Corrective Action Plans

Finding 551208 (2024-019)

Material Weakness 2024

WV

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.334

The Board will establish procedures that will ensure compliance with guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200 for Special Education.

View Audit 352084 Questioned Costs: $1

Finding 551189 (2024-003)

Material Weakness 2024

The City of New York

NY

Questioned Costs Internal Control / Segregation of Duties Eligibility § 200.303

Finding No. 2024-003 Department(s): New York City Administration for Children’s Services and Department of Education Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: The City is planning to transition to the New York State IT system o...

Finding No. 2024-003 Department(s): New York City Administration for Children’s Services and Department of Education Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: The City is planning to transition to the New York State IT system once it is fully developed and implemented by the New York State Office of Children and Family Services and New York State Information Technology for the Child Care Assistance Program. The State IT system will be programmed to reflect current State policy on authorized hours, mitigating the risk of this error in the future. In the interim, The City will implement a short-term, manual solution that will ensure enrollments match authorized hours with regard to full time or part time enrollment and days of enrollment. The first step of the manual solution requires a feasibility analysis to see if it is possible to add a field for recording authorized hours into The City's IT system of record. DOE: The DOE will continue working with ACS to ensure compliance with internal controls, applicable state and federal statutes, regulations, requirements and guidelines. The internal controls include a quality assurance check process on submitted eligibility applications. Anticipated Completion Date: ACS: August 2025 and ongoing DOE: Ongoing Person(s) Responsible for Implementation: ACS: Shari Gruber, Associate Commissioner, Policy and Compliance, Division of Child & Family Well-Being, shari.gruber@acs.nyc.gov, (212) 393-5109 DOE: Meg Barboza, Senior Director of Program Enrollment, mbarboza@schools.nyc.gov, (212) 287-1996 Jodina Clanton, Eligibility and Senior Director of Policy, jclanton@schools.nyc.gov, (212) 287-1927

View Audit 352075 Questioned Costs: $1

Finding 551186 (2024-002)

Significant Deficiency 2024

The City of New York

NY

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

Finding No. 2024-002 Department(s): New York City Department of Health and Mental Hygiene Program(s): Assistance Listing Number 93.323, Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Corrective Action(s): DOHMH agrees with the recommendation that “DOHMH enhance their internal ...

Finding No. 2024-002 Department(s): New York City Department of Health and Mental Hygiene Program(s): Assistance Listing Number 93.323, Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Corrective Action(s): DOHMH agrees with the recommendation that “DOHMH enhance their internal controls over the reporting process by ensuring that all financial and special performance reports undergo documented review and approval before submission within the required timeframe.” Anticipated Completion Date: Effective Immediately; 3/25/2025 Person(s) Responsible for Implementation: Yuming Li - Director, yli@health.nyc.gov Anthony Faciane - Assistant Commissioner, afaciane@health.nyc.gov Wai Ting Yu - Assistant Commissioner, wyu4@health.nyc.gov Jennifer Carmona - Senior Director, jcarmona@health.nyc.gov Xiu Mei Mai - Director, xmai@health.nyc.gov James Chan - Director, jchan6@health.nyc.gov Yulia Gudzinskiy - Grants Manager, ygudzinskiy@health.nyc.gov Jenny Tejada - Director, jtejada@health.nyc.gov Inna Dubrovenska - Assistant Director, idubrovenska@health.nyc.gov

View Audit 352075

Finding 551180 (2024-004)

Material Weakness 2024

The City of New York

NY

HUD Housing Programs Eligibility Material Weakness § 200.303

Finding No. 2024-004 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimiz...

