Corrective Action Plans

Finding 504696 (2024-004)

Significant Deficiency 2024

IL

Reporting Allowable Costs / Cost Principles Significant Deficiency § 200.303

Significant Deficiency in Internal Control over Compliance (Reporting) Recommendation: We recommend the Village strengthen internal controls over the review process of the annual grant reporting prior to the report submission. This review should be documented. Explanation of disagreement with aud...

Significant Deficiency in Internal Control over Compliance (Reporting) Recommendation: We recommend the Village strengthen internal controls over the review process of the annual grant reporting prior to the report submission. This review should be documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A procedure will be implemented for the review of the report submission including the proper documentation of the review Name of the contact person responsible for corrective action: Angela Schults, Comptroller Planned completion date for corrective action plan: 1 April 2025

View Audit 327310

Finding 504669 (2024-001)

Significant Deficiency 2024

Anne Arundel Community College

MD

Special Tests & Provisions Student Financial Aid Reporting § 200.303

MANAGEMENT RESPONSE AND CORRECTIVE ACTION PLAN U.S. Department of Education Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FE...

MANAGEMENT RESPONSE AND CORRECTIVE ACTION PLAN U.S. Department of Education Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2024-01: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college has reviewed and updated procedures to ensure that graduation and enrollment files are submitted in the necessary sequence to reflect the appropriate enrollment status and effective dates. Name(s) of the contact person(s) responsible for corrective action: Nanci A. Beier, Registrar Planned completion date for corrective action plan: Completed

View Audit 327260

Finding 504665 (2024-001)

Significant Deficiency 2024

Art Center College of Design

CA

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

October 31, 2024 Corrective Action Plan To whom it may concern: This letter includes the corrective action plan in response to the audit finding from the Single Audit for the 2023-2024 award year. Audit Finding 2024-001: For students who did not return from an approved leave of absence or tho...

October 31, 2024 Corrective Action Plan To whom it may concern: This letter includes the corrective action plan in response to the audit finding from the Single Audit for the 2023-2024 award year. Audit Finding 2024-001: For students who did not return from an approved leave of absence or those that took a leave of absence that did not meet the requirements of an approved leave of absence, predominantly being leaves of absences in excess of 180 days in any 12-month period, Art Center did not consistently report to the NSLDS the effective date of the withdrawal as the date the student began the leave of absence. Management Response: ArtCenter management acknowledges that some incorrect Enrollment Reporting data were transmitted through the National Student Clearinghouse (“NSC”) to the National Student Loan Data System (“NSLDS”). However, this error was not due to any insufficiencies in ArtCenter’s policies, but rather, was due to a technical misunderstanding regarding which data fields are extracted from Colleague for NSC reporting. More specifically, if a student takes a second Leave of Absence (“LOA”), it had been ArtCenter’s practice to record the student’s actual last date of attendance in the “Last Date of Attendance” field on the Student Hiatus Summary screen in Colleague, but the file that NSC requires schools to use to extract reporting data does not pull data from this field, and as a result, the resulting reported information was inaccurate. Corrective Action Plan: To remediate this finding and avoid future inaccuracies in Enrollment Reporting, we have adjusted our procedures to ensure the appropriate withdrawal date is submitted to NSC for transmission to NSLDS, in alignment with NSLDS Enrollment Reporting definitions and expectations. Please let us know if you have any additional questions. Sincerely, Kaitlin Wallace Executive Director, Financial Aid Art Center College of Design 1700 Lida St. Pasadena, CA 91103 626.396.2214

View Audit 327259

Finding 504651 (2024-002)

Significant Deficiency 2024

Life Pacific University

CA

Student Financial Aid Eligibility Reporting

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The reason that R214 were done late/inaccurately was due to an employee who was new to the position and instead of seeking assistance in a timely manner, waited until the prior retired Director of Student accounts was...

