Corrective Action Plans

Finding 525014 (2024-003)

None 2024

Our Lady of the Lake University of San Antonio

TX

Internal Control / Segregation of Duties Special Tests & Provisions Matching / Level of Effort / Earmarking § 200.308

Finding: Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Corrective Action: The University ha...

Finding: Special Tests and Provisions – Key Personnel Research and Development Cluster, Assistance Listing Number: 84.031S Federal Granting Agency: U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Corrective Action: The University has a process in place for personnel charged to grants to complete personal activity reports to monitor their level of effort on the grants. We were not requiring key personnel that are providing in-kind services on grants to complete the personal activity reports, although the project directors are monitoring the involvement of all personnel working on grants to ensure we are providing an appropriate level of effort in the grant activities. The individual identified in this finding was providing in-kind services and was not paid from federal funds. The University will update its processes to ensure that that project activity reports are documented and reviewed for all key personnel assigned to grants, including in-kind personnel. Status: In-progress Person Responsible for Implementing: Edith Cogdell, Chief Financial Officer Implementation Date: 05/31/2025

View Audit 344329

Finding 525012 (2024-002)

None 2024

Our Lady of the Lake University of San Antonio

TX

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding: Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Ins...

Finding: Special Tests and Provisions – Enrollment Reporting Student Financial Assistance Cluster, Assistance Listing Number 84.268 Federal Direct Student Loans, Assistance Listing Number 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2023–2024 Type of Finding: Other Instance of Noncompliance and Deficiency Corrective Action: The failure to report certain enrollment status changes to the NSLDS on a timely basis during the fiscal year ending May 31, 2024, was an isolated instance due to turnover in the Registrar’s Office. The University has updated the process for reporting enrollment status changes to the NSLDS and has ensured there is adequate cross-training in the Registrar’s Office to prevent future instances of non-compliance with reporting deadlines. Status: Completed Person Responsible for Implementing: Melissa Delgado, Registrar Implementation Date: 01/01/2025

View Audit 344329

Finding 524993 (2024-006)

Significant Deficiency 2024

Minneapolis College of Art and Design

MN

Internal Control / Segregation of Duties Student Financial Aid Significant Deficiency

Notifications of Disbursements Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit findi...

Notifications of Disbursements Recommendation: We recommend the College review and strengthen its procedures for notifying students of their Direct Loan disbursements within the required time frame and that documentation of the letters sent is maintained. Explanation of disagreement with audit finding: The Financial Aid Office already has set procedures pertaining to the sending of mass communications to our students whenever Direct Loan disburses. There was an oversight only for the term of Fall 2023 where MCAD failed to launch the communication in a timely manner to disbursement receiving students. Action taken in response to finding: ● The Financial Aid Operations Calendar - will include updated entries concerning the generation of communication for Disbursement Notification. ● Process Update - the sending of the communication will be incorporated into the mass disbursement process at the end of Add/Drop periods during the Fall and Spring terms. Name(s) of the contact person(s) responsible for corrective action: Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: Mar 1, 2025

View Audit 344312

Finding 524988 (2024-005)

Significant Deficiency 2024

Minneapolis College of Art and Design

MN

Questioned Costs Significant Deficiency Matching / Level of Effort / Earmarking

Awarding of Direct Loans Recommendation: We recommend the College evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actio...

Awarding of Direct Loans Recommendation: We recommend the College evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ● Updating the current policy: Financial Aid Office will outline a more thorough policy pertaining to its awarding of additional unsubsidized loan amounts to dependent students. ● Proper documentation concerning the reason for the additional award amount will be required in the specific student’s file in Powerfaids. ● Training sessions will be conducted to assure all members of the Financial Aid Office understands the conditions and expectations from the Department of Education regarding the awarding of additional unsubsidized loans. Name(s) of the contact person(s) responsible for corrective action: Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: May 1, 2025

View Audit 344312 Questioned Costs: $1

Finding 524983 (2024-004)

Significant Deficiency 2024

Minneapolis College of Art and Design

MN

Student Financial Aid Reporting Significant Deficiency

Perkins Reconciliation Recommendation: It is recommended that the College review procedures in place to ensure accurate reporting of Perkins loan information to comply with Title IV regulations. Explanation of disagreement with audit finding: MCAD had undergone numerous staff transitions within The...

