Corrective Action Plans

Finding 525573 (2024-003)

Significant Deficiency 2024

NV

Cash Management

Staff will compare all bank account reconcilations against the total compostion of all cash accounts maintained within the general ledger's individual funds.

View Audit 344670

Finding 525554 (2024-001)

Significant Deficiency 2024

Bethany College

KS

Student Financial Aid Cash Management Subrecipient Monitoring

Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: Febru...

Corrective Action Plan 2024-001: The College concurs with the finding and has adjusted its processes and controls beginning with the Spring 2024 semester to conduct a review of students for which refund payments need to be made prior to drawing down funds from G5. Anticipated Completion Date: February 2024 Contact Person: Steven W. Eckman, President

View Audit 344637

Finding 525520 (2024-001)

Material Weakness 2024

Cleveland Municipal School District

OH

Cash Management Reporting Internal Control / Segregation of Duties

The Ohio Department of Education and Workforce audited the Nutrition Department last school year and found the same inconsistencies in its accounting and claiming practices. For this reason, we implemented a new point of sale (POS) system in all schools during the summer of 2024. Implementing the PO...

The Ohio Department of Education and Workforce audited the Nutrition Department last school year and found the same inconsistencies in its accounting and claiming practices. For this reason, we implemented a new point of sale (POS) system in all schools during the summer of 2024. Implementing the POS system will eliminate human errors in our paper-tracking meal-claiming practices. With the new POS system, the cashier presses a “meal” key when students receive a reimbursable meal. Doing so automatically tallies the day's meal counts for breakfast and lunch. The POS system will "flag" schools that have over claimed their enrollment. This flagging system is the same system that is on the CRRS site that the state uses. The new POS can also generate monthly CN-6 & 7 forms, which automatically add up the school's monthly breakfast and lunch counts and are used to file meal reimbursement in CRRS. Daily the managers check their end of day reports to make sure the meals were accounted for properly and not over claimed. At the end of the month our accounting team also checks the meal counts for accuracy before the numbers are entered into CRRS.

View Audit 344601

Finding 525508 (2024-005)

Significant Deficiency 2024

Maywood-Melrose Park-Broadview School District 89

IL

Questioned Costs Cash Management Eligibility § 200.402

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS22 Year Ending June 30, 2024 Corrective Action Plan Finding No.: 2024- 005 Condition: It was noted during the audit that ineligible expenditures were charged to...

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS22 Year Ending June 30, 2024 Corrective Action Plan Finding No.: 2024- 005 Condition: It was noted during the audit that ineligible expenditures were charged to the food service expenditure function. These expenditures were for a back-to-school picnic and consisted of backpacks with school supplies that were provided to students. These expenditures should not have been charged to the food service function in the District’s general ledger system. Plan: The district is reviewing all expenditures monthly to ensure all of them are recorded with the proper account code. Any changes needed will get a journal entry through the Proviso Treasurer’s Office. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Scott Wold, Business Manager

View Audit 344578

Finding 525499 (2024-006)

Material Weakness 2024

Maywood-Melrose Park-Broadview School District 89

IL

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.402 § 200.408

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2024 Corrective Action Plan Finding No.: 2024- 006 Condition: Audit procedures identified that the District claimed $2,097,350 of expendit...

Maywood-Melrose Park-Broadview School District 89 06-016-0890-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2024 Corrective Action Plan Finding No.: 2024- 006 Condition: Audit procedures identified that the District claimed $2,097,350 of expenditures on their June 30, 2024 reimbursement claim submitted to the Illinois State Board of Education, however these expenditures were not received and paid by the District until July/August 2024. Plan: The district performs a review of supporting documentation for expenditures claimed during a reimbursement request to ensure that expenditures claimed for reimbursement occurred during the fiscal year for which they are being claimed. Anticipated Date of Completion: June 30, 2025 Name of Contact Person: Scott Wold, Business Manager

View Audit 344578

Finding 525297 (2024-001)

Significant Deficiency 2024

Gilbert Unified School District No. 41

AZ

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties § 200.303 § 200.510

Finding Number: 2024‐001 Program Name/Assistance Listing Titles: Emergency Connectivity Fund; Education Stabilization Fund Assistance Listing Numbers: 32.009; 84.425 Contact Person: Jackie Mattinen, Director of Finance Anticipated Completion Date: February 28, 2025 Planned Corrective Action: The Gil...

