Corrective Action Plans

Finding 515700 (2024-003)

Significant Deficiency 2024

AZ

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There i...

Recommendation: We recommend the University review their current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Continue reviewing student credit balances on a weekly basis ensuring Title IV refund checks are processed within the 14 calendar days. Additionally, the Finace team will review current procedure and draft a formal policy and procedure for Student Credit Balances. Name(s) of the contact person(s) responsible for corrective action: Michael Werner- VP of Finance Planned completion date for corrective action plan: End of Calendar year 2024

View Audit 333555

Finding 515695 (2024-002)

Significant Deficiency 2024

Arizona Christian University

AZ

Questioned Costs Student Financial Aid Significant Deficiency

Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken ...

Recommendation: We recommend that the University implement a formal review process as it relates to withdrawn students to ensure R2T4 calculations are being performed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ACU has created 1 additional financial aid advisor position. This position will assist the financial aid team. The Financial aid office will review the withdrawn requests sent to the financial aid inbox on a weekly basis. The withdrawn report will be worked at the end of every week to ensure all withdrawn students have been reviewed to date and all R2T4 calculations have been completed. The Director of Financial Aid will create formal training processes and will conduct training with the financial aid advisors. The Director of Financial Aid will conduct periodic reviews to ensure ongoing compliance with Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Angel Faast- Director of Financial Aid Planned completion date for corrective action plan: 01/31/2025

View Audit 333555 Questioned Costs: $1

Finding 515690 (2024-001)

Significant Deficiency 2024

Arizona Christian University

AZ

Student Financial Aid Reporting Significant Deficiency

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. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in resp...

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. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The AVP of Institutional Effectiveness will create a secure digital tracking spreadsheet that will contain file submission tracking and error resolution tracking. A digital signature protocol will be implemented that will require a sign off on submission from ADIR and AVP will verify and sign off within 48 hours of submission. A weekly check-in will be conducted on Monday that will review weekly reports, upcoming submissions, error resolution status updates and documentation for meeting outcomes. Tracking deadlines will be implemented for error resolution. ADIR must acknowledge NSC error notifications within 1 business day and error resolution must begin within 2 business days. The first attempt must be completed within 5 business days and secondary error notifications must be addressed within 3 business days. AVP IE will conduct a monthly audit and a quarterly assessment to ensure ongoing compliance with Title IV regulations. Name(s) of the contact person(s) responsible for corrective action: Jeff Phillips-AVP of Institutional Effectiveness Planned completion date for corrective action plan: End of Calendar year 2024

View Audit 333555

Finding 515680 (2024-002)

Significant Deficiency 2024

El Monte City School District

CA

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

Finding 2024-002: Time and Effort Requirements (50000) Assistance Listing No. 93.600 HeadStart U.S. Department of Health & Human Services Passed through Los Angeles County Office of Education (LACOE) Dear Sir/Madam: Please find enclosed El Monte City School District Corrective Action Plan for the ...

Finding 2024-002: Time and Effort Requirements (50000) Assistance Listing No. 93.600 HeadStart U.S. Department of Health & Human Services Passed through Los Angeles County Office of Education (LACOE) Dear Sir/Madam: Please find enclosed El Monte City School District Corrective Action Plan for the Time and Effort Finding cited in the District's 2023-24 Single Audit. El Monte City School District Corrective Action Plan: Time and Effort Finding (2024-002) Goal: To ensure compliance with federal regulations for time and effort documentation and prevent recurrence of findings related to restricted funding sources. Action Steps: Staff Training and Awareness: • Conduct retraining sessions for relevant staff on federal time and effort reporting requirements. Include specific topics such as: o Record retention requirements for documentation supporting salary and wage charges. o Utilize scenarios and examples related to long tenn leave and benefit payouts with federal programs to enhance understanding. o Require attendees to sign acknowledgment fonns confirming participation and understanding of training content. Enhanced Review Mechanisms: • Establish additional internal controls to ensure compliance, including: o Periodic spot-check audits of time and effort records by the grants compliance officer or designee. o Use a checklist to verify completeness and accuracy of documentation. o Escalate issues to supervisors for prompt resolution before charges are applied to federal grants. Monitoring and Evaluation: • Develop a monitoring plan to ensure ongoing compliance: o Quarterly reviews of time and effort documentation by district leadership. o Solicit feedback from staff on challenges with compliance and address concemi promptly. Responsible Personnel: • Fiscal Area: Assistant Superintendent, Business Services Jose Herrera - Oversight of corrective action implementation and training. • Program Area: Juan Castillo, Director of Child Development- Regular monitoring of compliance for Time and Effort Documentation. Timeline for Implementation: • By March 31, 2024: Complete staff retraining sessions and re-distribute policies bulletins. • By April 30, 2024: Implement enhanced review mechanisms. • Quarterly (Ongoing): Conduct internal reviews and monitoring. By following this corrective action plan, the District aims to fully address the finding and ensure compliance with federal time and effort reporting requirements.