Perkins Reconciliation Recommendation: It is recommended that the College review procedures in place to ensure accurate reporting of Perkins loan information to comply with Title IV regulations. Explanation of disagreement with audit finding: MCAD had undergone numerous staff transitions within The Business Office. Its previous Perkins Loan Servicer, University Accounting Service (UAS), was derelict in its duty to fulfill the terms of the contract by failing to perform in managing all areas of MCAD’s Perkins Loan portfolio. UAS failed to keep current as well as accurate accounting and funds management records throughout its tenure as the servicer. Action taken in response to finding: ● Changing of Servicer: MCAD has removed UAS and completed the changeover to Heartland Educational Computer Systems Incorporated (ECSI) as its new Perkins servicer. ● Business Office (Student Accounts Manager) will provide close oversight to ensure accountability that ECSI will fulfill its duties and responsibilities as Perkins Loan Servicer ● The Financial Aid Office will partner with the Business Office as another layer of accountability and support to the Business Office as it supervises ECSI. ● Third-Party Assistance: The institution has engaged with CLA to assist with the reconciliation of the Perkins Loan accounts. It is expected that the work CLA has done to assist will come to full fruition and be fully reconciled sometime in 2025. Name(s) of the contact person(s) responsible for corrective action: Mary Alma Noonan, CFO, Brian Braden, Controller and Sherman Lee, Financial Aid Director Planned completion date for corrective action plan: June 30, 2025

View Audit 344312

Finding 524973 (2024-002)

Significant Deficiency 2024

Minneapolis College of Art and Design

MN

Significant Deficiency Internal Control / Segregation of Duties

Gramm-Leach Bliley Act (GLBA) Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findi...

Gramm-Leach Bliley Act (GLBA) Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MCAD’s IT department has been working to finalize its WISP protocols to comply with the updated GLBA requirements and ensure the safety and security of data held by MCAD. As we implement the necessary changes required for compliance, our intention is to have these documented and adopted by the end of our fiscal year. Name(s) of the contact person(s) responsible for corrective action: Mary Alma Noonan, CFO and Matthew Hoban, AVP Technology Planned completion date for corrective action plan: May 31, 2025

View Audit 344312

Finding 524968 (2024-002)

Material Weakness 2024

National University

CA

Student Financial Aid Material Weakness Reporting

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control National University acknowledges the findings and the importance of accuracy and timeliness when completing enrollment reporting to NSLDS. The University has made significant efforts to impr...

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control National University acknowledges the findings and the importance of accuracy and timeliness when completing enrollment reporting to NSLDS. The University has made significant efforts to improve all areas of the enrollment reporting process, and the results of this audit do not reflect those efforts and improvements due to the timing of the FY 23 audit completion in February 2024 and CAP completion in June 2024. The institution has identified two items that have resulted in challenges to accurate and timely enrollment reporting during the audit year. Intent to return: The University has identified a need to improve the understanding and implementation of its intent to return (ITR) process. As a result, the University will conduct a holistic review, including assessment and clarification of the current policy, identification and implementation of technological controls, comprehensive training for ITR, and the development and implementation of a monthly ITR review. National Student Clearing House (NSC) reporting: On October 18, 2024, the institution was notified by NSC that its access to process enrollment reporting on behalf of NU was revoked during July 2024, resulting in a reporting gap. The institution is investigating the root cause of this and submitted a ticket to the FPS/SAIG help desk, but no root cause was able to be identified. The issue was immediately resolved upon notification; however, the reporting gap had a significant impact on the FY 24 enrollment reporting sample. In addition to the above, the institution will continue or take the following steps: • Continued monthly testing of enrollment reporting accuracy to NSLDS conducted by the quality assurance team. • Identification and timely delivery of training for areas of opportunity identified in the monthly reviews to the registrar and data operations teams. • Revise the internal documentation process between quality assurance, data operations, and the registrar teams to ensure clarity of policy and regulatory guidance in areas of identified risk/confusion during enrollment reporting processing. Contact Person Responsible for Corrective Action: • Rob Conlon, AVP Financial Aid Compliance • Sarah Massey, AVP of Operations Student Support and Registrar Operations • Gabrielle Witruke, Associate Director Data Analytics • Melissa Diaz, AVP Operations Advising Anticipated Completion Date: March 2025

View Audit 344308

Finding 524963 (2024-001)

Material Weakness 2024

National University

CA

Questioned Costs Special Tests & Provisions Student Financial Aid

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University acknowledges the finding and impo...