Finding Number: 2024‐001 Program Name/Assistance Listing Titles: Emergency Connectivity Fund; Education Stabilization Fund Assistance Listing Numbers: 32.009; 84.425 Contact Person: Jackie Mattinen, Director of Finance Anticipated Completion Date: February 28, 2025 Planned Corrective Action: The Gilbert Public Schools Finance Department will provide financial oversight of all State and Federal fund applications and will require finance approval prior to submittal of all State and Federal fund applications initiated by all District departments and schools.

View Audit 344525 Questioned Costs: $1

Finding 525260 (2024-002)

Significant Deficiency 2024

Accessible Country Trail, Inc. 042-Hd033

OH

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. Explanation of disagreement with audit ...

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of deposit changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Management will make the required deposit immediately. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director Planned completion date for corrective action plan: June 30, 2025

View Audit 344482

Finding 525258 (2024-003)

Significant Deficiency 2024

Accessible Country Trail Ii, Inc./ Swan Creek Apts 042-Hd055

OH

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of surplus cash deposits. Explanation of disagreement with ...

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of surplus cash deposits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director

View Audit 344480

Finding 525256 (2024-002)

Significant Deficiency 2024

Accessible Country Trail Ii, Inc./ Swan Creek Apts 042-Hd055

OH

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of surplus cash deposits. Explanation of disagreement with ...

Supportive Housing for Persons with Disabilities – Assistance Listing No. 14.181 Recommendation: Perform training regarding HUD requirements surrounding Residual Receipts Provisions and introduce policies and procedures to prevent oversight of surplus cash deposits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management with conduct training and introduce new policies and procedures to prevent noncompliance. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wilson, Executive Director

View Audit 344480

Finding 525249 (2024-001)

Significant Deficiency 2024

American Baptist Theological Seminary

TN

Cash Management § 200.305

Management agrees with the finding and recommendation. A process will be put in place to ensure the cash drawn down will be expended within the 30 day timeframe. The Controller will prepare the analysis and the CFO will approve as a part of the month end closing process.

View Audit 344463

Finding 525200 (2024-004)

Material Weakness 2024

Mac, Inc.

MD

Cash Management Material Weakness Reporting

Checklist for completing quarterly reports will be developed by the Grants Managaer and implemented to ensure all quarterly reports for federal and state grants are completed within 15 days following the end of the quarter. Checklist will be given to the Financial Administrator for review on day 16 ...

Checklist for completing quarterly reports will be developed by the Grants Managaer and implemented to ensure all quarterly reports for federal and state grants are completed within 15 days following the end of the quarter. Checklist will be given to the Financial Administrator for review on day 16 following the end of the quarter. Financial Administrator will email confirmation of completion to CEO.

View Audit 344426

Finding 525196 (2024-002)

None 2024

Heart of Oregon Corps, Inc.

OR

Allowable Costs / Cost Principles Questioned Costs Procurement, Suspension & Debarment

Corrective Action: During a period of staff transition in a Program Director role, travel was arranged for a group on a grant-approved training trip, which included several program participants. When the airline tickets were purchased, one participant whose activities and enrollment were part of a ...

Corrective Action: During a period of staff transition in a Program Director role, travel was arranged for a group on a grant-approved training trip, which included several program participants. When the airline tickets were purchased, one participant whose activities and enrollment were part of a different funding source within the same overall program was mistakenly included in this group. This oversight was not caught by program staff at the time, and the member participated in the trip. The issue was identified during the audit, promptly corrected by staff, and the grant funder was refunded for the expense in January 2025, prior to the audit’s completion. Additionally, the process for vetting participants for such trips has been revised to include regular reviews of enrollment status, both at the time of airfare purchase, but also at the time of travel. Program staff will more regularly and actively provide fiscal staff current enrollment information, which will be cross-referenced during both the AP and cost allocation entry, and during the reimbursement A/R invoicing process, to ensure cost allowability. Anticipated Completion Date February 2025

View Audit 344410

Finding 525189 (2024-001)

Material Weakness 2024

Child & Family Services of Northwestern Michigan, Inc.

