Corrective Action Plans

Finding 516398 (2024-005)

None 2024

TX

Reporting Internal Control / Segregation of Duties

Inaccurate TRIO Reporting Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.042A Finding Summary: Certain line items of the Annual Performance Report (APR) included inaccurate student information. Responsible Individuals: Jessica Thomp...

Inaccurate TRIO Reporting Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.042A Finding Summary: Certain line items of the Annual Performance Report (APR) included inaccurate student information. Responsible Individuals: Jessica Thompson, TRIO Project Director Corrective Action Plan: We agree with the auditors’ findings and recommendations. Previously, a spreadsheet was used to maintain student information for input in the APR. To ensure the most up to date information is used, this student information will now be input using the university student services account system. Additionally, the APR will be reviewed by the finance department prior to submission. Anticipated Completion Date: December 31, 2024

View Audit 334328

Finding 516386 (2024-006)

Significant Deficiency 2024

Clatsop Community College

OR

Cash Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are no...

Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are no longer using a Tier One processor for our financial aid refunds. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Implemented July 2024 when we changed from Bank Mobile to TouchNet.

View Audit 334325

Finding 516382 (2024-005)

Material Weakness 2024

Clatsop Community College

OR

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

Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are wo...

Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are working on an updated WISP and plan to have it approved by college administration prior to the end of the academic year. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: 6/30/2025

View Audit 334325

Finding 516374 (2024-003)

Material Weakness 2024

Clatsop Community College

OR

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

Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action t...

Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented a plan to review monthly each outstanding check to ensure that all funds are returned to the Federal programs if appropriate. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Implemented in September 2024

View Audit 334325

Finding 516371 (2024-001)

Significant Deficiency 2024

Clatsop Community College

OR

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking § 200.303

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal...

Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented the auditor’s recommendation and thoroughly tested award rounding in the new SIS. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024

View Audit 334325

Finding 516363 (2024-001)

Significant Deficiency 2024

Keokuk County, Iowa

IA

Internal Control / Segregation of Duties

Segregation of Duties Name of Contact Person - Christy Bates, County Auditor Corrective Action - The duties will be separated as much as possible and alternative controls will be considered to...

Segregation of Duties Name of Contact Person - Christy Bates, County Auditor Corrective Action - The duties will be separated as much as possible and alternative controls will be considered to compensate for lack of separation. Proposed Completion Date - Ongoing.

View Audit 334234

Finding 516320 (2024-001)

Material Weakness 2024

Davinci Academy of Science and the Arts

UT

Material Weakness Reporting Internal Control / Segregation of Duties

Finding Summary: DaVinci Academy of Science and the Arts is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of ...

Finding Summary: DaVinci Academy of Science and the Arts is required to submit an annual performance report to the State of Utah detailing GEER and ESSER expenditures by subgrant fund, expenditure category, object code, number of specific positions supported with GEER and ESSER funds, allocation of GEER and ESSER funds and criteria used and number of full-time equivalent positions for all GEER & ESSER funds received from the USBE during the period of July 1, 2022 to June 30, 2023. DaVinci Academy of Science and the Arts did not properly report the correct amount of all ESSER funds expended. Responsible Individuals: Business Manager and Executive Director Corrective Action Plan: Management will provide the USBE with the correct the amount of all ESSER funds expended. Anticipated Completion Date: Ongoing Anticipated Completion Date: Management will ensure all necessary corrective action plan items are in place by the end of the next reporting period.

View Audit 334150

Finding 516274 (2024-002)

Material Weakness 2024

Western Oregon University

OR

Special Tests & Provisions Material Weakness Matching / Level of Effort / Earmarking

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Each month, the Common Origination and Disbursement (COD) system provides institutions...

Finding: 2024-002 Federal Agency Name: U.S. Department of Education Assistance Listing Number(s): 84.007, 84.033, 84.038, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: Each month, the Common Origination and Disbursement (COD) system provides institutions with a School Account Statement (SAS) data file which consists of a Cash Summary, Cash Detail, and (optional at the request of the institution) Loan Detail records. The institution is required to reconcile these files to the institution’s financial records. As a result of implementing a new Student Information System, the SAS reconciliations were not completed during the current year. Responsible Individuals: Kella Helyer, Director of Financial Aid Corrective Action Plan: Management agrees with this finding. Compliance on this finding was resolved by the end of the award year with reconciliation being completed by the end of June 2024. Financial aid implemented a new Financial Aid Management System (FAMS) starting with the 2023-24 year which caused delays in processes; however, the office is caught up with reconciliations, and going forward this compliance area is not an issue. Anticipated Completion Date: Completed June 2024

View Audit 334105

Finding 516273 (2024-002)

Significant Deficiency 2024

Anne Arundel County Board of Education

MD

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2024-002 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-...

