Corrective Action Plans

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2025-001 Section 202 Capital Advance – Assistance Listing No. 14.157 Recommendation: Centennial Square should evaluate their financial reporting processes and controls, including the expertise of its internal staff, to determine whether additional controls over the preparation of annual financial st...
2025-001 Section 202 Capital Advance – Assistance Listing No. 14.157 Recommendation: Centennial Square should evaluate their financial reporting processes and controls, including the expertise of its internal staff, to determine whether additional controls over the preparation of annual financial statements can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will continue to rely on CliftonLarsonAllen to draft the financial statements and the related notes to the financial statements, and will review, approve, and accept responsibility for the annual financial statements prior to their issuance. Name(s) of the contact person(s) responsible for corrective action: Tammy Gjerde, Finance Director
Incorrect Pell Calculations Planned Corrective Action: The Office of Financial Aid will obtain enrollment reports for each term and session to ensure that Pell Grant eligibility is accurately determined and awarded to students based on their enrollment intensity. To address the system limitations id...
Incorrect Pell Calculations Planned Corrective Action: The Office of Financial Aid will obtain enrollment reports for each term and session to ensure that Pell Grant eligibility is accurately determined and awarded to students based on their enrollment intensity. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler Anticipated Date of Completion: June 30, 2026
Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will provide regular in-house R2T4 training specific to WBU for all financial aid staff. All financial aid staff responsible...
Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will provide regular in-house R2T4 training specific to WBU for all financial aid staff. All financial aid staff responsible for R2T4 will be required to complete pertinent training provided by FSA and purchased through NASFAA. In addition, financial aid staff responsible for R2T4 have established procedures to ensure the accurate and timely Return of Title IV Funds. To address the system limitations identified, the University has acquired a new Software-as-a-Service (SaaS) financial aid management system. Person Responsible for Corrective Action Plan: Executive Director of Financial Aid, Robert Hamilton, and Assistant Director of Compliance & Reporting, Brooke Tyler, and Assistant Director of Financial Aid, Alyssa Shealor Anticipated Date of Completion: June 30, 2026
Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No. 21.027 U.S. Department of Treasury Missouri Primary Care Association Criteria or specific requirement – Reporting (2 CFR 200.329) Condition – The Organization’s internal controls over compliance were not able to ensure progress...
Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No. 21.027 U.S. Department of Treasury Missouri Primary Care Association Criteria or specific requirement – Reporting (2 CFR 200.329) Condition – The Organization’s internal controls over compliance were not able to ensure progress reporting required to be submitted to the pass-through entity was completed timely. Cause – The Organization’s internal controls over compliance did not ensure all grant reporting requirements were completed timely. Effect or potential effect – The Organization did not submit the required quarterly and annual performance reports in a timely manner. Questioned costs – None Context – The Organization is required to submit quarterly status reports and an annual performance report to the pass-through entity in a timely manner. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – The Organization should consider implementing a grant reporting calendar for all grants with reporting requirements. Views of responsible officials and planned corrective actions – In order for this finding not to occur in the future, the Chief Financial Officer will • Create a Grant calendar to track report due dates • Hold quarterly meetings with managers to ensure we have all reports submitted timely in the future Contact person responsible for corrective action – Toby Barnett, Chief Financial Officer Anticipated completion date – December 2025
Management's Response: We concur. Views of Responsible Officials and Corrective Action Plan Response: The two students identified were underpaid due to locks on their financial aid units for either late-start courses or being on an approved SAP appeal plan. Once locks were removed, PowerFAIDS should...