Finding No. 2024-004 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. HPD continues to make progress in addressing this substantial backlog through the implementation of technological and streamlined program improvements. HPD increased its HUD reporting rate of actions taken on household cases by 34% from FY23. Although there has been significant progress towards on time recertifications, HPD anticipates it will continue to take time until the agency achieves pre-pandemic overall submission levels as HPD ensures that any enforcement action the agency takes is taken as a last resort. HPD’s COVID-era policies involving adverse action have ceased and normal processes are in effect. However, it takes intensive tracking and follow up to ensure participants comply with requirements to submit annual certifications or have due-process before terminating subsidy for failing to respond. As a result, there is a lag between the re-implementation of HPD’s policy to take enforcement actions and ensuring every active participant has a completed certification. 1. Continue to build on existing systems to more closely track recertifications that are mailed and not returned. 2. Build on the more robust digital operations that were started during the pandemic to track the submission of documents improving reporting capabilities that help track overdue recertifications. 3. Create a streamlined process for referring overdue cases for Community Based Organizations that can assist participants complete and return recertification package 4. Continue to provide automated reminders for participants at risk of termination of assistance because of their failure to submit a recertification package. 5. Invest in a training team to meet the training needs of new staff Anticipated Completion Date: Implemented as of March 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 352075

Finding 551178 (2024-005)

Material Weakness 2024

The City of New York

NY

HUD Housing Programs Internal Control / Segregation of Duties Eligibility § 200.303

Finding No. 2024-005 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Pro...

Finding No. 2024-005 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. HPD continues to make progress in addressing this substantial backlog through the implementation of technological and streamlined program improvements. HPD increased its HUD reporting rate of actions taken on household cases by 34% from FY23. Although there has been significant progress towards on time recertifications, HPD anticipates it will continue to take time until the agency achieves pre-pandemic overall submission levels as HPD ensures that any enforcement action the agency takes is taken as a last resort. HPD’s COVID-era policies involving adverse action have ceased and normal processes are in effect. However, it takes intensive tracking and follow up to ensure participants comply with requirements to submit annual certifications or have due-process before terminating subsidy for failing to respond. As a result, there is a lag between the re-implementation of HPD’s policy to take enforcement actions and ensuring every active participant has a completed certification. 1. Continue to build on existing systems to more closely track recertifications that are mailed and not returned. 2. Build on the more robust digital operations that were started during the pandemic to track the submission of documents improving reporting capabilities that help track overdue recertifications. 3. Create a streamlined process for referring overdue cases for Community Based Organizations that can assist participants complete and return recertification package 4. Continue to provide automated reminders for participants at risk of termination of assistance because of their failure to submit a recertification package. 5. Invest in a training team to meet the training needs of new staff Anticipated Completion Date: Implemented as of March 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 352075

Finding 551177 (2024-007)

Significant Deficiency 2024

The City of New York

NY

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

Finding No. 2024-007 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): HRA implemented the corrective actions noted in our response to the Fiscal 2023 Single Audit findings. In Nove...

Finding No. 2024-007 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): HRA implemented the corrective actions noted in our response to the Fiscal 2023 Single Audit findings. In November of 2023, HRA hired an Executive Director for the Home TBRA program, updated the quality assurance evaluation tool and trained staff on the differences of budgeting the “gross” and “net” income. Note that HRA began closing out the TBRA tenants with renewal lease dates starting on 8/1/2023, as the program fully closed and transitioned to the City Fighting Homelessness and Eviction Prevention Supplement (“CityFHEPS”) by the 6/30/24 HRA- Housing Preservation and Development Memorandum of Understanding expiration date. Although the rental assistance portion of the HOME TBRA program began phasing out, the following corrective actions were implemented as part of the Fiscal 2023 Single Audit recommendation: • Supervisory staff were retrained on case review and instructed to do a thorough and comprehensive review of the budget and documentation received to inform case decisions. There have been on-going team and individual meetings, informational sessions and trainings with staff involved with TBRA to improve performance and outcome. Anticipated Completion Date: Not Applicable. As noted above, the Rental Assistance portion of the program has been taken over by CityFHEPS. Person(s) Responsible for Implementation: Jordan Worrell, HTBRA Executive Director worrellj@hra.nyc.gov (929)-252- 5403

View Audit 352075

Finding 551168 (2024-101)

Significant Deficiency 2024

Pima County Community College District

AZ

Questioned Costs Student Financial Aid Special Tests & Provisions § 200.303

Assistance Listings number and program name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans This finding initially occurred in fiscal year 2024. Name of Contact Person: David Donderew...