2024-002 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: None Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211837-01 Award Period: 3/3/2021 – 12/31/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that the Board continue with established policies and procedures implemented in November 2023 to ensure that documentation supporting the Board’s review and approval of the monthly FSR reimbursement requests are retained for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Reporting and Grants Management will ensure that the Board’s review and approval of monthly FSR reimbursement requests and documented and retained. Name(s) of the contact person(s) responsible for corrective action: Ruth Grasty Director of Financial Reporting and Grants Management Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 334095

Finding 516255 (2024-001)

Significant Deficiency 2024

Wingate University

NC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Maria Taylor, Registrar & Jenn Hall, Director of Financial Aid Corrective Action: It was identified during the Student Financial Aid audit that Wingate University (WU) is out of compliance with the enrollment reporting requirements for two students (one student at th...

Name of Responsible Individual: Maria Taylor, Registrar & Jenn Hall, Director of Financial Aid Corrective Action: It was identified during the Student Financial Aid audit that Wingate University (WU) is out of compliance with the enrollment reporting requirements for two students (one student at the campus level and one student at both the campus level and program level). We currently contract with the National Student Clearinghouse (NSC) for enrollment reporting and have identified the compliance issue to be a disconnect between the reporting requirements in place with NSC and WU Institutional policy. For each identified student, the student was permitted by WU policy to complete their degree requirements after the end of the academic term. When reporting the Graduated status in NSC, the Registrar is required to select the last date of the term as the Graduation Date instead of the date the student actually completed their degree requirements. When this occurs more than 60 days from the end of the term, the student is noted as out of compliance with reporting requirements due to the limitation identified with NSC. The Registrar and Director of Financial Aid will work with NSC to identify a solution for reporting the actual completion date for a student when it occurs after the conclusion of the standard term and outside of the reporting definitions offered by NSC. If a viable solution cannot be identified with NSC, we will establish a policy to manually update data in NSLDS for impacted students to meet the 60-day reporting requirements for enrollment status changes. Anticipated Completion Date: May 31, 2025

View Audit 334066

Finding 516254 (2024-003)

Significant Deficiency 2024

City of Three Rivers, Michigan

MI

Internal Control / Segregation of Duties Reporting Significant Deficiency

2024-003 - Reporting U.S. Department of Housing and Urban Development – American Rescue Plan Act - MI Hope Grant (ALN 21.027); Passed through the Michigan State Housing Development Authority; All project numbers. Auditor Description of Condition and Effect. During our audit procedures over the Cit...

2024-003 - Reporting U.S. Department of Housing and Urban Development – American Rescue Plan Act - MI Hope Grant (ALN 21.027); Passed through the Michigan State Housing Development Authority; All project numbers. Auditor Description of Condition and Effect. During our audit procedures over the City's reporting process, we noted that there were discrepancies in the expenditures that were stated on the reports compared to the schedule of federal expenditures and the underlying accounting records. The City followed grant requirements to complete the financial, performance and compliance reporting as required by Treasury, however, the reports were inaccurate. Auditor Recommendation. We recommend that the City review reports submitted to ensure they are accurate. Corrective Action. The Finance Director will review all financial documents before they are submitted to outside agencies to ensure accuracy. Responsible Person: Bobbi Schoon, Director of Finance and Administration

View Audit 334063

Finding 516248 (2024-006)

Significant Deficiency 2024

School District of Cadott Community

WI

Reporting Significant Deficiency Internal Control / Segregation of Duties

The District has asked CESA 10 to send the Medicaid claims prior to submission to the District for approval. The District will have a staff member review the salary and fringe information provided to CESA 10.

View Audit 334049

Finding 516244 (2024-005)

Significant Deficiency 2024

School District of Cadott Community

WI

Internal Control / Segregation of Duties Reporting Significant Deficiency

Due to its size, it is not cost effective to hire additional staff to complete necessary reporting. Reviews and checks have been put into place prior to claim submissions with existing staff members.

View Audit 334049

Finding 516242 (2024-003)

Material Weakness 2024

School District of Cadott Community

WI

Questioned Costs Special Tests & Provisions Procurement, Suspension & Debarment § 200.326

The District is in the process of developing a procurement policy, including prevailing wage rate requirements and will ensure that subcontractors meet the requirements.