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The reason that R214 were done late/inaccurately was due to an employee who was new to the position and instead of seeking assistance in a timely manner, waited until the prior retired Director of Student accounts was contracted in to assist. This employee was transferred from enrollment department oversight and then transferred to business office oversight mid-year. Neither department could provide the necessary management of this position and that is when they reached out to contract back the former Director of Student Accounts. Our only other trained R2T4 employee left LPU in Spring 24 and due to staffing challenges with FAFSA Simplification, we could not get someone new trained in time. We have been working with a consulting firm, JM Solutions, and with consultants' input, we are restructuring the financial aid and Student Accounts department to fall under one direct oversight. LPU created an Associate Vice President of Enrollment Services who oversees FinancialAid, Student Accounts and Registrar. Underthe Associate VP, there is a new Director of Student FinancialServices (this combined role is the Director of Financial aid and Student Accounts). Going forward R2T4 will be done on the COD system per consultants' recommendation. Currently the Director of Student Financial Services is being trained on R2T4, and they are seeking to hire a fulltime position of a Financial Aid processor who will be trained on R2T4 as well. For now, the Associate VP and Director of Student Financial Services will be working together to ensure R2T4 are completed according to regulations, with additional oversight by consultants throughout the academic year. Person Responsible for Corrective Action Plan: Amber Burnett, Associate Vice President of Enrollment Services and Angel Cavazos, Director of Student Financial Services Anticipated Date of Completion: At this time oversight and changes are in place for the R2T4 process

View Audit 327230

Finding 504609 (2024-002)

Significant Deficiency 2024

Charlton Heston Academy

MI

Subrecipient Monitoring School Nutrition Programs Significant Deficiency

Charlton Heston Academy respectfully submits the following corrective action plan for the year ended June 30, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2024 Academy Contact Person: Frank Patterson, Chief Financial Officer F...

Charlton Heston Academy respectfully submits the following corrective action plan for the year ended June 30, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2024 Academy Contact Person: Frank Patterson, Chief Financial Officer Finding 2024-001 – Significant deficiency Recommendation: We recommend the Academy establish improved controls for preparing and reviewing year-end reconciliations. The Academy should ensure that reconciliations are completed in a timely manner and agree to the general ledger. Actions to be taken: The Academy concurs with the facts of this finding and are in the process of adding human capital/capacity, developing a revised formal timeline, and checklist of year-end procedures as recommended. Finding 2024-002 – Significant deficiency Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: The Academy concurs with the facts of this finding and has implemented procedures to prevent this in the future.

View Audit 327194

Finding 504608 (2024-001)

None 2024

National Church Residences of Missouri D/b/a Summit Terrace

OH

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

The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely.

View Audit 327191

Finding 504583 (2024-002)

Significant Deficiency 2024

Jefferson Public Schools

MI

Reporting Significant Deficiency Internal Control / Segregation of Duties

The audited financial statements are required to be submitted to the Federal Audit Clearinghouse within 30 days of receiving the auditor’s report or 9 months after the end of the audit period, whichever is earlier. The deadline was missed in submitted the 2023 fiscal year audit due to a change in t...

The audited financial statements are required to be submitted to the Federal Audit Clearinghouse within 30 days of receiving the auditor’s report or 9 months after the end of the audit period, whichever is earlier. The deadline was missed in submitted the 2023 fiscal year audit due to a change in the submission process. The School District is aware of the process, and will ensure that the financial statements are filed timely in the future. Corrective action has already been taken, as immediate steps were taken to submit the 2023 fiscal year audit as soon the School District was made aware that it was not submitted. The audited financial statements for the 2024 fiscal year will be submitted by November 20, 2024.

View Audit 327175

Finding 504578 (2024-001)

None 2024

Ncr of Manhattan, Kansas D/b/a Garden Grove Apartments

OH

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

Condition: The Corporation failed to refund a security deposit to a tenant within 30 days of their move out date. Planned Corrective Action: The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are return...

Condition: The Corporation failed to refund a security deposit to a tenant within 30 days of their move out date. Planned Corrective Action: The security deposit has been refunded and management is currently reviewing internal controls over security deposit refunds to ensure all deposits are returned timely. Contact person responsible for corrective action: Jill Kolb, Vice President – Housing Accounting Completion Date: March 12, 2024

View Audit 327165

Finding 504530 (2024-001)

Significant Deficiency 2024

University of the Cumberlands, Inc.

