Corrective Action Plans

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Timeline: Recommendations should begin within 30 days of the audit report’s issuance.
Timeline: Recommendations should begin within 30 days of the audit report’s issuance.
Resources: Online HUD accounting Webinars or Self Study classes. Example AICPA, AHACPA, or Wester CPE
Resources: Online HUD accounting Webinars or Self Study classes. Example AICPA, AHACPA, or Wester CPE
Corrective Action Plan
Corrective Action Plan
Action: Management needs to monitor and review the processing of monthly financial statements to detect any errors in recording transactions. Further management needs to monitor and review on a monthly basis the processing of bank reconciliations. To Provide Mandatory training to accounting personne...
Action: Management needs to monitor and review the processing of monthly financial statements to detect any errors in recording transactions. Further management needs to monitor and review on a monthly basis the processing of bank reconciliations. To Provide Mandatory training to accounting personnel on certain accounting principles regarding HUD Multifamily Housing. This includes taking accounting continuing education classes in accounting for HUD Projects. Create an Internal Auditing function within the Management company.
Responsibility: The Accounting Manager is responsible for providing the training and assigning certain accounting classes that can be done online.
Responsibility: The Accounting Manager is responsible for providing the training and assigning certain accounting classes that can be done online.
Timeline: Training to begin within 30 days of the audit report’s issuance.
Timeline: Training to begin within 30 days of the audit report’s issuance.
Resources: Online HUD accounting Webinars or Self Study classes. Example AICPA, AHACPA, or Wester CPE
Resources: Online HUD accounting Webinars or Self Study classes. Example AICPA, AHACPA, or Wester CPE
Management has already instituted some actions to address the findings through hiring new
Management has already instituted some actions to address the findings through hiring new
accounting personnel including hiring a Accounting manager and also beefed up its IT functions
accounting personnel including hiring a Accounting manager and also beefed up its IT functions
by installing a new accounting system. Both the Accounting manager and the consultant have been monitoring activities on a frequent basis and providing IT support.
by installing a new accounting system. Both the Accounting manager and the consultant have been monitoring activities on a frequent basis and providing IT support.
Corrective Action Plan 2025-001: We acknowledge the overaward of Direct Subsidized Loans and underaward of Unsubsidized Loans for both students identified in the finding. Based on the guidance in Volume 8, Chapter 3 of the 2024-2025 Federal Student Aid Handbook which states “If you discover that a s...
Corrective Action Plan 2025-001: We acknowledge the overaward of Direct Subsidized Loans and underaward of Unsubsidized Loans for both students identified in the finding. Based on the guidance in Volume 8, Chapter 3 of the 2024-2025 Federal Student Aid Handbook which states “If you discover that a student received Direct Subsidized Loan funds in excess of financial need after the student is no longer enrolled for the loan period, you are not required to take any action to eliminate the excess subsidized loan amount.” We have not adjusted the student’s loan awards given the identification of the overaward took place after the end of the loan period for each student. As the University has closed after August 15, 2025, no additional actions are considered necessary. Completion Date: August 2025 Contact Person: Ann Spall, Chief Financial Officer
Finding 1174308 (2025-001)
Material Weakness 2025
Responsible Parties: Janet Payne, Human Services Director Ashley Lantz, Department of Social Services Director Finding 2025-001, Medicaid Program - Significant Deficiency-Eligibility Response/Corrective Action: Findings: During the FY26 Single Audit of Medicaid, it was determined that the Union Coun...