Assistance Listings number and program name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans This finding initially occurred in fiscal year 2024. Name of Contact Person: David Donderewicz, M. Ed., Executive Director of Financial Aid and Scholarships Anticipated completion date: June 30, 2025 Corrective Action: 1. Perform calculations for all students who received Title IV funds and withdrew during the period November 2023 through June 2024 and immediately return all unearned aid to ED. 2. Review and update the student information system’s automated controls to properly identify and flag all students who receive Title IV funds and withdraw from the District. 3. Test any changes made to the student information system and verify controls are operating as designed to comply with the SFA cluster’s requirements. The College concurs with the recommendations from the Arizona Auditor General. The College will conduct an additional review to identify any students who may have impacted financial aid adjustments and will enact any necessary corrections (estimated completion, 3/31/25). Additionally, the College will review the automated controls process to ensure the accuracy of the enrollment change data and will conduct assessments at the end of each term to ensure R2T4 calculations are processed correctly (estimated completion 6/30/25).

View Audit 352069 Questioned Costs: $1

Finding 551149 (2024-003)

Significant Deficiency 2024

Bergen Community College

NJ

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

Views of Responsible Officials: The College agrees that it did not submit the data correction nor recalculated awards for one out of the forty of the students sampled. While the College does not believe that this failure rate represents a significant deficiency, we acknowledge the importance of the ...

Views of Responsible Officials: The College agrees that it did not submit the data correction nor recalculated awards for one out of the forty of the students sampled. While the College does not believe that this failure rate represents a significant deficiency, we acknowledge the importance of the finding and will take mitigation steps moving forward. The Financial Aid Office brought verifications back in-house for the 23-24 award year after a five-year contract was ended with a third-party agency. To strengthen compliance efforts, our financial aid staff underwent verification training from NASFAA as well as internal training over the past two years. The Financial Aid Office will review existing procedures to identify areas of improvement, specifically, verification corrections within our SIS Colleague system and the FAFSA Partner Portals for the 24-25 and 25-26 award years. Furthermore, efforts are under way to hire additional staff to strengthen the breadth of available resources to meet compliance requirements.

View Audit 352065

Finding 551145 (2024-002)

Significant Deficiency 2024

Bergen Community College

NJ

Special Tests & Provisions Student Financial Aid Significant Deficiency

Views of Responsible Officials: The college agrees with this finding with explanation. These occurrences were anomalies related to a rare misalignment of the academic calendar for summer session for the 2023/2024 academic year. The calculation findings for five of the seven students were related to ...

Views of Responsible Officials: The college agrees with this finding with explanation. These occurrences were anomalies related to a rare misalignment of the academic calendar for summer session for the 2023/2024 academic year. The calculation findings for five of the seven students were related to a schedule misalignment for the summer semester. The academic calendar for the 2023/2024 award year had 106 days of enrollment during the summer semester. There was a gap of six days between the Summer 2 and Summer 3 terms skewed the calculations. The College has not identified a similar alignment gap for any previous award year. The Financial Aid Office will actively monitor the development of the academic calendar. Additionally, the Financial Office will review and revise existing procedures to identify areas for improvement to ensure that all withdrawn students who began attendance will have their Return to Title IV calculations accurately completed. The Financial Aid Office has taken steps to retrain relevant financial aid personnel and developed internal checks for accuracy in the calculation process.

