHS grant accounting team which extends MCHS system of controls over grant accounting to MMC-Dickinson to ensure accurate and timely completion of the Schedule. Proposed Completion Date: December 31, 2023
Finding 2022-004 Name of Contact Person: Dan Fischer, Internal Consultant (former Controller) Corrective Action Plan: In early 2022, the team calculating physician compensation costs eligible for reporting in the HRSA portal experienced turnover of staff and thorough review of new staff?s work wa...
Finding 2022-004 Name of Contact Person: Dan Fischer, Internal Consultant (former Controller) Corrective Action Plan: In early 2022, the team calculating physician compensation costs eligible for reporting in the HRSA portal experienced turnover of staff and thorough review of new staff?s work was not completed for several months. Although expenses were overstated in the portal, the grant was not overcharged as lower expenses reported for physician compensation costs would have been replaced by increasing the amount related to additional eligible lost revenues. Management will implement review procedures for eligible physician compensation costs to ensure expenditures to the portal are accurate. Proposed Completion Date: December 31, 2023
View Audit 24187 Questioned Costs: $1
We are in receipt of the findings required to be reported by the single audit for Period 2 and Period 3 reporting for payments received from the Provider Relief Fund (PRF), specifically, regarding discrepancies in the reporting requirements and auditing for the above period for the PRF. Management d...
We are in receipt of the findings required to be reported by the single audit for Period 2 and Period 3 reporting for payments received from the Provider Relief Fund (PRF), specifically, regarding discrepancies in the reporting requirements and auditing for the above period for the PRF. Management does not dispute the finding. Subsequent to the completion of the FY 2021 single audit and the completion of reporting for periods 2 and 3, the district has prioritized the development of policies over financial reporting processes for all future periods of PRF reporting and auditing. The district will perform detailed analysis of the reporting requirements in accordance with the guidelines set forth by HRSA. The hospital CEO, Kelly Park, will oversee this to ensure that this is accomplished. The district will also provide its? consultants and information to be submitted to HRSA for accuracy. The district has already implemented these new procedures for period 4 reporting, and is confident that all future submissions will be correct. The Corrective Action Plan will be implemented by September 30, 2023.
Finding 35302 (2022-002)
Significant Deficiency 2022
The Finance Division will work with the Housing Authority to ensure all amounts are paid back to the grantor if the County was reimbursed. The error has been addressed internally to ensure it will not occur again in future adjustments.
The Finance Division will work with the Housing Authority to ensure all amounts are paid back to the grantor if the County was reimbursed. The error has been addressed internally to ensure it will not occur again in future adjustments.
Northfield Healthy Community Initiative respectfully submits the following corrective action plan for the year ended September 30, 2022. Audit period: October 01, 2021 - September 30, 2022 U.S. Department of the Treasury 2022-0...
Northfield Healthy Community Initiative respectfully submits the following corrective action plan for the year ended September 30, 2022. Audit period: October 01, 2021 - September 30, 2022 U.S. Department of the Treasury 2022-002 Education Partnership Coalition Grant ? Assistance Listing No. 21.027 Recommendation: The Organization should review the expense incurred date for disbursement within the grant award period start date to ensure proper period of performance criteria is met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Organization implemented process to review incurred dates for expenditures within the grant award period start and end dates. Name(s) of the contact person(s) responsible for corrective action: Sandy Malecha, Executive Director Planned completion date for corrective action plan: February 2023 If there are any questions regarding this plan, please call Sandy Malecha at 507-664-3524.
View Audit 24523 Questioned Costs: $1
Accountant?s Finding 2022 ? 001 Management concurs with this finding and we have implemented the following correcting actions: ? In Workday, the Basis Limit field is the key mechanism that will determine whether a subaward charges the appropriate amount of overhead. We have reviewed the current gr...
Accountant?s Finding 2022 ? 001 Management concurs with this finding and we have implemented the following correcting actions: ? In Workday, the Basis Limit field is the key mechanism that will determine whether a subaward charges the appropriate amount of overhead. We have reviewed the current grants that have out-going subawards and added/updated the Basis Limit as applicable. ? The staff in Sponsored Projects Accounting that create new accounts have received additional training on how/when to load a Basis Limit for out-going subawards. ? New reports have been created which identify that Basis Limits entered are complete and appropriate and these are reviewed on a monthly basis. ? As a result of the 2022R2 Workday Feature Release (9/22), Management has added a custom validation that will require a Basis Limit when an out-going subaward is included on a grant. Completion Date: January 2023 University Contact and Responsible Party: Joseph M. Gindhart, (314) 935-7089
View Audit 24634 Questioned Costs: $1
Finding No. 2022-002 ? Salaries and Benefits Not Supported by Proper Time and Effort Documentation Federal Program: Crime Victim Assistance Project No: 219001 and 216001 CFDA No: 16.575 Passed Through: Illinois Coalition Against Domestic Violence and Illinois Coalition Against Sexual Assault Federa...
