Corrective Action Plans

Finding 512235 (2024-002)

Significant Deficiency 2024

IN

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

Recommendation: We recommend the Office of Financial Aid utilize their financial aid processing software to implement disbursement notifications which include all information required by (34 CFR Section 668.165(a)(2) to be sent electronically to students once disbursements are posted. Explanation of...

Recommendation: We recommend the Office of Financial Aid utilize their financial aid processing software to implement disbursement notifications which include all information required by (34 CFR Section 668.165(a)(2) to be sent electronically to students once disbursements are posted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: The Office of Financial Aid and Scholarships drafted a letter using best practices laid out by NAFSAA which includes all information required by 34 CFR Section 668.165. The System Specialist, who is responsible for disbursing aid, has created documentation that has been added to the disbursement process. Once a disbursement is complete, the System Specialist will run the process in PowerFAIDS that will send the Loan Disbursement Notification via email to students who have received loans. This includes students who have received Federal Direct Subsidized, Unsubsidized, Parent PLUS, Grad PLUS, and private loans. This process is updated and is now in place. Name of Contact Responsible for Corrective Action: David J. Sarah, Director of Financial Aid, 765.641.4110 Anticipated Completion Date: August 2024

View Audit 330010

Finding 512233 (2024-001)

Material Weakness 2024

Anderson University and Subsidiaries

IN

Questioned Costs Student Financial Aid Special Tests & Provisions

Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such a process can operate effectively and achieve compliance. We also recommend the University implement ...

Recommendation: We recommend an individual in financial aid with the appropriate level of experience periodically review R2T4 calculations and returns to help ensure that internal controls over such a process can operate effectively and achieve compliance. We also recommend the University implement controls to track and remind when returns need to be returned once the withdrawal determination has been made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Corrective Action Planned: ● Moving forward, for each year, when the academic calendar is released prior to the beginning of the fall semester, The Office of Financial Aid and Scholarships will immediately determine the dates and number of days used for the R2T4 calculations. ● The Senior Financial Aid Counselor within the Office of Financial Aid and Scholarships, who is responsible for preparing the R2T4 calculations, has enrolled for R2T4 training from NASFAA, which takes place starting on September 3, 2024. The Senior Financial Aid Counselor will also complete a PowerFAIDS training on the R2T4 process within the system. ● The Systems Specialist within the Office of Financial Aid and Scholarships will also be trained on the R2T4 process to provide quality control for the senior financial aid counselor and to ensure we are cross-trained within the Office of Financial Aid. With two individuals working to keep each other accountable, we will be able to avoid similar issues in the future. The Systems Specialist will also complete the NASFAA and PowerFAIDS training. ● All R2T4s will be tracked on a shared file starting in the Fall 2024. The Senior Financial Aid Counselor, Systems Specialist, and Director of Financial Aid will have access to the file for review and quality control. ● The Systems Specialist and Director of Financial Aid will be added to the student withdrawal form workflow through Etrieve. This team of three will all receive a notification when a student withdrawal needs to be processed. ● The Director of Financial Aid will check at least weekly on the shared R2T4 file and will monitor the dates and timelines to ensure calculations are completed within the timeframe allowed. Name of Contact Responsible for Corrective Action: David J. Sarah, Director of Financial Aid, 765.641.4110 Anticipated Completion Date: September 2024

View Audit 330010 Questioned Costs: $1

Finding 512229 (2024-001)

Material Weakness 2024

Goodwill Industries of Upstate/midlands South Carolina, Inc.

SC

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

Contact Person: Andretta Robinson Management’s Response: The Organization staff will conduct review dates to ensure the In-Kind tracker is accurately updated with current wage information and that all supporting documentation for those wages have been submitted. Monitoring staff will randomly select...

Contact Person: Andretta Robinson Management’s Response: The Organization staff will conduct review dates to ensure the In-Kind tracker is accurately updated with current wage information and that all supporting documentation for those wages have been submitted. Monitoring staff will randomly select at least 20 entries for auditing, cross-referencing them with the documentation to verify accuracy. Completion Date: 6/28/2025

View Audit 329994

Finding 512207 (2024-001)

Significant Deficiency 2024

Texas Wesleyan University

TX

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding: 2024-001 R2T4 Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: November 30, 2024 With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The Universi...