MI

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.403

Management's Response: The Organization acknowledges the finding and agrees with the auditors' recommendations. We recognize the importance of maintaining accurate documentation and financial controls to ensure compliance with federal regulations. To address the finding, the Organization will implem...

Management's Response: The Organization acknowledges the finding and agrees with the auditors' recommendations. We recognize the importance of maintaining accurate documentation and financial controls to ensure compliance with federal regulations. To address the finding, the Organization will implement the following corrective actions: 1) Journalizing administrative allocations - effective March 31, the Organization will implement a procedure to allocate administrative costs to each applicable federal award program through monthly journal entries within the general ledger. 2) Improved documentation retention - the Organization will establish a process to retain supporting documentation for all costs submitted for reimbursement, ensuring alignment between the general ledger and reimbursement requests. 3) Internal controls for expense classification - the Organization will implement additional controls to prevent expenses from being reclassified within the general ledger after reimbursement requests have been submitted. Any necessary adjustments will be documented with a clear audit trail. These corrective actions will be fully implemented by March 31, 2025, will include and cover all such costs from the start of the fiscal year which began October 1, 2024, and management will monitor compliance to ensure ongoing adherence to these procedures.

View Audit 344405

Finding 525017 (2024-001)

Significant Deficiency 2024

Brenda Thibeault

CT

Cash Management Reporting

After the former finance director completed the federal webinars on the guidelines for requesting funds through the Payment Management System and submitting Federal Financial Reports, it was identified and disclosed to the auditors that draw down procedures had not been in compliance. SAMHSA was no...

After the former finance director completed the federal webinars on the guidelines for requesting funds through the Payment Management System and submitting Federal Financial Reports, it was identified and disclosed to the auditors that draw down procedures had not been in compliance. SAMHSA was notified and accounts were reconciled with the return of unspent funds. All drawdowns are currently only occurring when funds are expended. Current finance personnel are trained and have extensive experience in federal reporting guidelines.

View Audit 344334

Finding 524952 (2024-001)

Material Weakness 2024

Queen Anne's County, Maryland

MD

Allowable Costs / Cost Principles Questioned Costs Cash Management § 200.303

Recommendation: We recommend all reimbursements and payments be reviewed in detail to ensure no payments are funding unallowable costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Going forward, the county w...

Recommendation: We recommend all reimbursements and payments be reviewed in detail to ensure no payments are funding unallowable costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Going forward, the county will implement a more thorough review process for expenditures that were initially paid by a separate entity and subsequently reimbursed by us, ensuring all such transactions are properly documented and compliant with grant guidelines. Name of contact person responsible for corrective action: Jeffrey Rank, Director, Office of Budget & Finance Planned completion date for corrective action plan: February 28, 2025

View Audit 344295

Finding 524858 (2024-001)

Significant Deficiency 2024

High Point University

NC

Cash Management Internal Control / Segregation of Duties Questioned Costs

Finding 2024-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely mann...

Finding 2024-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. University’s Response: The University has continued to ensure these funds are not comingled and has protected them from spending. Because of the discrepancies identified, each student’s loan history had to be reviewed and compared between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation have proven to be a tedious but necessary process to identify the funds never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: The University, working with an external financial aid consulting firm with experience in reconciling FFEL loan programs, has finished researching all related accounts against the National Student Loan Database System (NSLDS) records. Our next steps include consolidating student returns to each of the different lenders, working with the Department of Education to determine how to return funds in instances where the last lender used is no longer available to process student loan funds, and lastly, book the appropriate entries for any funds determined to belong to the University that were not moved to the University operating accounts properly at the time of the transactions. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services Anticipated Completion Date: May 31, 2025

View Audit 344215

Finding 524754 (2024-003)

Material Weakness 2024

Resources for Human Development, INC

PA

Cash Management Questioned Costs Material Weakness § 200.302

Management reviewed the process and determined that the error was self-identified and the necessary step were taken to be corrected by the fiscal year-end June 30, 2024. Management will further review the procedures that are in place to track available contract funding balances and implement adjustm...