Responsible Parties: Janet Payne, Human Services Director Ashley Lantz, Department of Social Services Director Finding 2025-001, Medicaid Program - Significant Deficiency-Eligibility Response/Corrective Action: Findings: During the FY26 Single Audit of Medicaid, it was determined that the Union County Medicaid program has deficiencies in the areas of oversight, income and deduction calculations, self employment income, self attestation, and internal controls related to 2nd party review corrections. Root Cause: It has been determined that staffing issues as well as deficiencies in training, due to vacancies on the training team, and lack of supervisor oversight due to span of control contributed to these deficiencies. Corrective Action: Due the the preliminary findings of the Single Audit, Union County Medicaid has already begun working on corrective actions. We have completed the following actions: • When an error is determined on an internal or external 2nd party review, the worker has 2 days to complete the correction. Once corrections are completed, the worker is to notify the supervisor that it has been completed. Supervisors are given 2 days to review the corrections. This is being added to our 2nd party review sheet for tracking effective 2/1. Initial tracking will be available once all February 2nd party reviews are completed. • Updates to our training are currently in progress for both new and seasoned staff. We anticipate these updates to be completed mid-February 2026 with training being completed by May 31, 2026 with all Medicaid staff. • Division Manager began monthly meetings with Medicaid leadership in November 2025. Monthly meetings focus on previous month’s 2nd party review findings and training needs as a way to ensure ongoing training needs are properly addressed. Corrective action currently in process includes the following: • Training on audit findings will be conducted by May 31, 2026. Pre and post assessments will be given to determine effectiveness of training. All staff will sign a statement of attendance and understanding upon the completion of trainings. Training topics will include income, self-employment income and deductions, self attestation, notices, and proper documentation. • Continuing education training will be completed monthly. Trainings will vary from month to month and will focus on common errors found in 2nd party reviews. Sessions will be conducted in small groups to allow better communication and more one on one time between the trainers and staff. Continuing education training will begin by May 31, 2026. • - Supervisors will continue to conduct 2nd party reviews to assess comprehension and adherance to Medicaid policy. Each month, beginning March 2026, Division Manager will receive a report from CQI to ensure that the 2 day correction and review mandate is being adhered to. It is important to note that the Medicaid Program Manager position is now vacant. The position will be filled as quickly as possible, and the Division Manager is currently taking over all roles of the Program Manager. Union County will implement the Corrective Action Plan by June 30, 2026.
Finding 2025-001 Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant Program, Assistance Listing 84.063 Criteria: The College must comply with 34 CFR 690.83 and 34 Section 685.301(a)(2). Condition: We tested 40 samples for eligibility, and noted that 12 o...
Finding 2025-001 Federal Program: U.S. Department of Education: Student Financial Aid Cluster: Federal Pell Grant Program, Assistance Listing 84.063 Criteria: The College must comply with 34 CFR 690.83 and 34 Section 685.301(a)(2). Condition: We tested 40 samples for eligibility, and noted that 12 of the samples had reporting errors related to the disbursement dates to Common Origination and Disbursement (COD). 11 of the errors related to Pell disbursements and one related to a disbursement of a direct loan. Cause: The College did not have a procedure in place to properly review COD disbursement amounts and dates to verify all students had the proper reporting in COD. Effect: The provisions of 34 CFR Section 690.83 and 34 Section 685.301(a)(2), were not followed and thus 11 students had incorrect reporting of one day in COD related to Pell disbursements and one student had incorrect reporting of 8 days related to a Direct Loan disbursement. Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date matches the student account. Views of responsible officials and planned corrective actions: The Director of Financial Aid will review and verify the funds that were disbursed to the students’ account match the disbursement dates in COD on the date the transfer batch report is sent to the College’s Business Office by pulling a reconciliation file from COD. The Director of Financial Aid also has in place to pull students who need Pell or Direct Loans to be disbursed by running a report out of CAMS instead of running a selection set in Powerfaids. Monthly reconciliations for both fund types will be completed every 30 days. Completion date: 2/10/2026. Responsible staff: Crystal Benton, Director of Financial Aid
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance wi...
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance with the requirements of the HUD Handbook4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. FG Companies has also implemented a bi-weekly file audit system that will continue to be completed by the Regional Manager. This system is to ensure all files are current with certifications and all required state and local forms are completed and filed accordingly.
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance wi...
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance with the requirements of the HUD Handbook4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. FG Companies has also implemented a bi-weekly file audit system that will continue to be completed by the Regional Manager. This system is to ensure all files are current with certifications and all required state and local forms are completed and filed accordingly.
Management agrees with the findings and has implemented the policies below and will continue to train and connect our team members with the in-house HUD Compliance Specialist for support. 1. Move in EIV’s – All move in files will be sent to our in-house compliance department and Franklin Group have ...