Finding: 2024-001 R2T4 Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: November 30, 2024 With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 3. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 4. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 5. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

View Audit 329972

Finding 512130 (2024-005)

Significant Deficiency 2024

Connors State College

OK

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Student Financial Assistance Cluster- Assistance Listing No. 84.063, Finding: The College under-awarded funds for the Pell Grant. Context: During our testing, we identified 2 out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment s...

Student Financial Assistance Cluster- Assistance Listing No. 84.063, Finding: The College under-awarded funds for the Pell Grant. Context: During our testing, we identified 2 out of 40 students were awarded and disbursed less Pell funds than should have been awarded based on the 23-24 Pell payment schedule. The Pell payment schedule considers the cost of attendance, the student's Expected Family Contribution and the enrollment status of the student. Cause: Student was initially not disbursed Pell funds due to electronic terms & conditions not being completed. However, when the student completed this requirement in the Spring, Pell was not disbursed for the Fall semester Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed 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: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge procedures and knowledge will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024

View Audit 329878 Questioned Costs: $1

Finding 512118 (2024-001)

Significant Deficiency 2024

Connors State College

OK

Questioned Costs Student Financial Aid Significant Deficiency § 200.303

Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Finding: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculations and did not have formal procedures in place to document review of calculations. Context: During ...

Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Finding: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculations and did not have formal procedures in place to document review of calculations. Context: During our testing, we identified 2 out of 15 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, during our testing, we identified 13 instances of no documentation of a formal review of R2T4 calculations. Cause: The College was using the date a withdrawal form was processed, rather than the date the withdrawal process began. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff will review policies and procedures and make adjustments as needed to ensure that the calculations are accurate. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024

View Audit 329878 Questioned Costs: $1

Finding 512117 (2024-001)

Material Weakness 2024

Mana Academy

UT

Material Weakness Reporting Internal Control / Segregation of Duties

Management will provide the USBE with the correct the amount of ESSER funds expended by FTE categories, the number of FTE’s supported with ESSER funds and the total number of FTE positions on September 30, 2023.

View Audit 329874

Finding 512113 (2024-002)

Significant Deficiency 2024

Lutheran Social Services of South Dakota

SD

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance - State Administered Programs Reporting Finding Summary: The FFATA report filed for Huron School District included the incorrect Subaward Obligation/Action Da...

Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance - State Administered Programs Reporting Finding Summary: The FFATA report filed for Huron School District included the incorrect Subaward Obligation/Action Date within the FFATA Subaward Reporting System. Corrective Action Plan: FFATA reporting requirements were reviewed after the 2023 single audit report was received to ensure management has the correct understanding of reporting terms. The report in question was prepared and filed during July 2023 which was prior to the 2023 single audit report being finalized. FFATA reports filed during April 2024 and May 2024 were properly filed. Responsible Individuals: Nathan Beyer, Emily Lyons Anticipated Completion Date: December 31, 2023

View Audit 329857

Finding 512071 (2024-003)

Significant Deficiency 2024

Eastern Oregon University

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored. Explanation of disagreement with audit finding: There ...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend the University enhance procedures for reviewing professional judgement to ensure documentation of review is stored. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office (FAO) plans to do more expansive training for the Financial Aid Administrators upon hire. FAO is exploring the option of National Association of Student Financial Aid Administrators training certification for a Professional Judgment credential. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert Planned completion date for corrective action plan: February 28, 2025

View Audit 329796

Finding 512059 (2024-003)

Significant Deficiency 2024

Bradley University

IN

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

2024-003: U.S. Department of Education. Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program). Criteria or specific requirement: The G...

2024-003: U.S. Department of Education. Assistance Listing Number: 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program). Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). The Code of Federal Regulations 2 CFR 200.303 requires the University to establish and maintain effective internal controls over Federal awards. Context: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Cause: The University has continued to make progress in updating the University’s written security program to become in compliance with all requirements; however, due to capacity and demands on the information technology individuals, this is still a work in process. Recommendation: We recommend the University work to update the written security program to ensure compliance with all the standards. Views of responsible officials: There is no disagreement with the audit finding.