Management reviewed the process and determined that the error was self-identified and the necessary step were taken to be corrected by the fiscal year-end June 30, 2024. Management will further review the procedures that are in place to track available contract funding balances and implement adjustments in order to allow for the prevention, or timely detection and correction of, errors in federal draw-down requests. This will be completed by June 30, 2025.

View Audit 344160

Finding 524706 (2024-002)

Significant Deficiency 2024

Housing and Redevelopment Authority of Austin

MN

Cash Management Internal Control / Segregation of Duties Questioned Costs

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Complia...

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Recommendation: We recommend that the HRA continue to evaluate their procedures and controls in place over the draw down of funds. Management’s Response: Management agrees with the finding and will continue to monitor the draws to ensure they are spent within the required timeframe. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will ensure that all draws of funds are spent within the required timeframe. Official Responsible for Ensuring CAP: Angela Maiden, Finance Director, is the official responsible for ensuring corrective action of the deficiency. Planned Completion Date for CAP: September 30, 2025 Plan to Monitor Completion of CAP: Taggert Medgaarden, Executive Director, will ensure that the draw downs are properly managed through discussions with the Finance Director.

View Audit 344136 Questioned Costs: $1

Finding 524639 (2024-003)

None 2024

Eureka College

IL

Questioned Costs Student Financial Aid Cash Management

2024-003 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-003 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: Three of the 40 student files (7.5%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003. Management Response: Management agrees with the finding Corrective Action Plan: Loan calculations are automatic as part of JFA. Any manual changes to these loan amounts will be documented on the student file to justify differing amounts. Responsible Person: Tim Marten Implementation Date: 7/01/2024

View Audit 344088 Questioned Costs: $1

Finding 524636 (2024-001)

Significant Deficiency 2024

Eureka College

IL

Questioned Costs Student Financial Aid Cash Management

2024-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b)84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: During our testing of thirty-seven draw downs, we noted 4 individuals (11%) that resulted in having cash on hand that exceeded the immediate disbursement need for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency relating to the Cash Management compliance requirement. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: Implementation of a newer process based on the system and program defaults in Jenzabar Financial Aid (JFA). Will use posted dates in Sonis to ensure they match COD within the 3-day regulatory requirement. New reporting usages of SAS loan files will be checked in Sonis to ensure matching disbursement dates. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088 Questioned Costs: $1

Finding 524629 (2024-003)

Significant Deficiency 2024

Keystone College

PA

Questioned Costs Subrecipient Monitoring Cash Management

Management will review the FY 24 FISAP report concerning the accuracy of the SEOG drawdown and whether any portion of the drawdown should have been reported as carryover funds. Any overdraw determined as part of this reconciliation will be returned to the U.S. Department of Education. The College ...

Management will review the FY 24 FISAP report concerning the accuracy of the SEOG drawdown and whether any portion of the drawdown should have been reported as carryover funds. Any overdraw determined as part of this reconciliation will be returned to the U.S. Department of Education. The College has also strengthened controls and trained staff to ensure compliance with cash management practices for future federal awards.

View Audit 344059 Questioned Costs: $1

Finding 524616 (2024-004)

Significant Deficiency 2024

Marymount University

VA

Subrecipient Monitoring Cash Management § 200.305

Research and Development Cluster – Assistance Listing Numbers 47.070, 47.076, 47.084, and 93.846 Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and per...