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University acknowledges the finding and importance of accurate identification and timely and accurate calculation of R2T4s. The University has made significant efforts to improve all areas of R2T4 processing, and the results of this audit show significant gains over the previous year. Given the timing of the FY 23 audit completion in February 2024 with CAP completion scheduled for June 2024, the benefits of the FY 23 corrective action plan have a limited impact on this audit period. This, coupled with the improved results the institution has seen in timeliness such as the late return error rate having decreased from 31% in FY 23 to 13% in the current audit, suggests that NU is pathing towards compliance with R2T4 requirements. Based on this assessment, NU will continue to take the following actions: • Continual assessment of staffing levels and hiring as needed to ensure timely identification and processing of R2T4s. Staffing ratios were established in FY24 and staffing increases were implemented to ensure accurate processing and timely completion. • Continual identification of risks with weekly testing and readouts from Quality Assurance to the financial aid processing team. • Re-training with the R2T4 processing team on the order of returns. • Identification and timely delivery of training for areas of risk identified in the weekly reviews. • Revise internal processes between the Quality Assurance and financial aid processing to better communicate policy and regulatory guidance in areas of identified risk/confusion during R2T4 processing. Contact Person Responsible for Corrective Action: • Rob Conlon, AVP Financial Aid Compliance • Alan Coddington, AVP Student Financial Services Anticipated Completion Date: January 2025

View Audit 344308 Questioned Costs: $1

Finding 524960 (2024-001)

Significant Deficiency 2024

Housing Authority of Cook County

IL

HUD Housing Programs Internal Control / Segregation of Duties Eligibility

Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed accurately and on a timely basis. Danita W. Childe...

Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed accurately and on a timely basis. Danita W. Childers, Executive Director, is responsible for implementing this corrective action by March 31, 2025.

View Audit 344304

Finding 524954 (2024-001)

Significant Deficiency 2024

Boscobel Area School District

WI

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Finding #2024-00 I - Limited Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control ...

Finding #2024-00 I - Limited Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the district's operations. Response: We agree with this finding and continue to work to achieve segregation of duties whenever cost effective. The cash disbursements process includes approval of purchase orders and matching of approved purchase orders with invoices. Review of account coding is performed by the district accounting staff. The payroll disbursement process includes approval of timesheets and review of coding on an ongoing basis. The Board of Education reviews budget to actual information along with disbursement information on a monthly basis. Contact Person: Lisa Wallin-Kapinus Anticipated Completion: Not Applicable

View Audit 344301

Finding 524939 (2024-001)

Material Weakness 2024

El Camino Community College District

CA

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking

Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Response to Recommenda...

Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Response to Recommendation: The District acknowledges the importance of adhering to R2T4 requirements and has taken the following actions to address this recommendation: The District adjusted the student samples as notated by auditors. Samples with discrepancies have been recalculated based on R2T4 requirements and correct amounts have been returned to the Department of Education. Verification of corrected R2T4 calculations was provided to auditors. Action taken in response to finding: 1. Consultant Engagement: o A NASFAA-certified consultant with extensive experience as a financial aid director has been hired to assist the R2T4 team during the 2024-2025 aid year. o The consultant will review all R2T4 calculations to ensure compliance and accuracy. Additionally, a secondary staff member is assisting in reviewing all 2024-2025 R2T4 calculations. 2. Training Initiatives o Provided department-wide training on R2T4 policies and procedures. o Delivered in-depth training sessions specifically tailored for the R2T4 team. o The R2T4 team has successfully completed NASFAA’s R2T4 course series to enhance their expertise. 3. Staffing Adjustments o An Accounting Technician under the direction of the District Business Manager will be assigned to Financial Aid to support R2T4 processing and reconciliation to ensure accuracy and compliance. o Additionally, this Accounting Technician will need to have view-only access to all data and reports available in the Student Financial Aid module contained in Colleague in o order to be effective in providing meaningful analysis and reconciliation of student-level detail to summary ledgers and reports contained in the Fiscal Services module of Colleague and other financial reporting tools. 4. Process Improvements o Instruct the R2T4 team to use the Department of Education’s R2T4 worksheet in the COD system instead of the R2T4 module in Colleague. o This change addresses the lack of automation and checks in the Colleague system, which has been a contributing factor to discrepancies. o Financial Aid has reached out and established rapport and protocols with academic and registrar offices to enhance understanding of academic engagement, registration processes, and data fields. o The department has updated the policy and procedures manual, including cheat sheets to clarify points of regulatory interpretation along with El Camino’s data fields to use. 5. System and Workflow Evaluation o Identified that the R2T4 module in Colleague lacks automation or checks and balances to flag manual input discrepancies. o Future plans include exploring system enhancements or alternatives to improve functionality and reduce reliance on manual calculations. o The District has begun evaluating ways to improve the R2T4 reports to help automate this process as much as possible. Name of the contact person responsible for corrective action: Chau Dao, Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: Implementation Timeline:  Consultant Review: Begin immediately, with ongoing review throughout the 2024-2025 aid year; retain consultant services for 2025-2026 aid year.  Training: Complete with Spring 2025 R2T4 calculation, with periodic refresher sessions scheduled on an annual basis.  Staffing Request: The Accounting Technician position will be assigned no later than July 1, 2025. This position shall be filled by existing accounting staff or, if needed, a new employee.  Process Transition: Full transition to the COD system worksheet for R2T4 calculations with the Fall 2024 term R2T4 calculation.  System Evaluation: Initiate and maintain ongoing discussions with IT and software providers, leveraging opportunities from conferences, networking events, and training sessions to explore and implement improvements. Monitoring and Evaluation:  Conduct monthly audits of R2T4 calculations to identify and address errors promptly.  Maintain ongoing collaboration with the consultant to refine processes and implement best practices.  Evaluate the effectiveness of new training and staffing adjustments after six months and report findings.

View Audit 344288

Finding 524920 (2024-002)

Significant Deficiency 2024

Howard Community College

MD

Special Tests & Provisions Student Financial Aid Reporting § 200.303

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommenda...

2024‐002: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with Records, Registration and Veterans Affairs (RRVA) to conduct a thorough review of the current policies and procedures for reporting student enrollment status changes and effective dates to NSLDS and then subsequently implement process improvements to ensure that our process aligns with federal regulations. Name(s) of the contact person(s) responsible for corrective action: Jessica Peterson, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 344285

Finding 524916 (2024-005)

Significant Deficiency 2024

Howard Community College

MD

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation:...

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation: It is recommended that the College strengthens its internal controls and improves coordination among departments to ensure timely submission of required data for the Return of Funds. This may include implementing a more robust tracking system, providing additional training to staff, and establishing clear deadlines and responsibilities for data submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services will work with the Administration Information Systems department along with other stakeholders to strengthen its internal controls and improve communication. Additionally, Howard Community College will work with AIS to develop and implement a more robust system to track and review the data required to complete the Return of Funds process. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Education has questions regarding this plan, please call Detra Hooper, Financial Aid Services Director at 443‐518‐4776.

View Audit 344285

Finding 524915 (2024-004)

Significant Deficiency 2024

Howard Community College

MD

Student Financial Aid Reporting Significant Deficiency § 200.303

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recom...

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recommendation: It is recommended that the College strengthens its internal controls and verification processes to ensure the accuracy of data reported in the FISAP. This may include creating a formalized review process for the FISAP and ensuring all supporting schedules used to populate the form are centrally stored. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services has created a formalized review process for FISAP and created a central location to store data. This review process includes multiple staff members and internal controls for future review. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Director Planned completion date for corrective action plan: June 30, 2025

View Audit 344285

Finding 524914 (2024-003)

Significant Deficiency 2024

Howard Community College

MD

Subrecipient Monitoring Internal Control / Segregation of Duties Student Financial Aid § 200.303

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the ...