Management's Response: We concur. Views of Responsible Officials and Corrective Action Plan Response: The two students identified were underpaid due to locks on their financial aid units for either late-start courses or being on an approved SAP appeal plan. Once locks were removed, PowerFAIDS should have recalculated their aid to reflect their current units, however that did not happen. As a result, the Pell Grant was under-awarded. The students have now been disbursed with their full Pell eligibility. Corrective Action Plan: The transition from a legacy SIS and PowerFAIDS to a single ERP will consolidate financial aid and enrollment data into a single system, eliminating reliance on manual adjustments and reducing the risk of data discrepancies between two systems. Banner allows for automated and real-time recalculations for enrollment changes such as late start courses, reducing the risk of Pell under or over-awarding. Financial aid staff will receive updated training and guidance on the importance of verifying Pell recalculations when manual locks on student financial aid records are needed, for instance in the case of a student on an approved SAP appeal plan.
The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was n...
The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately. Officials Responsible for Ensuring Corrective Action: Shanna Pope, Registrar Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding and will implement enhanced procedures to ensure internal controls support the timely and accurate reporting of student status, program, and completion information to the National Student Loan Data System (NSLDS). For each National Student Clearinghouse (NSC) file submitted, students with status, program, or completion changes will be systematically identified and flagged for review. Registrar staff will conduct a targeted, sample-based review of these flagged records directly within NSLDS to verify that data transmitted from NSC was received, processed, and reflected accurately. All policies and procedures governing enrollment reporting and the processing of student status, program, and completion changes will be reviewed, revised as necessary, and formally implemented no later than April 1, 2026, to align with this corrective action.
Views of Responsible Officials and Corrective Action Plan Each Return of Title IV calculation will be supported by verifiable supporting reports or information demonstrating the number of calendar days used in the calculation. During the annual New Year Roll, all date fields will be manually reviewe...
Views of Responsible Officials and Corrective Action Plan Each Return of Title IV calculation will be supported by verifiable supporting reports or information demonstrating the number of calendar days used in the calculation. During the annual New Year Roll, all date fields will be manually reviewed to ensure default system values are appropriate and consistent with the academic calendar. This information will be reviewed by supervisory personnel independent of the staff member preparing the dates and calculations.
Management's Reponse: We concur. View of Responsible Offiicals and Corrective Action Plan The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehens...
Management's Reponse: We concur. View of Responsible Offiicals and Corrective Action Plan The Financial Aid department has strengthened R2T4 compliance through staff training, system validation, deadline tracking, peer reviews, and internal audits. The Director will also conduct an annual comprehensive review to assess processes, staffing, and systems to ensure ongoing compliance and improvement. Implementation Date: September 2025
Procedures are currently in place to comply with the requirement to send Direct Loan notifications within the regulatory time frame. To support this, the responsible team member will have a weekly reminder added to their Lewis & Clark Outlook work calendar to prompt timely notifications. Management ...
Procedures are currently in place to comply with the requirement to send Direct Loan notifications within the regulatory time frame. To support this, the responsible team member will have a weekly reminder added to their Lewis & Clark Outlook work calendar to prompt timely notifications. Management will also add a weekly reminder to one of the office managers' calendars to assist with ongoing monitoring and compliance checks. Person(s) Responsible: Angela Weaver Timing for Implementation: November 7, 2025
The Financial Aid office conducted a comprehensive internal review in Spring 2025 to verify that our procedures were consistently followed. As a result, management corrected a student’s loan proration calculation to be consistent with current practices, regarding truncating rather than rounding the ...
The Financial Aid office conducted a comprehensive internal review in Spring 2025 to verify that our procedures were consistently followed. As a result, management corrected a student’s loan proration calculation to be consistent with current practices, regarding truncating rather than rounding the fractional percentage (decimal) of loan eligibility for students receiving one-semester loans in their last semester of study. Management corrected the loan proration calculation in accordance with current procedures, and the loan amount was adjusted accordingly, resulting in the institution returning $64 in Federal Unsubsidized loan funds to Federal Student Aid. The student was eligible only for unsubsidized loans. Person(s) Responsible: Angela Weaver Timing for Implementation: November 21, 2025
Although Financial Aid Administrators pride themselves on their attention to federal guidelines and the administration of student aid, errors can occur. To reinforce our shared commitment, management has expanded quality assurance reviews and incorporated additional training into regular staff meeti...
