Corrective Action Plans

Finding 524939 (2024-001)

Material Weakness 2024

CA

Questioned Costs Student Financial Aid Material Weakness

Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Response to Recommenda...

Recommendation: We recommend the District review the R2T4 requirements and implement procedures to ensure award adjustments as determined by the R2T4 calculations are being properly adjusted to the student’s account and the correct amounts are being returned to the Department. Response to Recommendation: The District acknowledges the importance of adhering to R2T4 requirements and has taken the following actions to address this recommendation: The District adjusted the student samples as notated by auditors. Samples with discrepancies have been recalculated based on R2T4 requirements and correct amounts have been returned to the Department of Education. Verification of corrected R2T4 calculations was provided to auditors. Action taken in response to finding: 1. Consultant Engagement: o A NASFAA-certified consultant with extensive experience as a financial aid director has been hired to assist the R2T4 team during the 2024-2025 aid year. o The consultant will review all R2T4 calculations to ensure compliance and accuracy. Additionally, a secondary staff member is assisting in reviewing all 2024-2025 R2T4 calculations. 2. Training Initiatives o Provided department-wide training on R2T4 policies and procedures. o Delivered in-depth training sessions specifically tailored for the R2T4 team. o The R2T4 team has successfully completed NASFAA’s R2T4 course series to enhance their expertise. 3. Staffing Adjustments o An Accounting Technician under the direction of the District Business Manager will be assigned to Financial Aid to support R2T4 processing and reconciliation to ensure accuracy and compliance. o Additionally, this Accounting Technician will need to have view-only access to all data and reports available in the Student Financial Aid module contained in Colleague in o order to be effective in providing meaningful analysis and reconciliation of student-level detail to summary ledgers and reports contained in the Fiscal Services module of Colleague and other financial reporting tools. 4. Process Improvements o Instruct the R2T4 team to use the Department of Education’s R2T4 worksheet in the COD system instead of the R2T4 module in Colleague. o This change addresses the lack of automation and checks in the Colleague system, which has been a contributing factor to discrepancies. o Financial Aid has reached out and established rapport and protocols with academic and registrar offices to enhance understanding of academic engagement, registration processes, and data fields. o The department has updated the policy and procedures manual, including cheat sheets to clarify points of regulatory interpretation along with El Camino’s data fields to use. 5. System and Workflow Evaluation o Identified that the R2T4 module in Colleague lacks automation or checks and balances to flag manual input discrepancies. o Future plans include exploring system enhancements or alternatives to improve functionality and reduce reliance on manual calculations. o The District has begun evaluating ways to improve the R2T4 reports to help automate this process as much as possible. Name of the contact person responsible for corrective action: Chau Dao, Director of Financial Aid & Basic Needs Planned completion date for corrective action plan: Implementation Timeline:  Consultant Review: Begin immediately, with ongoing review throughout the 2024-2025 aid year; retain consultant services for 2025-2026 aid year.  Training: Complete with Spring 2025 R2T4 calculation, with periodic refresher sessions scheduled on an annual basis.  Staffing Request: The Accounting Technician position will be assigned no later than July 1, 2025. This position shall be filled by existing accounting staff or, if needed, a new employee.  Process Transition: Full transition to the COD system worksheet for R2T4 calculations with the Fall 2024 term R2T4 calculation.  System Evaluation: Initiate and maintain ongoing discussions with IT and software providers, leveraging opportunities from conferences, networking events, and training sessions to explore and implement improvements. Monitoring and Evaluation:  Conduct monthly audits of R2T4 calculations to identify and address errors promptly.  Maintain ongoing collaboration with the consultant to refine processes and implement best practices.  Evaluate the effectiveness of new training and staffing adjustments after six months and report findings.

View Audit 344288

Finding 524920 (2024-002)

Significant Deficiency 2024

Howard Community College

MD

Special Tests & Provisions Questioned Costs Student Financial Aid § 200.303

2024‐002: 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. Recommenda...

2024‐002: 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: Howard Community College will work with Records, Registration and Veterans Affairs (RRVA) to conduct a thorough review of the current policies and procedures for reporting student enrollment status changes and effective dates to NSLDS and then subsequently implement process improvements to ensure that our process aligns with federal regulations. Name(s) of the contact person(s) responsible for corrective action: Jessica Peterson, Registrar Planned completion date for corrective action plan: June 30, 2026

View Audit 344285

Finding 524916 (2024-005)

Significant Deficiency 2024

Howard Community College

MD

Questioned Costs Student Financial Aid Significant Deficiency § 200.303

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation:...

2024 – 005: Population for Return of Title IV Funds Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The College was unable to provide the required population for the students that withdrew during the fiscal year in a timely manner. Recommendation: It is recommended that the College strengthens its internal controls and improves coordination among departments to ensure timely submission of required data for the Return of Funds. This may include implementing a more robust tracking system, providing additional training to staff, and establishing clear deadlines and responsibilities for data submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services will work with the Administration Information Systems department along with other stakeholders to strengthen its internal controls and improve communication. Additionally, Howard Community College will work with AIS to develop and implement a more robust system to track and review the data required to complete the Return of Funds process. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Planned completion date for corrective action plan: June 30, 2026 If the U.S. Department of Education has questions regarding this plan, please call Detra Hooper, Financial Aid Services Director at 443‐518‐4776.