KY

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

2024-001 Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University did not include the estimated amount of disbursement in the Federal Direct Loan disbursement notifications. Name of Contact Person Management ag...

2024-001 Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University did not include the estimated amount of disbursement in the Federal Direct Loan disbursement notifications. Name of Contact Person Management agrees with finding 2024-001. When disbursement notifications were built for the 2023-24 award year, the calculated fields to notify students of the amount of aid being disbursed were not properly updated. Alex Campbell, Director of Financial Aid, and Kaitrin Parrett, Assistant Director of Financial Aid, are the responsible parties for the corrective action. Contact information for the responsible parties is alex.campbell@ucumberlands.edu (606) 539-5569 and kaitrin.parrett@ucumberlands.edu (606) 539-5591 Corrective Action Plan Upon identifying the deficiencies in meeting regulations for disbursement notifications, immediate corrective actions were undertaken. In collaboration with software engineers, the disbursement notification template was updated to notify students of the type of Federal Direct Loan, the date of disbursement, the amount of aid disbursed, and all other required information related to regulatory requirements. The Financial Aid Office tested and reviewed disbursement notifications for Direct Subsidized Loans, Direct Unsubsidized Loans, and Direct PLUS Loans across all student populations and confirmed that the notifications were updated and all necessary information was communicated to students before the disbursement of Fall 2024 Federal Direct Loans. In future aid years, disbursement notification templates will be internally reviewed and tested by the Director and Assistant Director of Financial Aid each semester before the disbursement of Federal Direct Loans to ensure continued compliance. Testing of the configurations for the disbursement notification template will be completed in our Student Information System’s sandbox environment. In this environment, staff will be able to simulate and disburse all Federal Direct Loans to ensure notification templates are properly set up before moving into the production tenant. Periodic reports will be generated in the production tenant to confirm that students received the appropriate disbursement notification based on their award type and disbursement date. Expected Completion Date This corrective action plan was implemented on August 1, 2024, before Fall 2024 aid disbursements began on August 30, 2024.

View Audit 327110

Finding 504488 (2024-001)

Significant Deficiency 2024

North Muskegon Public Schools

MI

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

Finding 2024-001: Internal Controls Over the Federal Expenditure Report Type of Finding: Control U.S. Department of Education Pass-through Entity: Michigan Department of Education Assistance Listing Number: 84.425D Award Numbers: COVID-19 213712-2021, COVID-19 213782-2223 Award Year End: Sep...

Finding 2024-001: Internal Controls Over the Federal Expenditure Report Type of Finding: Control U.S. Department of Education Pass-through Entity: Michigan Department of Education Assistance Listing Number: 84.425D Award Numbers: COVID-19 213712-2021, COVID-19 213782-2223 Award Year End: September 30, 2023 Recommendation: The School District should establish procedures to require the documented review and approval of all reports by an individual with adequate skills, knowledge, and experience prior to submission. Action Taken: The School District has implemented a new procedure requiring that all reports be reviewed and approved by a designated reviewer before submission. The reviewer, who must possess the appropriate skills, knowledge, and experience relevant to the report's content, will ensure that the information is accurate, complete, and compliant with organizational standards and regulatory requirements. Responsible Person and Anticipated Completion Date: Director of Business Services, September 2024. If the Michigan Department of Education has questions regarding this plan, please call Mark Mesbergen at (231) 719-4102.

View Audit 327050

Finding 504487 (2024-001)

Significant Deficiency 2024

Great Oaks Academy

MI

Questioned Costs Cash Management Allowable Costs / Cost Principles

Finding Number: 2024-001 Condition: The Academy did not accurately apply the approved indirect cost rate for the program at the time drawdown requests were submitted creating a cash management issue involving unallowable cost reimbursements. Planned Corrective Action: Management agrees with the find...