View Audit 333492 Questioned Costs: $1

Finding 515666 (2024-001)

Material Weakness 2024

City of Clarion

IA

Internal Control / Segregation of Duties

The City should review its control activities to obtain the maximum internal control possible under the circumstances utilizing currently available staff, including elected officials, to provide additional controls through review of financial transactions, reconciliations and financial report. The r...

The City should review its control activities to obtain the maximum internal control possible under the circumstances utilizing currently available staff, including elected officials, to provide additional controls through review of financial transactions, reconciliations and financial report. The reviews should be documented by the signature or initials of the reviewer and the date of the review.

View Audit 333479

Finding 515665 (2024-001)

Material Weakness 2024

Mid-South Food Bank

TN

Material Weakness Reporting Internal Control / Segregation of Duties

Compliance officer will be handling this now.

View Audit 333474

Finding 515662 (2024-001)

Significant Deficiency 2024

School District of Hartford Jt. No. 1

WI

Internal Control / Segregation of Duties

The Finance Manager will continue to review bank reconciliations on a monthly basis to ensure everything is accurate and appropriate. On a weekly/bi-weekly basis the Finance Manager has established business office meetings to review opportunities for continuous improvement within the business office...

The Finance Manager will continue to review bank reconciliations on a monthly basis to ensure everything is accurate and appropriate. On a weekly/bi-weekly basis the Finance Manager has established business office meetings to review opportunities for continuous improvement within the business office. As part of these meetings, the Finance Manager plans to review the bank reconciliation process. The Finance Manager will also review financial activity on a monthly basis to look for any discrepancies in the accounts. Throughout the year, the Finance Manager randomly investigates several accounts each month to check for any discrepancies between his expectations and actual results. The Board of Education reviews all checks printed on a monthly basis. After the checks are approved, they are mailed out. Three to four times a year the Finance Committee randomly pulls checks to review them. All expense reports are currently being countersigned. The budget to actual comparisons are reviewed twice a year by the Finance Committee (1st and 3rd quarter) and twice a year by the Board (2nd and 4th quarter). The Finance Manager provides financial updates to the Board of Education on a regular basis. Add items on payroll. District is willing to accept the risk.

View Audit 333461

Finding 515647 (2024-002)

Significant Deficiency 2024

North Star School District

PA

Internal Control / Segregation of Duties Cash Management Reporting

Nutrition Cluster – CFDA Nos. 10.553 and 10.555 Significant Deficiency in Internal Controls over Compliance: See Find-ing 2024-001

View Audit 333428

Finding 515591 (2024-005)

Material Weakness 2024

Griggsville-Perry Community Unit School District #4

IL

Internal Control / Segregation of Duties

FINDINGS- MAJOR FEDERAL AWARD PROGRAMS Material Weakness U.S. DEPARTMENT OF EDUCATION- 2023 Elementary and Secondary School Emergency Relief Fund- AL Number 84.425 Finding No.: 2024-005 Condition: The District's accounting function is controlled by a limited number of individuals resulting in...

FINDINGS- MAJOR FEDERAL AWARD PROGRAMS Material Weakness U.S. DEPARTMENT OF EDUCATION- 2023 Elementary and Secondary School Emergency Relief Fund- AL Number 84.425 Finding No.: 2024-005 Condition: The District's accounting function is controlled by a limited number of individuals resulting in the inadequate segregation of duties. Recommendation: The District should segregate duties where possible and create checks and balances. The Board should be aware of this issue and closely review and approve all financial related information. Action Taken: The District concurs with the recommendation. The District is reviewing its financial policies and procedures to better segregate duties where possible. The Superintendent will make the Board aware of their responsibility in regards to reviewing and approving financial items and asking questions. Anticipated Date of Completion: Ongoing

View Audit 333309

Finding 515575 (2024-001)

Significant Deficiency 2024

Union County College

NJ

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

FINDINGS — FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2024-001 Student Financial Aid – CFDA No. 84.007, 84.268, 84.063, 84.033 Recommendation: 1) We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollme...