Research and Development Cluster – Assistance Listing Numbers 47.070, 47.076, 47.084, and 93.846 Recommendation: We recommend the University review its internal controls around the reimbursement process for all federal grants to ensure the necessary review and approval controls are in place and performed by an individual other than the one performing the drawdown calculation and request from the federal agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Midway through the fiscal year, we introduced a new process involving multiple layers of approval before a drawdown is executed. The drawdown calculation is done either by the Senior Accountant or Grant Manager and sent to either the Grant Manager (if prepared by the Senior Accountant), or Controller (if prepared by the Grant Manager) for review and approval. If additional information is needed, the approver sends the request back for updating and recalculation. Name(s) of the contact person(s) responsible for corrective action: Mutale Sokoni, Associate Vice President for Finance, 703-284-1496 Planned completion date for corrective action plan: Action taken during April 2024

View Audit 344056

Finding 524604 (2024-008)

Significant Deficiency 2024

Vance County

NC

Questioned Costs Cash Management Eligibility

Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-008 Name of contact person: Stephanie Williams, Budget and Finance Director Corrective Action: Proposed Completion Date: May-25 Corrective Action Plan for Finding 2024-004, 2024-005, 2024-006, and 2024-007 also apply to State Award...

Corrective Action Plan For the Year Ended June 30, 2024 Finding 2024-008 Name of contact person: Stephanie Williams, Budget and Finance Director Corrective Action: Proposed Completion Date: May-25 Corrective Action Plan for Finding 2024-004, 2024-005, 2024-006, and 2024-007 also apply to State Awards findings. The County Manager has instituted a Grant approval process so that she, Department Heads, Offices and the Finance Department are aware of grants prior to receipt or spending of them. This process will allow time for receipt, BoCC approval, if necessary, and to be coded and tracked separately from the General Fund. Section IV - State Award Findings and Question Costs 146

View Audit 344037

Finding 524564 (2024-001)

Significant Deficiency 2024

The Chicago School-Cal INC Dba the Chicago Sch of Pro Psychology

IL

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federa...

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $528,450 to $1,238,306, from November 13, 2023, to December 18, 2023. While the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the amounts were not returned within the seven-day period as required. Summary: The College draws a portion of funds for student stipends while award reconciliation is in progress to ensure timely disbursement. An administrative oversight led to excess cash being held longer than allowed. Specifically, the prior stipend drawdown was not netted out when calculating subsequent fund requests, resulting in excess cash being held for 24 business days. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure compliance with the seven-day return requirement. 2. Process Change: Going forward, the College will refrain from drawing funds for student stipends until reconciliations have been fully completed. This will ensure that funds are drawn in alignment with actual disbursement needs, reducing the risk of excess cash. 3. Internal Control Strengthening: The College will enhance internal controls around cash management to ensure that excess cash instances are identified and corrected promptly. 4. Staff Training: All relevant staff will undergo training on revised cash management procedures and the importance of timely reconciliation and returns. 5. Improved Monitoring: The College will implement a more robust monitoring process to track excess cash and ensure compliance with Federal regulations, including daily checks during peak disbursement periods. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343996

Finding 524562 (2024-001)

Significant Deficiency 2024

Pacific Oaks Education Corporation

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title...

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $1,335,590 to $4,774,182, from September 6, 2023, to September 13, 2023. The excess cash exceeded the one-percent tolerance of prior year drawdowns, and the funds were not posted to students' ledgers within the three-business-day period as required. Summary: The College draws a portion of funds early to ensure the timely disbursement of stipends to students, while the reconciliation process is still underway. However, the funds were not posted to students’ ledgers within the required three days, leading to a violation of the federal cash management requirements. The issue was related to administrative oversight in the processing of the drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure funds are posted to students’ ledgers within the three-business-day requirement. 2. Process Change: The College will refrain from drawing funds early to cover stipends until all necessary reconciliations are completed, ensuring compliance with the required disbursement timeline. 3. Internal Control Strengthening: The College will strengthen internal controls by implementing more rigorous checks to ensure timely posting of funds to students' accounts after drawdowns. 4. Staff Training: Relevant staff members will undergo training on the updated procedures and the importance of timely posting of funds to student ledgers. 5. Improved Monitoring: The College will institute enhanced monitoring and tracking of funds after drawdowns to ensure that the required posting timeframe is consistently met. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343993

Corrective Action Plans

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