Finding Number: 2024-001 Condition: The Academy did not accurately apply the approved indirect cost rate for the program at the time drawdown requests were submitted creating a cash management issue involving unallowable cost reimbursements. Planned Corrective Action: Management agrees with the finding. Management identified the error after the draw down occurred and reduced the indirect costs and is in the process of enhancing procedures to prevent overdrawn amounts in the future. Contact person responsible for corrective action: Rebecca Joyner Anticipated Completion Date: 12/31/2024

View Audit 327039 Questioned Costs: $1

Finding 504486 (2024-004)

Material Weakness 2024

Ecorse Public Schools

MI

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Issue: Allowable Activities - Allocable Fringe Benefits Corrective Action Plan: The district will ensure that retirement rates are updated in the SMART program and that all accounts are charged at a consistent rate.

View Audit 327038 Questioned Costs: $1

Finding 504485 (2024-003)

Material Weakness 2024

Ecorse Public Schools

MI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Issue: Material Weakness in Internal Controls Over Financial Reporting and Material Noncompliance - Allowable Activities and Chart of Accounts and Budget Monitoring Corrective Action Plan: The district is updating and correcting all accounts in accordance with the 1022 manuals.

View Audit 327038 Questioned Costs: $1

Finding 504481 (2024-001)

Significant Deficiency 2024

College of Southern Idaho

ID

Special Tests & Provisions Student Financial Aid Reporting

Finding: 2024-00 I Federal Agency Name: U.S. Department of Education Assistance Listing Number(s}: 84.007, 84.033, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely ...

Finding: 2024-00 I Federal Agency Name: U.S. Department of Education Assistance Listing Number(s}: 84.007, 84.033, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student's enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student's enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. During the testing of compliance for Enrollment Reporting, there was I instance out of 60 students tested where the change in student's enrollment status was not updated in NSLDS within 60 days of the effective date of the change. There was 1 instance out of 60 students tested where the enrollment status per CSI records did not agree to the enrollment status that was certified in NSLDS. Responsible Individuals: Bethany Parmer, Office of the Registrar, and Larisa Alexander, Information Technology Staff Corrective Action Plan: As a corrective measure, we have assigned a single point of contact to manage the submission of dates to the Clearinghouse, which then feeds the data to NLDS. This process was implemented last year and has proven effective, as the individual in charge has developed significant expertise and improved our reporting accuracy. However, during our transition to the new student system, we discovered that incorrect data was being fed from Jenzabar, which caused the finding. CSI will no longer input dates into both systems. The data is submitted in one system, and the systems communicate with each other, ensuring consistency and preventing discrepancies in dates. The follow chart demonstrates the flow of information for how the CAP will occur.

View Audit 327020

Finding 504474 (2024-002)

Significant Deficiency 2024

Bellevue Fire Control Board

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

Management is in the process of drafting an updated procurement policy to comply with the requirements of the Uniform Guidance.

View Audit 327007

Finding 504472 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 2010, Inc.

PA

Cash Management HUD Housing Programs Significant Deficiency

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 327004

Finding 504470 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA Ii, Inc.

PA

Cash Management HUD Housing Programs Significant Deficiency

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 327003

Finding 504468 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing Pennsylvania, Inc.

PA

Cash Management HUD Housing Programs Significant Deficiency

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 327002

Finding 504466 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing Del Ii, Inc.

PA

Cash Management HUD Housing Programs Significant Deficiency

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 327001

Finding 504464 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing De 2003, Inc.

PA

Cash Management HUD Housing Programs Significant Deficiency

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 327000

Finding 504462 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 2009, Inc.

PA

Cash Management HUD Housing Programs Significant Deficiency

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326999

Finding 504460 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 2006, Inc.

PA

Cash Management HUD Housing Programs Significant Deficiency

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326998

Finding 504458 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 2002, Inc.

PA

Cash Management HUD Housing Programs Significant Deficiency

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326997

Finding 504456 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 2001, Inc.

PA

Cash Management HUD Housing Programs Significant Deficiency

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326996

Finding 504454 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 99, Inc.

PA

Cash Management HUD Housing Programs Significant Deficiency

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326994

Corrective Action Plans

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