View Audit 329791

Finding 512057 (2024-002)

Significant Deficiency 2024

Bradley University

IN

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

2024-002: U.S. Department of Education. Assistance Listing Numbers: 84.063 - Federal Pell Grant Program, 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes ...

2024-002: U.S. Department of Education. Assistance Listing Numbers: 84.063 - Federal Pell Grant Program, 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

View Audit 329791

Finding 512056 (2024-001)

Significant Deficiency 2024

Bradley University

IN

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

2024-001: Student Financial Assistance Cluster. Assistance Listing Number: 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.16 states whenever an institution di...

2024-001: Student Financial Assistance Cluster. Assistance Listing Number: 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.16 states whenever an institution disburses FWS funds by crediting a student's account and the result is a credit balance, the institution must pay the credit balance directly to the student as soon as possible, but no later than 14 days after the credit balance occurred on the account. Cause: The student's refund was set to be sent out on but it fell on Labor day it didn't get sent out until after the 14 days. Effect: The University is not in compliance with Department of Education requirements that all credit balances be paid directly to the student as soon as possible, but no later than 14 days after the credit balance occurred. Recommendation: We recommend the University implement a process to ensure that any credit balances arising from federal student financial aid are made within the 14 day time limit imposed by the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

View Audit 329791

Finding 511980 (2024-001)

Material Weakness 2024

Cornbelt Educational Cooperative

SD

Internal Control / Segregation of Duties Material Weakness

The Cornbelt Educational Cooperative Business Manager, Pamela Selken is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number of staff employed in the Cooperative's business office. Staffing the office at an efficient and financia...

The Cornbelt Educational Cooperative Business Manager, Pamela Selken is the contact person responsible for the corrective action plan for this finding. This finding is due to the limited number of staff employed in the Cooperative's business office. Staffing the office at an efficient and financially feasible level precludes the hiring of enough personnel to provide an ideal environment for the internal controls. We are aware of the weakness in internal controls and will continue to develop policies and procedures and provide compensating controls to reduce the risk. We will also communicate this concern with our Board of Directors. The Cornbelt Educational Cooperative did adopt an Internal Controls and Procedures policy on March 13th, 2018 that does address many of these issues, and would ask for consideration reflecting this implementation. This finding will be an ongoing process, requiring continued analysis of processes and procedures in order to minimize the risk.

View Audit 329740

Finding 511958 (2024-001)

Significant Deficiency 2024

Westminster University

UT

Student Financial Aid Reporting Significant Deficiency

Westminster University is deeply committed to supporting its students and ensuring compliance with the requirements of the Student Financial Assistance Cluster. We appreciate the feedback provided in the Schedule of Findings and Questioned Costs and have taken action to address the concern raised. O...

Westminster University is deeply committed to supporting its students and ensuring compliance with the requirements of the Student Financial Assistance Cluster. We appreciate the feedback provided in the Schedule of Findings and Questioned Costs and have taken action to address the concern raised. Our institution is dedicated to continuous improvement in both our financial aid processes and overall student support services. We have developed an action plan to address the issue identified: FINDING 2024‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a policy to ensure address changes for all semesters are reported timely. Response: There is no disagreement with this audit finding. Action Taken in Response to Finding: Based upon the definition provided of Section 34 CFR Section 685.309(b) (2), it is our understanding that we are required to report address changes only on enrolled students through the period where they are marked as either (W) Withdrawn or (G) Graduated status. Our policy is to report students’ most current home address with each enrollment submission a minimum of 14 dates per year (three of which are only for graduated students) which ensures compliance with the 60-day threshold. However, our current practices have not always ensured that the current main home address was the one supplied to the National Student Clearinghouse. We will immediately implement processes to ensure that the main home address is the one sent to the National Student Clearinghouse. We consider this to be remediated. Contact Person(s): Karen Henriquez, Director of Financial Aid

View Audit 329674

Finding 511953 (2024-004)

Significant Deficiency 2024

Summit Academy Oic

MN

Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend the Academy implement MFA for individuals that access sensitive information per GLBA requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Though this finding is noted as a repe...