Although Financial Aid Administrators pride themselves on their attention to federal guidelines and the administration of student aid, errors can occur. To reinforce our shared commitment, management has expanded quality assurance reviews and incorporated additional training into regular staff meetings. As a result of a verification compliance review, a misread number resulted in a higher Student Aid Index (SAI). A student received Direct Subsidized Loan funds in excess of financial need. Since the student is no longer enrolled during the loan period, according to federal aid guidelines, the institution is not required to take any action to eliminate the excess subsidized loan amount. In contrast if, due to an error, a student borrower who was eligible for a Direct Subsidized Loan instead received a Direct Unsubsidized Loan, the institution would have to correct the error, even if the loan period had ended, by submitting a downward adjustment to reduce or eliminate the Direct Unsubsidized Loan, as appropriate, and replacing it with the same amount of Direct Subsidized Loan funds. Person(s) Responsible: Angela Weaver Timing for Implementation: November 21, 2025
Condition Found The Council did not submit quarterly reports to NHTSA within the required timeframe as stipulated under federal grant requirements. The reports were only provided in September 2025 after the Council became aware of the obligation and coordinated with the Contracting Officer’s Represe...
Condition Found The Council did not submit quarterly reports to NHTSA within the required timeframe as stipulated under federal grant requirements. The reports were only provided in September 2025 after the Council became aware of the obligation and coordinated with the Contracting Officer’s Representative (COR) to submit all past-due reports retroactively. Corrective Action Plan Onboarding Enhancement: Develop and implement a standardized onboarding checklist for new program managers that includes all federal reporting requirements. Compliance Monitoring: Establish quarterly internal compliance reviews to verify timely submission of required reports. Communication Protocol: Formalize communication with government agency to confirm reporting expectations at the start of each contract year. Training: Provide annual compliance training for program managers and relevant staff on federal reporting obligations. Responsible Person for Corrective Action Plan Keith Radeke, Chief Financial Officer Implementation Date of Corrective Action Plan December 18, 2025
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The District's management reviewed all audit adjusting entries with the auditor and agreed to make those adjustments to their accounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The District's management reviewed all audit adjusting entries with the auditor and agreed to make those adjustments to their accounts.
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The District's management is aware of the need for the expertise necessary to prepare a complete set of financial statements and related disclosures. Management has carefully reviewed the ...
Views of Responsible Officials and Planned Corrective Actions: There is no disagreement with the audit finding. The District's management is aware of the need for the expertise necessary to prepare a complete set of financial statements and related disclosures. Management has carefully reviewed the financial statements, disclosures, supplementary information, and schedule of expenditures of federal awards prior to approving them and has accepted responsibility for their content and presentation.
FINDINGS- MAJOR FEDERAL AWARD PROGRAMS AUDIT Material Weakness Special Education Cluster- AL 84.173 / 84.027 Finding No.: 2025-005 Condition: The District's accounting function is controlled by a limited number of individuals resulting in the inadequate segregation of duties. Recommendation: The Dis...
FINDINGS- MAJOR FEDERAL AWARD PROGRAMS AUDIT Material Weakness Special Education Cluster- AL 84.173 / 84.027 Finding No.: 2025-005 Condition: The District's accounting function is controlled by a limited number of individuals resulting in the inadequate segregation of duties. Recommendation: The District should segregate duties where possible. The Board should be ware of this problem and closely review and approve all financial related information. Action Taken: The District concurs with the recommendation. The District has reviewed and continues to review its financial policies and procedures to better segregate duties where possible. The Superintendent continually reminds the Board of their responsibility in regards to review and approving financial items and asking questions. It is not cost feasible to hire additional personnel.
FINDINGS- MAJOR FEDERAL AWARD PROGRAMS AUDIT Material Weakness U.S. Department of Education- Child Nutrition Cluster- AL 10.553 / 10.555 Finding No.: 2025-004 Condition: The District's accounting function is controlled by a limited number of individuals resulting in the inadequate segregation of dut...