Management agrees with the findings and has implemented the policies below and will continue to train and connect our team members with the in-house HUD Compliance Specialist for support. 1. Move in EIV’s – All move in files will be sent to our in-house compliance department and Franklin Group have an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90-day reminders for all move in. 2. Existing Tenant EIV – It is the policy that all existing tenant EIV & 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The Regional Manager is required during monthly visits to spot check at least 5 existing tenants.
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance wi...
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance with the requirements of the HUD Handbook4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. FG Companies has also implemented a bi-weekly file audit system that will continue to be completed by the Regional Manager. This system is to ensure all files are current with certifications and all required state and local forms are completed and filed accordingly.
The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.
The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.
Finding 2025-002 - Eligibility - Student Financial Assistance Cluster, ALN 84.268, June 30, 2025 Award Year, U.S. Department of Education Condition Calculation of Benefits: In addition to the requirements and limits, awards must be coordinated among the various programs and with other federal and no...
Finding 2025-002 - Eligibility - Student Financial Assistance Cluster, ALN 84.268, June 30, 2025 Award Year, U.S. Department of Education Condition Calculation of Benefits: In addition to the requirements and limits, awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). The determination of need-based SFA award amounts is based on financial need. Non-need based SFA awards are not limited to financial need but cannot exceed the student’s COA. To determine non-need based SFA awards (unsubsidized aid) one would use the following formula – COA minus OFA. (November 2025 OMB Compliance Supplement pages 5-3-10 and 5-3-11) Out of forty students tested, two students were under-awarded both Subsidized and Unsubsidized loans and one student was under-awarded Subsidized loans. This was not a statistic. Corrective Actions To address the finding, loan certification procedures have been revised to include step-by-step procedures for determining loan eligibility. A standardized template has been created for calculating subsidized and unsubsidized loan amounts, with clear instructions that subsidized loans must be maximized before awarding unsubsidized loans. Comprehensive training on the calculation of loan eligibility has been provided for new staff, including subsidized versus unsubsidized loan rules, and one-on-one coaching is being provided for staff members with knowledge gaps. A quality assurance program that includes a random sample review of loan awards will be performed between the fall and winter semesters to identify errors and ensure that loans are being certified in accordance with applicable rules and limits. Reviews and findings will be documented so that errors can be addressed immediately. Responsible Official: Wendy G. Glass, Director of Student Financial Services Completion Date: December 4, 2025
All Financial Aid personnel were re-trained on the SEOG minimum and maximum award parameters. The office will conduct quarterly reviews of awards to ensure compliance and verify that no students are incorrectly awarded.
All Financial Aid personnel were re-trained on the SEOG minimum and maximum award parameters. The office will conduct quarterly reviews of awards to ensure compliance and verify that no students are incorrectly awarded.
Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Cause: Within the University's student information system, PowerCampus, the degree verifier report was not cros...
Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Cause: Within the University's student information system, PowerCampus, the degree verifier report was not cross referenced with the graduation report. This student was on the degree verifier report but did not appear on graduation report, which is the report that is sent to the National Student Clearinghouse ("NSC") who then transmits information to NSLDS on behalf of the University. Condition: One student was excluded from the report used for the Clearinghouse as a graduated student. As they did not appear on the report twice, the Clearinghouse changed their status to withdrawn. The School then became aware of the change and the graduated status was transmitted to the clearinghouse on 2/7/25 and not received by NSLDS until 7/24/25. Criteria: The Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Corrective Action Plan to be Taken: After each graduation period the Registrar’s Office will compare the Degree Verify file against the Graduation Enrollment file as both files are uploaded to the National Student Clearinghouse. The Degree Verify file is generated and uploaded after the Graduation Enrollment file; this process of report comparison will allow us to capture any student not reported in the Graduation Enrollment file. Thereby ensuring all graduating students are reported correctly to the National Student Clearinghouse. We’ll begin this process, on October 3, 2025 with the August 2025 graduates as they were just reported to the National Student Clearinghouse this past month. Sincerely, Linda M. Arce Registrar
Corrective Action/Management Response: Ensuring that Adoption records are maintained accurately with all documented requirements. Changing Practice to include putting documents into the document management system (Traverse) in order to have a copy of required documents in the event originals are los...