View Audit 352065

Finding 551141 (2024-001)

Significant Deficiency 2024

Bergen Community College

NJ

Special Tests & Provisions Student Financial Aid Reporting

Views of Responsible Officials: The College has noted that this finding may not align with the unique nature of our summer session, which has three terms included. There are four non-standard summer terms that do not follow the same reporting structure as the Fall and Spring Terms. The College inter...

Views of Responsible Officials: The College has noted that this finding may not align with the unique nature of our summer session, which has three terms included. There are four non-standard summer terms that do not follow the same reporting structure as the Fall and Spring Terms. The College interprets the 60-day reporting requirement to apply to the standard terms for Fall and Spring only. Historically, the college has reported summer enrollments in August, which has been treated as compliant by the Clearinghouse. However, after further review, the College will adjust its reporting schedule to align with recommendations from this finding. This adjustment will ensure that summer reporting aligns with the 60-day timeframe that is consistent with the Fall and Spring terms.

View Audit 352065

Finding 551134 (2024-001)

Significant Deficiency 2024

Young at Heart Resources

MO

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

Agency Response: Currently, Young at Heart follows policies and procedures for holidays, week hours, etc. CEO and CFO are aware we must follow our policies. We have changed the work week policy and the holiday listings in our policies. Creating new policies was part of the corrective action plan wit...

Agency Response: Currently, Young at Heart follows policies and procedures for holidays, week hours, etc. CEO and CFO are aware we must follow our policies. We have changed the work week policy and the holiday listings in our policies. Creating new policies was part of the corrective action plan with the DHSS. The policies were created and approved by Young at Heart Board in July 2024. Employees work a 36 hour week and receive 13 paid holidays. The credit card procedure now is being followed as it should. This was also on the Correctve Action Plan with DHSS. Both the previous CEO (Michael Stopka) and CFO (Shari Harris) are no longer employed with the agency. When I started as CFO, the current interim CEO Freda Miller and I called the board chair regarding the personal charges by Michael Stopka on the corporate credit card. The board chair was unaware of this and would address the issue and make sure he not only didn’t use the card for personal charges but would not pay it online and bypass the internal control function of accounts payable and cash disbursements. The current procedure of all purchases must be approved by the CEO and CFO prior to purchase. Once the item is purchased, the receipt and the requisition is sent to the fiscal assistant who matches the receipts to the credit card bill. Once all items are accounted for, the fiscal assistant will cut a check. The check will then be signed by CEO and a board member. The credit card bill is no longer being paid on-line. I believe the internal control problems have been addressed both on the corrective action plan with MO DHSS and by current management. These items were corrected in July 2024 after M. Stopka & S. Harris had left the agency.

View Audit 352061

Finding 551133 (2024-009)

Material Weakness 2024

County of Solano

CA

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.303

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Foster Care Federal Assistance Listing Number: 93.658 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Allowable Activities and Allowed Costs Type ...

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Foster Care Federal Assistance Listing Number: 93.658 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Allowable Activities and Allowed Costs Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Views of Responsible Officials and Corrective Action Plan: Solano County has policies and procedures as well as systematic processes and oversight set up to ensure accurate assessments and determinations are made regarding the Federal or Non-Federal Eligibility of youth in the Foster Care system. It is Solano County’s policy to conduct these assessments at the onset of the case and ensure quality documentation. In addition, the Foster Care unit has a Lead worker and Supervisor who conduct periodic reviews of open cases to ensure accuracy of documentation and adherence to timelines are met. The specific corrective actions identified in this audit found errors related to the migration of data to the CalSAWS program in 2023, where an identified payment was incorrectly identified (Non-Federal to Federal) due to errors or information which existed in CalWin and were transferred improperly to CalSAWS. These conversion errors occurred automatically. As a result, the Foster Care Eligibility Unit has implemented the following changes. • Correction to identified payment: o The identified case was corrected immediately, and all payments adjusted as appropriate. • Changes to workflow to ensure accuracy: o The entire caseload of open Foster Care Eligibility cases will be reviewed to ensure that the original determination or as found in the FC3 or FC3A and granting comments, is correctly input in CalSAWS, and any payment errors corrected as needed. o The case aid code (noting eligibility type) will be included next to the youth’s name to ensure that it shows in the workload report in CalSAWS to ensure the information is easily accessible and any future errors can be identified. o Cases will be reviewed to ensure the above changes are completed through the unit supervisor’s ongoing qualitative review of cases. • The Foster Care Eligibility Supervisor will discuss the findings and requirement with subordinate staff in the following ways: o Unit meeting communication regarding Corrective Action findings and Agency steps to remediate. o Issue a reminder to all staff regarding the above remediation plan. Responsible Individual(s): Kim McDowell, Social Services Manager Neely McElroy, Deputy Director, Child Welfare Services Anticipated Completion Date: May 31, 2025