FINDINGS — FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION 2024-001 Student Financial Aid – CFDA No. 84.007, 84.268, 84.063, 84.033 Recommendation: 1) We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the College’s last date of attendance. 2) We recommend the College reevaluate its procedures and review policies surrounding reporting program enrollment effective dates to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Corrective Action Response Regarding Graduation Date Discrepancy 1. Immediate Correction of Records: • Verified and corrected all affected student records to reflect accurate graduation dates. • Graduation dates for graduates from Fall 2023 to Summer 2024 will be updated. This action ensures alignment between the student information system, official transcripts, and graduation rosters. 2. Process and Policy Updates: • Internal policies will be revised to provide clear guidance on assigning and verifying graduation dates. Corrective Action Response Regarding Enrollment Transmission Reporting Timeline Beyond the 60-Day Requirement 1. Policy and Procedure Enhancements: • Updated internal policies to require enrollment data transmission at least every 20 days, well ahead of the 60-day federal requirement to ensure receipt by the National Student Loan Data System (NSLDS) in a timely manner. • Staff will periodically request a transmission audit from the Clearinghouse verifying that the institution’s enrollment data has been forwarded to the National Student Loan Data System (NSLDS). Name of the contact person responsible for corrective action: Dayne Chance, Director of Financial Aid at 908-709-7089 If the Department of Education has questions regarding this plan, please contact the appropriate individual outlined above.

View Audit 333286

Finding 515541 (2024-004)

Material Weakness 2024

Port Edwards School District

WI

Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs § 200.334

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends the District review its grant reporting processes and implement internal controls to help ensure that there is adequate segregation of duties in regards to grant reporting in...

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends the District review its grant reporting processes and implement internal controls to help ensure that there is adequate segregation of duties in regards to grant reporting including special reports and that all supporting documentation is maintained with the filed copy of the report. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for grants but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing.

View Audit 333281

Finding 515538 (2024-003)

Material Weakness 2024

Port Edwards School District

WI

Internal Control / Segregation of Duties Procurement, Suspension & Debarment HUD Housing Programs

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowabil...

Elementary and Secondary School Emergency Relief – Assistance Listing No. 84.425D, 84.425U Recommendation: Auditor recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving purchases when purchase orders are not required, along with adding controls to ensure that the item purchased was received by the District. We also recommend the District review its payroll process and identify payroll tasks that could be reassigned to other district personnel or consider implementing additional review procedures specifically focused on payroll and related fringe benefit costs claimed on federal and state grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for grants but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing.

View Audit 333281

Finding 515533 (2024-006)

Material Weakness 2024

Port Edwards School District

WI

Procurement, Suspension & Debarment Internal Control / Segregation of Duties HUD Housing Programs

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: Auditor recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving micro pu...

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: Auditor recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving micro purchases, along with adding controls to ensure that the item purchased was received by the District. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will improve on the review process for micro purchases but with the current financial situation, additional staff cannot be added. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing. If the oversight agencies have questions regarding this plan, please call Lisa Miller at 715-887-9000.

View Audit 333281

Finding 515525 (2024-002)

Significant Deficiency 2024

Penns Manor Area School District

PA

Internal Control / Segregation of Duties Reporting

Education Stabilization Fund – CFDA No. 84.425 Internal Controls over Compliance: Significant Deficiency: See Finding 2024-001

View Audit 333262

Finding 515146 (2024-001)

Material Weakness 2024

Golden Thread Housing, Inc.

IA

Internal Control / Segregation of Duties Reporting

The Project has limited resources and additional controls are not financially feasible through the hiring of additional staff. The Project is a small entity and the lack of segregation of duties is common among entities with minimal employees and should be recognized as such. The Project will cont...

The Project has limited resources and additional controls are not financially feasible through the hiring of additional staff. The Project is a small entity and the lack of segregation of duties is common among entities with minimal employees and should be recognized as such. The Project will continue to evaluate the cost versus benefit of correcting the deficiency.

View Audit 333177

Finding 515138 (2024-003)

Significant Deficiency 2024

Louisburg College Inc.

NC

Special Tests & Provisions Student Financial Aid Eligibility

Identifying Number: 2024‐003 ‐ U.S. Department of Education Student Financial Assistance Cluster – Special Tests and Provisions: Return of Title IV Funds Finding: The College failed to return title IV funds to the student within the 45‐day time frame for 1 student out of 3 students tested. Contact P...