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with the Administrative Information Systems (AIS) department to conduct a thorough review of the written information security program to ensure the necessary elements are included and meeting the minimum requirements as outlined in 16 CFR 314.4. Name(s) of the contact person(s) responsible for corrective action: Tyria Stone, Executive Vice President, Finance & Administration

View Audit 344285

Finding 524897 (2024-002)

Significant Deficiency 2024

Town of Coventry, Connecticut

CT

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting

UNITED STATES DEPARTMENT OF THE TREASURY 2024-002 COVID-19 – American Rescue Plan Act – Assistance Listing No. 21.027 Recommendation: We recommend that the Town review its procedures over grant reporting requirements to ensure all reports are reviewed and documentation of that review is retained. ...

UNITED STATES DEPARTMENT OF THE TREASURY 2024-002 COVID-19 – American Rescue Plan Act – Assistance Listing No. 21.027 Recommendation: We recommend that the Town review its procedures over grant reporting requirements to ensure all reports are reviewed and documentation of that review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although there were no errors in the reporting, to ensure efficiencies, staff other than the Finance Director will review grant reporting and sign off before it is submitted. Name(s) of the contact person(s) responsible for corrective action: Julie Chapman Planned completion date for corrective action plan: February 1, 2025

View Audit 344253

Finding 524881 (2024-002)

Significant Deficiency 2024

East Windsor Regional School District

NJ

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.403 § 200.430

Cross training will occur between the BA, Assistant BA and the Senior Accountant. In the event of extended vacancies or absences, multiple staff members will be trained on filing correct final reports.

View Audit 344245 Questioned Costs: $1

Finding 524876 (2024-001)

None 2024

East Windsor Regional School District

NJ

Reporting Internal Control / Segregation of Duties

Cross training will occur between the BA, Assistant BA and the Senior Accountant. In the event of extended vacancies or absences, multiple staff members will be trained on filing correct final reports.

View Audit 344245

Finding 524870 (2024-001)

Significant Deficiency 2024

Markesan District Schools

WI

Internal Control / Segregation of Duties

Finding #2024-001 – Lack of Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Checks and balances should be in place to allow management or employees, in the normal course of ...

Finding #2024-001 – Lack of Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Checks and balances should be in place to allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct any misstatements on a timely basis. Cause: A small number of individuals within the District’s administration perform substantially all accounting functions and have control over both records and assets. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the District’s operations. Response: We agree and will continue to provide supervision and monitor accounting information and operations, obtain explanations for variances from unexpected results and work to increase segregation of duties. The Assistant to the Business Manager will continue to clear checks in Skyward as part of the bank reconciliation process. The District Administrator will review and initial all journal entries. The Assistant to the Business Manager will review payroll on a monthly basis, and the District Administrator will review payroll on a quarterly basis. Contact Person: Tim Zacharias Anticipated Completion: Not Applicable

View Audit 344235

Finding 524859 (2024-002)

Significant Deficiency 2024

High Point University

NC

Questioned Costs Special Tests & Provisions HUD Housing Programs

Finding 2024-002 Program: Federal Work-Study Program Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2023 - 2024 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program fi...

Finding 2024-002 Program: Federal Work-Study Program Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2023 - 2024 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and that all amounts paid are appropriately earned. University’s Response: The University continues to emphasize and reinforce with its students and student supervisors that, regardless of whether jobs are funded by the Federal Work Study program or by the institution, students must not be working during scheduled class hours regardless of whether the class is cancelled or let out early. The Student Employment Program holds annual training sessions for and provides updated publications to these responsible individuals. As part of the University student employment application process, students must submit their class schedule with their application. The University expects supervisors to utilize the student class schedules provided and keep work schedules distinct. The University also expects that supervisors continue to obtain students class schedules each semester and updates students work schedules accordingly each semester to ensure students are not working during times they are in class. The University continues to use the internal audit process it instituted in February 2023. A sample of student work records from the previous semester will be compared to students’ class schedules to ensure students are not working during class hours. This review will be performed by Michael Peeler, Vice President for Financial Affairs. Any violations of the school’s student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Corrective Action Plan: The University’s Student Employment Office continues to send monthly emails to student employee supervisors and to the student staff, reminding them of the student employment guidelines they are expected to abide by. This communication reminds them of their responsibility to adhere to student employment guidelines and their responsibility to keep their supervisor informed of any changes they may make to their class schedule that could require their work schedule to be adjusted. Since the hours of overpayment appeared to be resulting from students failing to clock out and managers failing to catch inaccurate hours of record (working for eight or more hours in a day, working overnight, etc.), further training and instruction to pay closer attention to these discrepancies so they are corrected at the time of approving timesheets has been provided to student employee supervisors as part of the monthly email communication. Student employee supervisors will continue to be expected to hold a mandatory meeting with their student staff at or before the start of each semester.The University’s internal audit process is also being expanded to be performed quarterly, twice each semester. This process will continue to sample student work records at the midpoint and end of the fall and spring semesters, where students’ class schedules are compared to hours worked to ensure students are not working during class hours. Michael Peeler, Vice President for Financial Affairs, will perform this review. Any violations of the school’s student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services; Sandra Fantauzzi, Student Employment Program Manager; Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs Anticipated Completion Date: March 31, 2025