Finding No. 2022-002 ? Salaries and Benefits Not Supported by Proper Time and Effort Documentation Federal Program: Crime Victim Assistance Project No: 219001 and 216001 CFDA No: 16.575 Passed Through: Illinois Coalition Against Domestic Violence and Illinois Coalition Against Sexual Assault Federal Agency: U.S. Department of Justice Condition: During our testwork, we noted the following: ? Two employee?s timesheets did not reflect the correct allocation percentages determined by the Organization, and ? One employee did not have a time and effort certification submitted during the 4th quarter of 2022. Plan: The Survivor Empowerment Center, Inc. is currently in the process of training a new HR Specialist and putting together a step-by-step checklist for completing payroll to ensure all steps are taken. This checklist includes a review of payroll by the Assistant Director. Anticipated Date of Completion: By February 10, 2023 ? the next payroll. Name of Contact Person: Susan Hicks, Assistant Director
Finding 35185 (2022-002)
Significant Deficiency 2022
Federal Program Corporation of National and Community Service - AmeriCorps Seniors Foster Grandparent Program, ALN 94.011, Award No. 21SFBPA002, Period 7/1/21 - 6/30/24 Condition/Cause Due to turnover in program staff, management was unable to locate certain requested documentation for audit testin...
Federal Program Corporation of National and Community Service - AmeriCorps Seniors Foster Grandparent Program, ALN 94.011, Award No. 21SFBPA002, Period 7/1/21 - 6/30/24 Condition/Cause Due to turnover in program staff, management was unable to locate certain requested documentation for audit testing. Recommendation We recommend that the University revisit and revise their documentation filing system for timecards, mileage reimbursement, and other documentation that would support amounts paid for stipends under the program. This would also include a complete inventory of all clearances/criminal background checks for current staff and volunteers working in the program and obtain updated background checks for any that are not on file. We also recommend the University revisit the process of replacing a director after their departure to ensure program compliance continues. Management Response We agree with the auditors' finding. The instance of non-compliance occurred during a period when the University had a vacancy in both the Grant Specialist and Program Director positions. These roles carry duties to includes design and oversight of the internal control environment regarding the compliance of the federal program. As of August 2022, both vacant positions have been appointed to provide oversight for program compliance. To mitigate deficiencies in controls regarding change management, personnel status change forms involving federally funded programs will be circulated to the Program Director, Grant Specialist, and Business Affairs office. The University will implement the auditors? recommendation to invest in a documentation and approval system for credentials and allowable costs. The Program Director will also perform routine maintenance over personnel files and required documentation.
Finding 35184 (2022-001)
Significant Deficiency 2022
Federal Program Department of Education - Strengthening Institutions Program, ALN 84.031A, Award No. P031A190172, Period 10/1/19 - 9/30/24 Condition/Cause During the year ended June 30, 2022, an individual working in an allowable position under the grant changed job titles to a different position, ...
Federal Program Department of Education - Strengthening Institutions Program, ALN 84.031A, Award No. P031A190172, Period 10/1/19 - 9/30/24 Condition/Cause During the year ended June 30, 2022, an individual working in an allowable position under the grant changed job titles to a different position, which was not allowable under the grant. The wages and fringe benefits for this individual continued to be charged to the grant after the change in position. Internal controls in place did not detect the unallowable costs charged to the grant in the 4th quarter of the fiscal year, prior to drawing down funds. Recommendation We recommend that the University revisit and strengthen internal controls over determining compliance with the allowable activities and allowable cost requirements of the grant for wages and fringe benefits. Management Response We agree with the auditors' finding. The instance of non-compliance occurred during a period when the University had a vacancy in the Grant Specialist position. This role?s duty includes oversight of the internal control environment regarding the compliance of the federal program. Effective August 2022, the position has been filled and corrective actions are in process to strengthen internal controls to avoid non-compliance going forward. To mitigate deficiencies in controls regarding change management, personnel status change forms involving federally funded programs will be circulated to the Program Director, Grant Specialist, and Business Affairs office. In addition, the Program Director will reconcile funds disbursed for unallowable costs prior to the filing of the September 30, 2023 annual report.
Finding 35165 (2022-004)
Significant Deficiency 2022
Name of Contact Person: Alyssa McDermott Corrective Action Plan: In the past year, the City has worked to develop an updated set of policies and procedures for the CDBG program and has engaged in substantial Environmental Review training. For all Environmental Reviews that are Exempt or Categorical...
Name of Contact Person: Alyssa McDermott Corrective Action Plan: In the past year, the City has worked to develop an updated set of policies and procedures for the CDBG program and has engaged in substantial Environmental Review training. For all Environmental Reviews that are Exempt or Categorically Excluded Not Subject to Section 58.5, no Request for Release of Funds is necessary. For Environmental Reviews that are Categorically Excluded, Subject to Section 58.5, the review is conducted to determine if there are any circumstances which require compliance with any of the federal laws and authorities cited at ?58.5. If not, funds may be committed and drawn down without the need to submit a Request for Release of Funds. In the event that a project is Categorically Excluded, Subject to Section 58.5, and there are circumstances which require compliance with one or more federal laws and authorities cited at ?58.5, the City completes all required consultation and mitigation protocol requirements, publishes the Notice of Intent to Request Release of Funds, and obtains the required ?Authority to Use Grant Funds? (HUD 7015.16) per Section 58.70 and 58.71 before committing or drawing down any funds. Similarly, all Environmental Assessments are subject to the RROF process, based on whether there is a Finding of No Significant Impact or a Finding of Significant Impact. City staff is following all specific requirements of 24 CFR Part 58. Proposed Completion Date: 6/30/23
Finding 2022-002 Contact Person Responsible for Corrective Action: Darrin Boas, Clerk-Treasurer Contact Phone 812 522 4020 View of Responsible Official: We concur with the findings. While I concur that no one reviewed this document prior to submission, and I input and submitted the data, much of thi...