View Audit 334049 Questioned Costs: $1

Finding 516237 (2024-002)

None 2024

Marissa Community Unit School District No. 40

IL

Reporting Internal Control / Segregation of Duties

Condition: Expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to...

Condition: Expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to file all quarterly expenditure reports on time in the future.

View Audit 334048

Finding 516225 (2024-008)

Significant Deficiency 2024

Marissa Community Unit School District No. 40

IL

Reporting Internal Control / Segregation of Duties

Condition: Expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to...

Condition: Expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to file all quarterly expenditure reports on time in the future.

View Audit 334048

Finding 516224 (2024-002)

Significant Deficiency 2024

Community Unit School District No. 196

IL

Reporting Internal Control / Segregation of Duties

Condition: Expenditure reports for the ESF - Post Secondary Success grant were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management's Response...

Condition: Expenditure reports for the ESF - Post Secondary Success grant were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management's Response: Management will take the necessary steps to file all quarterly expenditure reports on time in the future.

View Audit 334032

Finding 516216 (2024-001)

Significant Deficiency 2024

Yadkin County

NC

Eligibility Reporting Internal Control / Segregation of Duties

Finding: 2024-001 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2024-002 Name of contact person: Corrective Action: Proposed Completion Date: Corrective Action Plan For the Year Ended June 30, 2024 Section II - Financial Statement Findings Section III - Federal Award ...

Finding: 2024-001 Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2024-002 Name of contact person: Corrective Action: Proposed Completion Date: Corrective Action Plan For the Year Ended June 30, 2024 Section II - Financial Statement Findings Section III - Federal Award Findings and Questioned Costs Jessica Wall, Director YCHSA will inititate income calculation quizzes for staff following training to ensure understanding of training around this finding. YCHSA will continue second party at least 76 Medicaid cases per quarter and will do a targeted second party review of an additional 50 cases to verify appropriate income calculations and household members. YCHSA will implement a checklist to be used prior to eligibility decision for applications and recerts that would ensure that determinations in the case and correct outcomes. YCHSA will develop a shared training platform that will include powerpoint presentations and handouts around the areas of accurate information entry. Calculation quizzes will be in use by November 30, 2024. Checklist will be developed and implemented by 11/18/24. YCHSA will complete an additional targeted review of at least 50 cases per quarter beginning with Quarter 2 of Fiscal Year 2025. YCHSA will develop shared training platform with the expectation that staff will have completed at least one module by 11/30/24. Jessica Wall, Director YCHSA will continue second party at least 76 Medicaid cases per quarter and will do a targeted second party review of an additional 15 cases to verify appropriate resource entry. YCHSA will implement a checklist to be used prior to eligibility decision for applications and recertifications that would ensure that appropriate resources have been entered and evaluated. YCHSA will develop a shared training platform that will include powerpoint presentations and handouts around the areas of accurate resource entry. Checklist will be developed and implemented by 11/18/24. YCHSA will complete an additional targeted review of at least 15 cases per quarter beginning with Quarter 2 of Fiscal Year 2025. YCHSA will develop shared training platform with the expectation that staff will have completed at least one module by 11/30/24.

View Audit 334031

Finding 516162 (2024-001)

Significant Deficiency 2024

Seneca Housing Corporation

SC

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Finding #2024-001: Comments on the Finding and Each Recommendation: During the year ended September 30, 2024, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Management should transfer $950 from the operating account to the reserve for replacements a...

Finding #2024-001: Comments on the Finding and Each Recommendation: During the year ended September 30, 2024, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Management should transfer $950 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation.

View Audit 334001 Questioned Costs: $1

Finding 516152 (2024-002)

Significant Deficiency 2024

Ramona Unified School District

CA

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

The District will enhance internal controls to provide reasonable assurance that all personnel expenses charged to federal awards are accurately documented and approved. This will involve implementing a systematic internal review process for time and effort reporting. The process will include regula...

The District will enhance internal controls to provide reasonable assurance that all personnel expenses charged to federal awards are accurately documented and approved. This will involve implementing a systematic internal review process for time and effort reporting. The process will include regular checks and approvals by supervisory personnel to ensure that all charges are properly allocated and compliant with established accounting policies. Additionally, the District will integrate these reviews into the official records of the District, ensuring that all activities compensated by the District are accurately reflected. To support this, the District will provide training for staff on the updated procedures and the importance of maintaining accurate records for personnel expenses charged to federal awards. Furthermore, the District will conduct periodic internal audits to monitor compliance with the updated procedures and identify any areas for improvement These audits will help ensure that all documentation of personnel expenses meets the standards required by federal regulations. The actions to remedy this finding are currently in effect as of December 11, 2024.