View Audit 352056 Questioned Costs: $1

Finding 551132 (2024-008)

Material Weakness 2024

County of Solano

CA

Questioned Costs Eligibility Material Weakness

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Foster Care Federal Assistance Listing Number: 93.658 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2023/24 Compliance Requirement: Eligibility Type of Finding: Material Weakness...

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Foster Care Federal Assistance Listing Number: 93.658 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2023/24 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Views of Responsible Officials and Corrective Action Plan: Solano County has policies and procedures as well as systematic processes and oversight set up to ensure accurate assessments and determinations are made regarding the Federal or Non-Federal Eligibility of youth in the Foster Care system. It is Solano County’s policy to conduct these assessments at the onset of the case and ensure quality documentation. In addition, the Foster Care unit has a Lead worker and Supervisor who conduct periodic reviews of open cases to ensure accuracy of documentation and adherence to timelines are met. The specific corrective actions identified in this audit found errors related to the migration of data to the CalSAWS program in 2023, where two cases were inadvertently converted from Non-Federal to Federal cases due to errors or information which existed in CalWin and were transferred improperly to CalSAWS. These conversion errors occurred automatically. As a result, the Foster Care Eligibility Unit has implemented the following changes. • Corrections to identified cases: o The two identified cases were corrected immediately, and all payments adjusted as appropriate. • Changes to workflow to ensure accuracy: o The entire caseload of open Foster Care Eligibility cases will be reviewed to ensure that the original determination or as found in the FC3 or FC3A and granting comments, is correctly input in CalSAWS, and any payment errors corrected as needed. o The case aid code (noting eligibility type) will be included next to the youth’s name to ensure that it shows in the workload report in CalSAWS to ensure the information is easily accessible and any future errors can be identified. o Cases will be reviewed to ensure the above changes are completed through the unit supervisor’s ongoing qualitative review of cases. • The Foster Care Eligibility Supervisor will discuss the findings and requirement with subordinate staff in the following ways: o Unit meeting communication regarding Corrective Action findings and Agency steps to remediate. o Issue a reminder to all staff regarding the above remediation plan. Responsible Individual(s): Kim McDowell, Social Services Manager Neely McElroy, Deputy Director, Child Welfare Services Anticipated Completion Date: May 31, 2025

View Audit 352056 Questioned Costs: $1

Finding 551122 (2024-001)

Significant Deficiency 2024

Molloy College

NY

Student Financial Aid Special Tests & Provisions Reporting

Name of contact person responsible for corrective action: Marguerite Lane, Associate Vice President Enrollment Management Mlane@molloy.edu 516-323-4014 Corrective action: Molloy University understands the finding and has devised a process to ensure that the correct withdrawal dat...