FINDINGS- MAJOR FEDERAL AWARD PROGRAMS AUDIT Material Weakness U.S. Department of Education- Child Nutrition Cluster- AL 10.553 / 10.555 Finding No.: 2025-004 Condition: The District's accounting function is controlled by a limited number of individuals resulting in the inadequate segregation of duties. Recommendation: The District should segregate duties where possible. The Board should be ware of this problem and closely review and approve all financial related information. Action Taken: The District concurs with the recommendation. The District has reviewed and continues to review its financial policies and procedures to better segregate duties where possible. The Superintendent continually reminds the Board of their responsibility in regards to review and approving financial items and asking questions. It is not cost feasible to hire additional personnel.
We have carefully reviewed the finding of Documentation of Internal Controls over Federal Awards. The City of Central concurs with the finding. City management recognizes the importance of maintaining current, comprehensive, and properly documented internal controls over federal awards in accordance...
We have carefully reviewed the finding of Documentation of Internal Controls over Federal Awards. The City of Central concurs with the finding. City management recognizes the importance of maintaining current, comprehensive, and properly documented internal controls over federal awards in accordance with 2 CFR part 200.303(a). The City acknowledges that while formal policies and procedures existed, they were not fully updated to reflect current Uniform Guidance requirements and did not sufficiently address all applicable compliance areas for the federal programs administered. The City will undertake a comprehensive review of its existing policies and procedures. Management will update and formalize internal control documentation over federal awards to ensure alignment with Uniform Guidance requirements and to address all relevant compliance areas applicable to the City’s federal programs. This process will include identifying key control activities, documenting responsibilities, and ensuring controls are properly designed and implemented. Additionally, management will increase awareness of Uniform Guidance requirements and internal controls documentation standards by providing resources to applicable staff. Management will continue to periodically review internal control documentation to ensure continued compliance as federal requirements change. Responsible Officials: Mayor Wade Evans; Suzonne Cowart, CPA; Michele Lobianco Anticipated Completion Date: February 2026
Section III Federal Award Findings and Questioned Costs Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care),) Grants for New and Expanded Services Under the Health Center Program, COVID-19 Grants for New and Expanded...
Section III Federal Award Findings and Questioned Costs Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care),) Grants for New and Expanded Services Under the Health Center Program, COVID-19 Grants for New and Expanded Services Under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Item 2025 002 – Special Tests Recommendation The Center should establish a system of internal controls to ensure that all slide fee discounts are properly calculated based on family size and income. Repeat Finding Yes Action Taken The Finance Department will take the following steps to enhance the slide fee discounts process: 1. Policy Revision: the health center will revise its Sliding Fee Discount Policy to ensure alignment with HRSA requirements, including accurate discount calculation methodologies, annual updates to the sliding fee scale, and proper utilization of NextGen system functionality to support implementation 2. Staff Training: the health center will provide comprehensive training to all relevant staff on the revised Sliding Fee Discount Policy and procedures. 3. Training will emphasize correct discount calculations, required documentation, and income verification processes. A recurring training program will be implemented to ensure ongoing compliance for both new hires and existing employees. 3. Retrospective Review: the health center will conduct a retrospective review of patient files for the current fiscal year to confirm that all sliding fee discounts are appropriately supported by required documentation. Any identified discrepancies will be corrected in a timely manner. 4. Ongoing Monitoring: the health center will establish monthly internal audits of sliding fee discount determinations to monitor compliance. Audit results will be documented and reviewed by management to ensure corrective actions are taken as needed. Responsible Party: Chief Financial Officer Target Completion Date: 04/30/2026 If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Javier Vallejo, CFO at (314)-482-0915. Sincerely yours, Javier Vallejo Chief Financial Officer
The City will implement procedures to ensure that all current year expenditures related to federal awards are accurately recorded on the SEFA and properly reconciled to the General Ledger.