Identifying Number: 2024‐003 ‐ U.S. Department of Education Student Financial Assistance Cluster – Special Tests and Provisions: Return of Title IV Funds Finding: The College failed to return title IV funds to the student within the 45‐day time frame for 1 student out of 3 students tested. Contact Person Responsible for Corrective Action Plan: Director of Financial Aid Corrective Action Plan: The Vice President of Academic Life (VPAL) has been informing the Director of Financial Aid ofeach student who has withdrawn, been administratively withdrawn, or been suspended from the College so as to be able to accurately calculate the return of Title IV funds in a timely manner. Anticipated Completion Date: Immediately

View Audit 333176

Finding 514650 (2024-002)

None 2024

Illinois Valley Community College Dist. No.513

IL

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

2024-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition Found During our student file testing, we noted two students out of 40 did not have documentation in their file t...

2024-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition Found During our student file testing, we noted two students out of 40 did not have documentation in their file that exit counseling was sent thirty days after the student withdrew. We consider the missing exit counseling to be an instance of non-compliance with the Eligibility Compliance Requirement. Corrective Action Plan We have updated our Loan Procedures to include running an internal report on all loan students on the 1st and 15th of every month, or the next work day following those dates if they land on a day the campus is closed. If a student with loans has withdrawn completely and stopped attending, we will send an exit letter within 7 business days of discovering that the student has ceased attending. Responsible Person for Corrective Action Plan Isamar Taylor - Director of Financial Aid and Jill Wohrley - Financial Aid Reconciliation and Compliance Specialist Implementation Date of Corrective Action Plan 10/16/2024

View Audit 333030

Finding 514648 (2024-001)

Significant Deficiency 2024

Illinois Valley Community College Dist. No.513

IL

Special Tests & Provisions Student Financial Aid Reporting

2024-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition Found During our Return of Title IV Fund testing, we noted that the College did not return Title IV Student Finan...

2024-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition Found During our Return of Title IV Fund testing, we noted that the College did not return Title IV Student Financial Aid for five out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be a Significant Deficiency relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan To rectify this issue, we have taken the following corrective actions: Enhanced Monitoring and Reporting: Run our internal tracking report once a week to monitor and ensure timely Return of Title IV (R2T4) calculations. This system will alert financial aid staff when a student withdraws, prompting immediate action to review and process the return within the required 45-day timeframe. Staff Training and Certification: Conducted a comprehensive training session for all financial aid staff to reinforce the importance of timely R2T4 calculations. Training covered procedures for identifying students who have ceased attendance, the calculation process, and deadlines for completing returns. Regular refresher training sessions will be scheduled each term to ensure staff remain informed and compliant with federal guidelines. Audit and Quality Control Checks: Institute periodic quality control checks by the Financial Aid Reconciliation and Compliance Specialist to verify the accuracy and timeliness of R2T4 calculations. Responsible Person for Corrective Action Plan Isamar Taylor - Director of Financial Aid and Jill Wohrley - Financial Aid Reconciliation and Compliance Specialist Implementation Date of Corrective Action Plan 10/16/2024

View Audit 333030

Finding 514616 (2024-002)

None 2024

Kankakee Community College District 520

IL

Reporting Internal Control / Segregation of Duties

2024-002: Enrollment Reporting - Student Financial Aid Cluster -Assistance Listing Number 84.007, 84.033, 84.063, and 84.268 - Year Ended June 30, 2024 Condition: During our Enrollment Status Changes testing, we selected forty students for our sample. In our sample of forty we tested twenty graduate...

2024-002: Enrollment Reporting - Student Financial Aid Cluster -Assistance Listing Number 84.007, 84.033, 84.063, and 84.268 - Year Ended June 30, 2024 Condition: During our Enrollment Status Changes testing, we selected forty students for our sample. In our sample of forty we tested twenty graduated students to verify that they were reported within sixty days and we tested twenty current students to note that their student status is reported correctly. We noted two students were not reported within the required sixty days. We consider this finding to be an instance of noncompliance relating to the Reporting Compliance Requirement. Corrective Action Plan: The KCC Office of Adminssions and Registration has reviewed and updated the Graduation Reporting process to ensure compliance standards are consistently met. The scehdule for graduated students has been updated to ensure students are being reporting within sixty days from conferral date. Responsible Person for Corrective Action Plan: Michelle Hasik, Director of Enrollment Services Implementation Date of Corrective Action Plan: November 1, 2024

View Audit 332960

Finding 514615 (2024-001)

None 2024

Kankakee Community College District 520

IL

Special Tests & Provisions Student Financial Aid Reporting

2024-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition: During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV Stude...