Name of contact person responsible for corrective action: Marguerite Lane, Associate Vice President Enrollment Management Mlane@molloy.edu 516-323-4014 Corrective action: Molloy University understands the finding and has devised a process to ensure that the correct withdrawal date is recorded National Student Loan Data System (NSLDS) with the 60-day window from the date of determination. In the finding, the withdrawals were reported within the window, but the effective dates reported were incorrect. We identified the issue and made the corrections, but the corrections were made outside the 60-day window. To address this, we will utilize our current practice of relying on error reports to address such errors, but we will run these reports at an increased frequency (bi-weekly) and have an additional staff member review the information. We will keep a file for each student withdrawal to show that our dates align in our system, the National Student Clearinghouse, and NSLDS within the required timeframe. Proposed Completion Date: March 31, 2025

View Audit 352050

Finding 551113 (2024-002)

Material Weakness 2024

City of Rancho Cordova

CA

Reporting Internal Control / Segregation of Duties § 200.303

Program/Cluster: Disaster Grants – Public Assistance Federal Financial Assistance Listing Number: 97.036 Federal Grantor: U.S. Department of Federal Emergency Management Agency Pass-through: California Governor’s Office of Emergency Services Award Year: 2024 Grant Award Number: FEMA-4683-DR-CA Comp...

Program/Cluster: Disaster Grants – Public Assistance Federal Financial Assistance Listing Number: 97.036 Federal Grantor: U.S. Department of Federal Emergency Management Agency Pass-through: California Governor’s Office of Emergency Services Award Year: 2024 Grant Award Number: FEMA-4683-DR-CA Compliance Requirement: P – Other Information Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The noncompliance resulted from staff managing these records not being fully aware of the FEMA program compliance supplement that states expenditures are to be reported on the SEFA once they are approved and obligated. The City of Rancho Cordova will implement the following corrective actions: • Ensure all relevant personnel within the city are aware of FEMA’s specific documentation requirements. • Review and revise internal procedures to strengthen controls over grant expenditures to include documentation that supports the status of FEMA’s review of the eligible project cost • Implement a tracking system to ensure all future expenditures have been both approved and obligated by FEMA prior to being included on the SEFA, regardless of the year in which the expenditure was incurred. These measures will ensure that all future costs claimed are allowable, approvals properly supported, and in full compliance with FEMA regulations. Name of Responsible Person: Kim Juran, Administrative Services Director Projected Implementation Date: January 1, 2025

View Audit 352034

Finding 551112 (2024-001)

None 2024

Conservatorio De Musica De Puerto Rico

PR

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.510

Management is implementing enhanced controls and formal procedures to ensure that all funding sources, particularly those received through intermediary or passthroughentities, are correctly identified and appropriately classified for reporting. These measures include: - Expanding documentation reque...

Management is implementing enhanced controls and formal procedures to ensure that all funding sources, particularly those received through intermediary or passthroughentities, are correctly identified and appropriately classified for reporting. These measures include: - Expanding documentation requests to verify funding sources. - Maintaining ongoing dialogue with pass-through entities to confirm federal assistance classifications.

View Audit 352031

Finding 551106 (2024-014)

Material Weakness 2024

William Peace Universirty

NC

Student Financial Aid Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate...

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has expanded staffing and continues to provide ongoing training through NASFAA, NCASFAA, CFNC, and Ellucian. Roles and responsibilities are now clearly defined to ensure proper segregation of duties, and cross-training is underway to provide continuity during vacancies. These efforts support the implementation of enhanced internal controls and Title IV compliance. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025

View Audit 352022

Finding 551105 (2024-013)

Significant Deficiency 2024

William Peace Universirty

NC

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

Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a proc...

Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: The University should ensure all necessary employees receive proper training, support, and time to follow the University’s policies and federal requirements related to monthly reconciliations. There should be a process to maintain all reconciliations as support of performance monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office will complete monthly reconciliations in addition to the reconciliation at the time of draw of federal funds to comply with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Belinda Burke, VP for Finance and Administration, CFO Planned completion date for corrective action plan: April 2025

View Audit 352022

Finding 551103 (2024-012)

Significant Deficiency 2024

William Peace Universirty

NC

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no...