Finding 2022-002 Contact Person Responsible for Corrective Action: Darrin Boas, Clerk-Treasurer Contact Phone 812 522 4020 View of Responsible Official: We concur with the findings. While I concur that no one reviewed this document prior to submission, and I input and submitted the data, much of this report is auto populated by the website. My responsibility was to confirm the data, respond if we are using the Standard Allowance, and a brief description of our plan to distribute. Moving forward, all US Treasury reports will be reviewed by either the Mayor or 2nd Deputy, and signed off on once submitted by the Clerk/Treasurer. A copy will be maintained with initials/signatures in the Treasury File in the Clerk/Treasure?s office. Anticipated Completion Date 7/2023
Finding # 2022-003 Response South Lyon Medical Center received the provider relief funds in May 2020. Immediately after award, and using HRSA?s authorized usage of the funds, Administration reviewed weaknesses in the facility needed to mitigate the COVID19 pandemic. After due diligence and several...
Finding # 2022-003 Response South Lyon Medical Center received the provider relief funds in May 2020. Immediately after award, and using HRSA?s authorized usage of the funds, Administration reviewed weaknesses in the facility needed to mitigate the COVID19 pandemic. After due diligence and several meetings on the funding guidelines, SLMC determined the greatest benefit to the community and patients was to upgrade the original HVAC system in its 1963 skilled nursing facility as the most effective way for SLMC to prevent, prepare for, and respond to coronavirus. The facility?s architect/engineer was immediately tasked with the creation of a feasibility report and design plans to perform the needed upgrades, removing the 1963 antiquated system and replacing it with a modern efficient system and the process of finding a contractor to complete the project. In October 2020, plans were completed and submitted to contractors in the surrounding area in pursuit of a proposal. The project was awarded to Miles Construction in March 2021 and a contract was signed on May 5th, 2021. HVAC projects at hospitals require a significant amount of time to plan, design, and build under normal circumstances, even before taking into consideration complications added by the pandemic, which included contractor shortages, labor availability issues, and supply chain issues. These obstacles are much more pronounced in rural areas. There were additional delays in receiving State approval due to the increased number of projects submitted for review to the state during this period. The Medical Center committed funds to the project and entered into the contract in good faith, using the guidance available at the time of the commitment. The project was part of the Medical Center?s initiative to prevent, prepare for, and respond to coronavirus and, accordingly, the Provider Relief Fund grants were used to help fund the initiative. The FAQs available at the time the contract was executed did not include a requirement that the capital project be fully complete by the end of the Period of Availability to be an allowable use of the funds. This requirement was added on August 30, 2021, which is two months after the end of the period 1 Period of Availability, June 30, 2021. Responsible Party David Bezard, CFO South Lyon Health Center, Inc. Estimated Completion The Project was completed and put into service in September 2022 after the Fire Marshall?s final inspection and the Contractor/Architect signed off on the project?s completion.
View Audit 32577 Questioned Costs: $1
Corrective Action Plan Responsible Official: Iman Riddick, Registrar and T.J. Snowden, Director of Financial Aid Anticipated Completion Date: Dec 15, 2022 Finding 2022-001: Enrollment Reporting and Documentation of Controls Views of Responsible Officials and Planned Corrective Action: Management ...
Corrective Action Plan Responsible Official: Iman Riddick, Registrar and T.J. Snowden, Director of Financial Aid Anticipated Completion Date: Dec 15, 2022 Finding 2022-001: Enrollment Reporting and Documentation of Controls Views of Responsible Officials and Planned Corrective Action: Management agrees with the recommended corrective action for which the Institute immediately began to remediate. This relates to the National Student Loan Data System (NSLDS) site modernization resulting in NSLDS functionality/operational pauses that included the data flow from National Student Clearinghouse (NSC) to NSLDS. This issue has been resolved. The Institute has established a procedure to ensure this does not happen again. It should also be noted that as of December 2022, the Director of Financial Aid and Registrar have implemented procedures and controls to ensure that all required reporting to the NSLDS is performed accurately and in a timely manner. Each month?s enrollment data submission to National Student Clearinghouse by the Registrar will be reviewed by the Director of Financial Aid to verify the consistency of the data in NSLDS; The Director of Admissions and the Registrar will review submission of the 10 business days after the original submission and on the 14th of each month prior to the submission of the next batch of enrollment data to the National Student Clearinghouse. This will allow IWP to correct any inaccurate reporting and verify timely submissions to both systems, providing a preventive control in addition to the resolution of the NSLDS functionality pause.
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