2024-001: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2024 Condition: During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for two out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be an instance of noncompliance relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan: The KCC Office of Financial Aid has reviewed and updated the Return of Title IV process to ensure compliance standards are consistently met. A weekly report has been set up to detect unprocessed R2T4 awards and transmittal will occur on a weekly basis to support the timely return of Title IV funds. Responsible Person for Corrective Action Plan: Kendra Souligne, Director of Financial Aid & Student Engagement Implementation Date of Corrective Action Plan: June 12, 2024

View Audit 332960

Finding 514595 (2024-001)

Material Weakness 2024

Niad Center for Human Development, Inc. D/b/a Crisis Intervention Services

IA

Internal Control / Segregation of Duties

As documented in our response to the auditor's comment, we plan to monitor and segregate duties as efficiently as possible

View Audit 332943

Finding 514583 (2024-002)

Significant Deficiency 2024

University of Northwestern - St. Paul and Subsidiaries

MN

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Variou Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is n...

Student Financial Assistance Cluster – Assistance Listing No. Variou Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will update our procedures to make sure we are reporting accurate graduate dates and enrollment effective dates in a timely manner. We have already begun reviewing this and are finding that the incidents found appear to be isolated. Therefore we are updating procedure to include additional quality control checks to ensure that anomalies are found and resolved within the required timeframe. Name(s) of the contact person(s) responsible for corrective action: Hannah Blahnik Planned completion date for corrective action plan: May 2025

View Audit 332923

Finding 514577 (2024-001)

Significant Deficiency 2024

University of Northwestern - St. Paul and Subsidiaries

MN

Significant Deficiency Equipment & Real Property Management Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit ...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding:  An Information Security Policy that addresses all policy gaps related to the GLBA audit findings will be presented to the President’s cabinet for approval by Dec. 2, 2024.  A migration of our Banner environment to Oracle Cloud Infrastructure will be completed by Nov. 6, 2024. This will include encrypting our database at rest, which is the last step in implementing best practices for encrypting our Banner data.  In addition to our annual security awareness training, we will complete an organizationwide phishing simulation by Dec. 31, 2024. Name(s) of the contact person(s) responsible for corrective action: Chad Miller Planned completion date for corrective action plan: December 31, 2024

View Audit 332923

Finding 514569 (2024-004)

Material Weakness 2024

Clarenceville School District of Oakland and Wayne Counties

MI

Subrecipient Monitoring Cash Management Material Weakness

Condition: The School District is required to account for all revenues and expenditures of its non-profit school food service account in accordance with state and federal requirements. In order to ensure that federal reimbursement payments received monthly from the Michigan Department of Education a...

Condition: The School District is required to account for all revenues and expenditures of its non-profit school food service account in accordance with state and federal requirements. In order to ensure that federal reimbursement payments received monthly from the Michigan Department of Education are correctly credited to the school food service account, monthly bank reconciliations should be prepared and reviewed by individuals with requisite skill and experience. During the 2024 fiscal year, bank reconciliations and monthly reconciliations of food service revenues and expenditures of the school food service account were not being prepared and reviewed in a timely manner. As there was an unexpected reduction in staff resources in the business office, there were not adequate resources to perform these accounting reconciliations on a timely regular basis during the year. The absence of these timely regular reviews could lead to undiscovered errors in the school food service account and material noncompliance with federal regulations. Planned Corrective Action: The School District agrees that its internal control structure should ensure that accounting reconciliations are prepared and reviewed in a timely manner during the year. Although the School District had an intergovernmental Agreement with its Intermediate School District to provide business services, such services could not be rendered due to inability to find staffing. Near the end of the 2024 fiscal year, a Finance Director was directly hired into the business office. Monthly reconciliations of accounting records and closing of monthly books are now being performed and reviewed on a timely basis. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: July 1, 2024

View Audit 332905

Finding 514565 (2024-003)

Material Weakness 2024

Clarenceville School District of Oakland and Wayne Counties

MI

School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School ...

Condition: The School District must submit monthly claims for reimbursement for meals served to eligible students within 60 days following the last day of the month covered by the claim (7 CFR sections 210.8, 220.11, 215.10, and 225.15 (c)). Upon preparation of meal reimbursement claims, the School District is required to have controls in place to ensure the accuracy of the request for reimbursement. The School District did not have a documented review process in place over the reimbursement requests. Meal counts entered into the Michigan Nutrition Data (MIND) system took place without a secondary review, which could result in incorrect reporting of the number of meals. The preparation of the request without a secondary review could result in incorrect reporting of the number of free and reduced priced meals, which could result in the School District being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The School District's business office performed a detailed review of all meal claim submissions for the 2023-2024 fiscal year. Claims were accurately completed as was the amount of reimbursement paid by the Michigan Department of Education. The business office has since implemented a formalized internal control procedure beginning in July 2024, whereby a formal documented review of the meal claim submission is performed. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: July 1, 2024

View Audit 332905

Corrective Action Plans

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