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and policies around reporting to the COD to ensure that student information is reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Department will evaluate its policies and procedures around reporting to the COD to ensure that student information is reported timely. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: April 2025

View Audit 352022

Finding 551099 (2024-011)

Significant Deficiency 2024

William Peace Universirty

NC

Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007,84.033 Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained as well as maintained in student files. Explanati...

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007,84.033 Recommendation: The University should review the procedures surrounding the verification process to ensure all necessary support and documentation is obtained as well as maintained in student files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has added personnel and implemented an electronic document management system. All verification documentation is now scanned and maintained within each student’s electronic file to ensure accuracy, completeness, and audit readiness. Staff continue to receive regular training on verification protocols. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: April 2025

View Audit 352022

Finding 551098 (2024-010)

Material Weakness 2024

William Peace Universirty

NC

Student Financial Aid Eligibility Material Weakness

Student Financial Assistance Cluster - Assistance Listing No. No. 84.268 Recommendation: We recommend the University review its process around sending exit counseling information to students to ensure this information is received and the University is performing required procedures. Explanation of d...

Student Financial Assistance Cluster - Assistance Listing No. No. 84.268 Recommendation: We recommend the University review its process around sending exit counseling information to students to ensure this information is received and the University is performing required procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has hired additional staff, enhanced training efforts, and established a standard procedure to send loan exit counseling notifications to students at the end of each term, ensuring regulatory compliance. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025

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Finding 551097 (2024-009)

Significant Deficiency 2024

William Peace Universirty

NC

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster - Assistance Listing No. No. 84.063 Recommendation: We recommend the University implement a review process to ensure calculations of Pell awards are using the correct information. Explanation of disagreement with audit finding: There is no disagreement with the a...

Student Financial Assistance Cluster - Assistance Listing No. No. 84.063 Recommendation: We recommend the University implement a review process to ensure calculations of Pell awards are using the correct information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To reduce calculation errors in Pell Grant awards, the Financial Aid Office has hired additional staff, increased training, and implemented an automated packaging system. This system ensures Pell award amounts are calculated using accurate and verified student information. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: August 2025

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Finding 551093 (2024-007)

Significant Deficiency 2024

William Peace Universirty

NC

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Explanation of disagreement with audit finding: There is no disagree...

Student Financial Assistance Cluster - Assistance Listing No. 84.268 Recommendation: We recommend the University establish additional policies to ensure all students meet the financial need criteria before awarding Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office has hired additional personnel to enhance oversight and processing capacity. Staff will continue to receive training and will review all late and supplemental awards to verify that students meet financial need criteria before Title IV funds are disbursed. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: June 2025

View Audit 352022 Questioned Costs: $1

Finding 551091 (2024-006)

Significant Deficiency 2024

William Peace Universirty

NC

Reporting Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Explanation of...

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review regulations to ensure the University understands the definitions for enrollment information required to be reported to the NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Given the findings related to enrollment reporting, the University will review policies and procedures to ensure information is reported in a timely and accurate manner. The University will review the NSLDS regulations and ensure understanding and compliance of the NSLDS definitions related to required reporting of enrollment changes. The University will verify program lengths for all active programs reported to NSLDS. The Registrar is the responsible party for enrollment reporting via NSC to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Lynda Szymanski, VP for Academic Affairs Planned completion date for corrective action plan: April 2025

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Finding 551087 (2024-005)

Significant Deficiency 2024

William Peace Universirty

NC

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

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. Explanation ...

Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the University review the R2T4 requirements and ensure their process incorporates a review of students to ensure no calculations are missed that should be performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: At the conclusion of each academic term, the Director of Financial Aid will review enrollment data with the Registrar’s Office to identify students who may require Return of Title IV (R2T4) calculations. Completion of all required R2T4 calculations will be documented and verified by the Director to ensure full compliance with federal guidelines. Name(s) of the contact person(s) responsible for corrective action: Damon Wade, VP for Enrollment Management and Marketing Planned completion date for corrective action plan: May 2025

View Audit 352022

Corrective Action Plans

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