View Audit 344215 Questioned Costs: $1

Finding 524858 (2024-001)

Significant Deficiency 2024

High Point University

NC

Cash Management Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

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 524822 (2024-001)

Significant Deficiency 2024

The College of New Jersey

NJ

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.403 § 200.430

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administra...

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administration 609-771-2847 Corrective Action Plan: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions from July 1, 2023, to December 31, 2023, in the fiscal year being audited. The effort was certified after the fiscal year, as part of the year-end process which was not in line with the semi-annually time frames as historically done with guidance in our Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). The timing delays occurred due to staffing vacancies and knowledge transfer of current staff as well as misalignment of staffing. Once the staffing was realigned, trained, and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed. This task occurred during the months between August 2024 and November 2024 which was outside the policy time frames. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance by taking corrective action steps to improve monitoring and oversight, strengthen training and communications, and develop an action plan for corrective timing. The College implemented part of the corrective action on August 01, 2024, retroactive to July 1, 2023, and will complete the remaining items by the end of the next fiscal year. Anticipated Completion Date: June 30, 2025

View Audit 344210

Finding 524808 (2024-001)

Significant Deficiency 2024

Corban University

OR

Questioned Costs Student Financial Aid Significant Deficiency

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The academic calendar has been updated between academic catalog and website ensuring better accuracy. Policies and procedures surrounding the date of withdrawal and what constitutes an academic break have also been corrected and u...

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The academic calendar has been updated between academic catalog and website ensuring better accuracy. Policies and procedures surrounding the date of withdrawal and what constitutes an academic break have also been corrected and understood across the Registrar and Financial Aid offices. Financial Aid professionals have also been added to internal meetings where decisions on programs, academic calendars, and other significant timing decisions are made to better enhance our ability to comply. Person Responsible for Corrective Action Plan: Jordan Lindsey, Vice President for Enrollment Management and Marketing Anticipated Date of Completion: 2/1/25

View Audit 344190 Questioned Costs: $1

Finding 524791 (2024-003)

Significant Deficiency 2024

University of Dubuque

IA

Subrecipient Monitoring Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive securi...

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive security policy. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 10/01/2024

View Audit 344180

Finding 524786 (2024-001)

Significant Deficiency 2024

Villanova University

PA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Villanova University agrees with this finding. During the year, there was turnover at the University, and we acknowledge the training of new staff must be a priority to ensure continuity of key controls. Appropriate training and new internal control processes that would have detected this error hav...

Villanova University agrees with this finding. During the year, there was turnover at the University, and we acknowledge the training of new staff must be a priority to ensure continuity of key controls. Appropriate training and new internal control processes that would have detected this error have been implemented. The department has created a submission file consisting of new graduates only to be transmitted to the National Student Clearinghouse at the end of May and another at the end of June to identify any additional students to report. In addition, the University has created a Graduation Audit Report to be used internally to verify the change in status for students who graduated, and a final validation check performed by the Senior Assistant Registrar for Student History to confirm accuracy of student status. Name of contact person: Susan Morgan, Director of Technical Student Systems, Registrars Office Anticipated Completion date: May 2025 in conjunction with the next submission of graduation files

View Audit 344168

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