Corrective Action/Management Response: Ensuring that Adoption records are maintained accurately with all documented requirements. Changing Practice to include putting documents into the document management system (Traverse) in order to have a copy of required documents in the event originals are lost, or documents are damaged due to flooding (which is what occurred in the basement where documents were housed). Cases that are more than 10 years old are typically going to be more difficult to locate needed items, due to records being maintained differently at that time and requirements were different in what the Department was required to maintain in an Adoption file. Proposed Completion Date: June 30, 2026 checking monthly to ensure paper files are scanned into Traverse.
2025-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan ...
2025-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need this student was eligible for $586 in Subsidized Loans and $2,914 in Unsubsidized Loans; however, the College awarded the student $549 in Subsidized loans and $2,951 in Unsubsidized loans which resulted in an under award of $37 in Subsidized Loans and an over award of $37 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Waubonsee will ensure to add the loan fees first to ensure sub-loans are calculated correctly. Responsible Person for Corrective Action Plan Mary Greenwood Implementation Date of Corrective Action Plan 12/9/2025
1. Immediate System Correction The clock-to-credit hour conversion file in Banner (GTVSDAX) was reviewed and updated to include all applicable course prefixes, including MAH and PSY. This correction ensured that clock-to-credit hour conversions were calculated accurately for affected technical progr...
1. Immediate System Correction The clock-to-credit hour conversion file in Banner (GTVSDAX) was reviewed and updated to include all applicable course prefixes, including MAH and PSY. This correction ensured that clock-to-credit hour conversions were calculated accurately for affected technical programs. 2. Identification and Review of Impacted Students Financial Aid reviewed all students enrolled in the affected term (202610) and identified those whose federal aid hours had been overstated due to the conversion omission. 3. Correction of Federal Aid Awards Federal aid awards were recalculated for impacted students. The engagement team noted, and the College confirms, that all affected students were enrolled in a current payment period for which funds had not yet been fully drawn, allowing corrections to be made timely. 4. Resolution of Financial Impact Where recalculations resulted in reduced eligibility, institutional need-based funds were applied to affected student accounts to prevent students from incurring balances due to an internal administrative error. This ensured students were not financially penalized for the control deficiency. Preventive Actions and Controls to Avoid Recurrence To address the identified control deficiency and strengthen internal controls over clock-to-credit hour conversions, the College has implemented the following preventive measures: 1. Enhanced Curriculum Oversight The Registrar (Tara Dumas) and Director of Financial Aid (Stacia Richerson) now serve as standing members of the Academic/Curriculum Review Committee. This ensures that Financial Aid and Registrar review all proposed curriculum changes, including: o New courses o New course prefixes o Courses designated as “in degree plan” for technical or clock-hour programs This review occurs prior to course approval and implementation, allowing clock-to-credit hour implications to be addressed in advance. 2. Formal Notification and Review Process Academic Affairs will notify Financial Aid of any curriculum changes that may impact clock-to-credit hour conversions. Financial Aid will review and update Banner conversion tables as needed before federal aid calculations occur. 3. Assigned Responsibility and Monitoring Responsibility for maintaining and reviewing clock-to-credit hour conversion tables has been formally assigned to the Director of Financial Aid (Stacia Richerson). o Conversion tables will be reviewed each semester prior to awarding federal aid. o Discrepancies in ROAENRL will be reviewed promptly to ensure accuracy. 4. Ongoing Compliance Review The College will perform periodic reviews of conversion logic and awarding calculations to ensure continued compliance with federal regulations and internal control standards under 2 CFR 200.303. Conclusion Reid State Technical College has corrected the clock-to-credit hour conversion issue, resolved the related questioned costs, and implemented strengthened internal controls. The addition of the Registrar (Tara Dumas) and Director of Financial Aid (Stacia Richerson) to the Academic/Curriculum Review Committee, combined with formalized review and notification procedures, provides reasonable assurance that clock-to-credit hour conversions will be accurately applied prior to federal aid calculation and disbursement.
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