The City will implement procedures to ensure that all current year expenditures related to federal awards are accurately recorded on the SEFA and properly reconciled to the General Ledger.
Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperativ...
Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.
Finding Synopsis - Three vendor disbursements made under the Child Nutrition Cluster did not have the required purchase orders as required by the District's established internal control policies. Action Steps - The District will communicate with staff the importance of preparing purchase orders prio...
Finding Synopsis - Three vendor disbursements made under the Child Nutrition Cluster did not have the required purchase orders as required by the District's established internal control policies. Action Steps - The District will communicate with staff the importance of preparing purchase orders prior to making a purchase. We will establish a procedure in which the purchaser must review required documentation, inclusive of purchase orders, prior to making a purchase. Contact Person - Kevin Spain, Superintendent Anticipated Completion Date - December 31, 2025
Student Financial Assistance Cluster – Assistance Listing No. Various Views of Responsible Officials and Planned Corrective Actions The exception identified was due to the implementation of the new mobile application which should not have allowed withdrawal functionality to bypass an academic adviso...
Student Financial Assistance Cluster – Assistance Listing No. Various Views of Responsible Officials and Planned Corrective Actions The exception identified was due to the implementation of the new mobile application which should not have allowed withdrawal functionality to bypass an academic advisor when withdrawing from all courses. Management identified the mobile application withdrawal capability and has already performed targeted reviews of students who withdrew via the app and will continue to capture future app withdrawals and perform R2T4 review and calculations accordingly. Responsible Persons Heidi Granger – Associate Vice Chancellor, Financial Aid Michelle Hill – Director, Technical Support, Financial Aid Amber Aboud – Associate Director, Compliance, Financial Aid Sarah Cuellar – Associate Director, Financial Aid Planned completion date for corrective action plan Completed during audit review - December 2025
Student Financial Assistance Cluster – Assistance Listing No. Various Views of Responsible Officials and Planned Corrective Actions Student Financial Aid has implemented exception reports to monitor students whose enrollment status has changed after initial disbursement while the attending hours fun...
Student Financial Assistance Cluster – Assistance Listing No. Various Views of Responsible Officials and Planned Corrective Actions Student Financial Aid has implemented exception reports to monitor students whose enrollment status has changed after initial disbursement while the attending hours functionality is turned off due to the Banner student system defect. This review will ensure timely identification and evaluation of Pell Grant eligibility eliminating the over-awarding of the Pell Grant award amount. Responsible Persons Michelle Hill – Director, Technical Support, Financial Aid Planned completion date for corrective action plan Completed during audit review - December 2025
Audit Finding Reference: 2025-002 – Title I Grants to Educational Agencies (LEAs) – ALN #84.010 Planned Corrective Action: For FY26, the Academy has implemented a process to ensure procurement of approval signatures on Semi-Annual Time Certification Forms, which will demonstrate a review has been pe...
Audit Finding Reference: 2025-002 – Title I Grants to Educational Agencies (LEAs) – ALN #84.010 Planned Corrective Action: For FY26, the Academy has implemented a process to ensure procurement of approval signatures on Semi-Annual Time Certification Forms, which will demonstrate a review has been performed over salary allocations. Name of Contact Person: Bob Haynes Interim Controller Bobhaynes@achievementfirst.org Anticipated completion date: December 9, 2025
Audit Finding Reference: 2025-001 – Title I Grants to Educational Agencies (LEAs) – ALN #84.010 Planned Corrective Action: We will revise our process to ensure the appropriate approval signatures are on Student Withdrawl Forms for transferred students, and for Graduated Students Listing. Name of Con...
Audit Finding Reference: 2025-001 – Title I Grants to Educational Agencies (LEAs) – ALN #84.010 Planned Corrective Action: We will revise our process to ensure the appropriate approval signatures are on Student Withdrawl Forms for transferred students, and for Graduated Students Listing. Name of Contact Person: Bob Haynes Interim Controller Bobhaynes@achievementfirst.org Anticipated completion date: December 9, 2025
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