Recommendation: We recommend the Academy implement MFA for individuals that access sensitive information per GLBA requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Though this finding is noted as a repeat finding, I would point out that it is only the one of the eight of the safeguard elements of GLBA, the Two-Factor authentication, that was out of compliance, not the entire array of elements of GLBA. That said, Summit agrees with the finding and has implemented two-factor authentication for staff that accesses its student database. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO Planned completion date for corrective action plan: Fall 2024

View Audit 329672

Finding 511947 (2024-002)

Significant Deficiency 2024

Summit Academy Oic

MN

Student Financial Aid Reporting Significant Deficiency

Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with...

Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since the audit, Summit Academy has determined a new process in which we certify and make changes to the enrollment data found in NSLDS. Moving forward, the Financial Aid Manager will be assigned tasks within our operating system (Anthology) that will notify her of any students who withdrawal, go on a leave of absence, changed their enrollment intensity or graduate. The Financial Aid Manager will check this daily and update the students NSLDS enrollment data accordingly. The Financial Aid Manager will also keep a spreadsheet detailing the students name and the dates each student was certified. The Financial Aid Manager will also work closely with the Registrar’s Department to ensure the graduation and withdrawal lists are accurate. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO Planned completion date for corrective action plan: Fall 2024

View Audit 329672

Finding 511944 (2024-001)

Significant Deficiency 2024

Summit Academy Oic

MN

Reporting Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with th...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Summit has created a new process that includes duplicated training and support with the Financial Aid Manager and the Chief Financial Officer for ongoing monitoring and maintenance of the organization’s ECAR. The Financial Aid Manager and the CFO have a list of the listed Officers on the ECAR. In the event of any changes in staffing, including the listed officer and Financial Aid positions, those changes will be reported up through the ECAR by the Financial Aid Manager or, in the event that the Financial Aid Manager is part of the change, the reporting will be handled by the CFO. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO Planned completion date for corrective action plan: Fall 2024

View Audit 329672

Finding 511942 (2024-002)

Significant Deficiency 2024

Lutheran Social Services of Central Ohio Mansfield Housing, Inc.

OH

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Finding Number: 2024-002 Condition: The Corporation did not send HUD the approved residual receipts recapture requested by HUD in a reasonable period of time. The Corporation did not have a control in place to track that these funds were properly remitted to HUD. Planned Corrective Action: Managemen...

Finding Number: 2024-002 Condition: The Corporation did not send HUD the approved residual receipts recapture requested by HUD in a reasonable period of time. The Corporation did not have a control in place to track that these funds were properly remitted to HUD. Planned Corrective Action: Management is in the process of improving controls to ensure that all approved residual receipt recaptures requested by HUD are timely remitted to HUD. Contact person responsible for corrective action: Fikru Nigusse, CFO Anticipated Completion Date: June 30, 2025

View Audit 329671

Finding 511937 (2024-003)

Significant Deficiency 2024

Lincoln University of the Commonwealth System of Higher Education

PA

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

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion. Explanation of disagreement with audit finding: ...

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to updating the Eligibility and Certification Approval Report in a timely fashion. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: University will review which individuals are listed on the ECAR. Upon learning of their departure, the University will update ECAR immediately. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024

View Audit 329658

Finding 511934 (2024-002)

Significant Deficiency 2024

Lincoln University of the Commonwealth System of Higher Education

PA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation o...

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will develop and implement a procedure wherein uncashed checks will be reviewed more closely. Student refunds identified as uncashed as of 60 days will be forwarded to the Bursar’s Office. Bursar’s Office will conduct outreach to refund recipients. If refund remains uncashed after 180 days, Bursar’s Office will return funds to federal agency. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024

View Audit 329658 Questioned Costs: $1

Finding 511931 (2024-001)

Significant Deficiency 2024

Lincoln University of the Commonwealth System of Higher Education

PA

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

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit finding: There is...