View Audit 333979

Finding 516145 (2024-002)

Significant Deficiency 2024

Riverside Community College District

CA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Views of Responsible Officials and Corrective Action Plan The College, with support from the District, will implement an annual review of compliance requirements and training for all staff associated with Return to Title IV calculation requirements to ensure that the data utilized in preparing the c...

Views of Responsible Officials and Corrective Action Plan The College, with support from the District, will implement an annual review of compliance requirements and training for all staff associated with Return to Title IV calculation requirements to ensure that the data utilized in preparing the calculation is accurate and that the College’s procedures are in line with compliance requirements of the program. Norco College Student Financial Services reviewed the workflow of Return to Title IV to enhance implementational procedures and regulatory compliance of this process. This will ensure that student withdrawal calculations are performed accurately and occur in a timely manner based on the District’s schedule of specific dates for each term of when calculations are completed. The purpose of these efforts is to meet compliance requirements as they are related to Return to Title IV. There was also staff turnover during the 2023-24 award year resulting in inconsistent procedures causing the two incorrect calculations and the lack of notification to the student of their eligible post withdrawal disbursement. An Assistant Director position was approved and filled as of May 2024. The Assistant Director takes an active role to ensure federal guidelines are adhered to, completes thorough training on a regular basis, and all calculations are reviewed for accuracy.

View Audit 333977

Finding 516138 (2024-001)

Significant Deficiency 2024

Riverside Community College District

CA

Student Financial Aid Eligibility Significant Deficiency

Views of Responsible Officials and Corrective Action Plan The College, with support from the District, will implement an annual review of compliance requirements and training for all staff associated with eligibility requirements for calculated disbursements amounts to ensure accuracy. Norco College...

Views of Responsible Officials and Corrective Action Plan The College, with support from the District, will implement an annual review of compliance requirements and training for all staff associated with eligibility requirements for calculated disbursements amounts to ensure accuracy. Norco College Student Financial Services reviewed the workflow and processing procedures of flagging student files in a timely manner for those that qualify for the additional Pell indicator. The intention of these efforts is to meet regulatory compliance requirements as they are related to student Pell eligibility when awarding and packaging students for additional Pell. There was staff turnover during the 2023-24 award year resulting in procedures misunderstood and not followed consistently which caused the student to not be flagged at the appropriate time in the awarding and disbursement process. An Assistant Director position was approved and filled as of May 2024. The Assistant Director is responsible for Pell grant payment oversight during the authorization and approval of the institution’s monthly disbursement process to ensure federal guidelines are adhered to. The Assistant Director has completed thorough training regarding the disbursement process and Pell eligibility. Additionally, training is conducted on a regular basis to review student Pell disbursement eligibility for accuracy.

View Audit 333977

Finding 516128 (2024-003)

Significant Deficiency 2024

Somerset School District

WI

Internal Control / Segregation of Duties Reporting Significant Deficiency

The district will update procedures to include review of the Quarterly Financial Summary reports by someone other than the preparer of the reports prior to submission. Review will be documented.

View Audit 333965

Finding 516117 (2024-004)

None 2024

University of Hawaii

HI

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

Finding No. 2024-004: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Jeff Anderson, Financial Aid Director Date Action Taken: November 14, 2024 ...

Finding No. 2024-004: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Jeff Anderson, Financial Aid Director Date Action Taken: November 14, 2024 The institution was unable to perform exit counseling to the borrower in a timely manner due to competing priorities of the program staff at the time. To ensure these can be done within the given timeframe the financial aid team will re-visit processes as well as provide training to new staff as they are onboarded to ensure back plans are in place in the event that key personnel are out of the office during this timeframe.

View Audit 333933

Finding 516116 (2024-003)

None 2024

University of Hawaii

HI

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

Finding No. 2024-003: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Anna Chamberlain, Financial Aid Director Date Action Taken: November 14, 20...

Finding No. 2024-003: Financial Aid Administration - Control Deficiency Federal Agency: U.S. Department of Education CFDA Number and Title: 84.268 – Federal Direct Student Loans Questioned Costs: $ - Responsible Individual: Anna Chamberlain, Financial Aid Director Date Action Taken: November 14, 2024 Loan exit was not conducted within 30 days because of staffing and training issues. The Financial Aid Office now has adequate staff trained to review and perform loan exit counseling as required. The office has also developed written instructions for training in the event of turnover.

View Audit 333933

Corrective Action Plans

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