Student Financial Assistance Cluster – Assistance Listing Number 84.007, 84.063, 84.268 Recommendation: We recommend that the University put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has in place a systematic procedure wherein reviews of credit balances are conducted promptly after aid is transmitted. The University will ensure that this procedure is followed thoroughly. Name(s) of the contact person(s) responsible for corrective action: H. Jonas Javier Planned completion date for corrective action plan: November 4, 2024

View Audit 329658

Finding 511888 (2024-014)

Material Weakness 2024

Nevada System of Higher Education

NV

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report. This review process will in...

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: UNLV Office of Sponsored Programs will work with PIs to ensure there is properly documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. • How compliance and performance will be measured and documented for future audit, management and performance review: Effective immediately, UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility along with applicable Deans. DRI – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: DRI will implement controls that require the documentation of review and approval on the invoice process. With the current limited resources available in DRI’s Financial Services team, a position will be recruited as soon as possible with an anticipated start date in early spring 2025. It is expected that this position will support the full implementation of review procedures once on board. • How compliance and performance will be measured and documented for future audit, management and performance review: Once the position is filled, all invoices will be reviewed prior to drawing down or requesting reimbursement of funds. Documentation will occur either through the business process in the accounting system or manually as needed. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. SA – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Future progress reports will require a review from a Director or higher supervisory approval prior to submission of reports to awarding sponsor/agency. • How compliance and performance will be measured and documented for future audit, management and performance review: Preparing department will provide either a signed version and/or email approval of progress report to the NSHE System Sponsored Programs to be filed with the award in Workday. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The NSHE System Sponsored Programs Director is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596

Finding 511786 (2024-020)

Significant Deficiency 2024

Nevada System of Higher Education

NV

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report, ensuring all information is...

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report, ensuring all information is correctly entered. Staff will also verify that all required FFATA (Federal Funding Accountability and Transparency Act) reporting is accurately completed and submitted in a timely manner. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured and documented through the independent review process, where management, independent of the preparer will verify and sign off on each report to ensure accuracy. These reviews will be tracked in Workday, with approvals and date stamps. A FFATA Entry Log will be maintained, documenting each submission. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for the reports. The Associate Director of PreAward is responsible for the FFATA. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596

Finding 511747 (2024-017)

Significant Deficiency 2024

Nevada System of Higher Education

NV

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

UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: While there were no specific instances noted regarding eligibility issues, the UNLV Office of Sponsored Programs r...

UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: While there were no specific instances noted regarding eligibility issues, the UNLV Office of Sponsored Programs recognizes the importance of documentation through the COSO internal control framework and will ensure the controls are continued, effective immediately. UNLV OSP will continue to enhance the documentation for the administrative management of programs to review and determine eligibility of participants per the requirements of the project, and those employees will be reminded of the importance of evidencing their reviews. • How compliance and performance will be measured and documented for future audit, management and performance review: Verification of eligibility will continue to be performed as required, with enhanced documentation. If escalation is needed, the employee will seek guidance from a supervisor and properly document. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: UNLV Office of Sponsored Programs Executive Director will be responsible for communicating the importance of enhanced documentation to the designated employees responsible for eligibility. UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Staff, independent of the preparer, will review and log each eligibility determination. • How compliance and performance will be measured and documented for future audit, management and performance review: A log will be maintained listing the review date and reviewer name for each determination. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Program Director, who is a Head Start Program Principal Investigator (PI), is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

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Finding 511735 (2024-010)

Significant Deficiency 2024

Nevada System of Higher Education

NV

Student Financial Aid Reporting Significant Deficiency

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: The Financial Aid Office and the Cashiers Office have implemented procedures to ensure that refund holds are review...

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: The Financial Aid Office and the Cashiers Office have implemented procedures to ensure that refund holds are reviewed twice a week (Tuesdays, Thursdays). Automatic reports have been implemented to check for students with credit balances who have holds on their accounts. Assigned FA advisors review the reports and work with the Cashiers Office to resolve any hold issues to ensure that the student receives their refund promptly but no later than 14 days after funds are disbursed to the student account. • How compliance and performance will be measured and documented for future audit, management and performance review: The Data Manager is running weekly quality assurance reports to check that the FA advisors are reviewing theirs list and that there are no students on the lists that need attention. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The assigned financial advisors who review refund holds and the Financial Aid Director will be responsible. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596

Corrective Action Plans

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