View Audit 344285

Finding 524915 (2024-004)

Significant Deficiency 2024

Howard Community College

MD

Questioned Costs Student Financial Aid Reporting § 200.303

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recom...

2024 – 004: Fiscal Operations Report and Application to Participate (FISAP) Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: The documents retained by the University to support amounts included in the FISAP did not agree to the FISAP. Recommendation: It is recommended that the College strengthens its internal controls and verification processes to ensure the accuracy of data reported in the FISAP. This may include creating a formalized review process for the FISAP and ensuring all supporting schedules used to populate the form are centrally stored. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Services has created a formalized review process for FISAP and created a central location to store data. This review process includes multiple staff members and internal controls for future review. Name(s) of the contact person(s) responsible for corrective action: Detra Hooper, Financial Aid Services Director Planned completion date for corrective action plan: June 30, 2025

View Audit 344285

Finding 524914 (2024-003)

Significant Deficiency 2024

Howard Community College

MD

Subrecipient Monitoring Internal Control / Segregation of Duties Student Financial Aid § 200.303

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the ...

2024‐003: Special Tests and Provisions – Gramm‐Leach‐Bliley Act Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Condition: Certain elements of the College’s information security program were not maintained in written form. Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Howard Community College will work with the Administrative Information Systems (AIS) department to conduct a thorough review of the written information security program to ensure the necessary elements are included and meeting the minimum requirements as outlined in 16 CFR 314.4. Name(s) of the contact person(s) responsible for corrective action: Tyria Stone, Executive Vice President, Finance & Administration

View Audit 344285

Finding 524897 (2024-002)

Significant Deficiency 2024

Town of Coventry, Connecticut

CT

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

UNITED STATES DEPARTMENT OF THE TREASURY 2024-002 COVID-19 – American Rescue Plan Act – Assistance Listing No. 21.027 Recommendation: We recommend that the Town review its procedures over grant reporting requirements to ensure all reports are reviewed and documentation of that review is retained. ...

UNITED STATES DEPARTMENT OF THE TREASURY 2024-002 COVID-19 – American Rescue Plan Act – Assistance Listing No. 21.027 Recommendation: We recommend that the Town review its procedures over grant reporting requirements to ensure all reports are reviewed and documentation of that review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Although there were no errors in the reporting, to ensure efficiencies, staff other than the Finance Director will review grant reporting and sign off before it is submitted. Name(s) of the contact person(s) responsible for corrective action: Julie Chapman Planned completion date for corrective action plan: February 1, 2025

View Audit 344253

Finding 524881 (2024-002)

Significant Deficiency 2024

East Windsor Regional School District

NJ

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Questioned Costs § 200.403 § 200.430

Cross training will occur between the BA, Assistant BA and the Senior Accountant. In the event of extended vacancies or absences, multiple staff members will be trained on filing correct final reports.

View Audit 344245 Questioned Costs: $1

Finding 524876 (2024-001)

None 2024

East Windsor Regional School District

NJ

Questioned Costs Reporting Internal Control / Segregation of Duties

Cross training will occur between the BA, Assistant BA and the Senior Accountant. In the event of extended vacancies or absences, multiple staff members will be trained on filing correct final reports.

View Audit 344245

Finding 524870 (2024-001)

Significant Deficiency 2024

Markesan District Schools

WI

Internal Control / Segregation of Duties

Finding #2024-001 – Lack of Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Checks and balances should be in place to allow management or employees, in the normal course of ...

Finding #2024-001 – Lack of Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Checks and balances should be in place to allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct any misstatements on a timely basis. Cause: A small number of individuals within the District’s administration perform substantially all accounting functions and have control over both records and assets. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the District’s operations. Response: We agree and will continue to provide supervision and monitor accounting information and operations, obtain explanations for variances from unexpected results and work to increase segregation of duties. The Assistant to the Business Manager will continue to clear checks in Skyward as part of the bank reconciliation process. The District Administrator will review and initial all journal entries. The Assistant to the Business Manager will review payroll on a monthly basis, and the District Administrator will review payroll on a quarterly basis. Contact Person: Tim Zacharias Anticipated Completion: Not Applicable

View Audit 344235

Finding 524859 (2024-002)

Significant Deficiency 2024

High Point University

NC

Questioned Costs Special Tests & Provisions HUD Housing Programs

Finding 2024-002 Program: Federal Work-Study Program Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2023 - 2024 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program fi...

Finding 2024-002 Program: Federal Work-Study Program Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2023 - 2024 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and that all amounts paid are appropriately earned. University’s Response: The University continues to emphasize and reinforce with its students and student supervisors that, regardless of whether jobs are funded by the Federal Work Study program or by the institution, students must not be working during scheduled class hours regardless of whether the class is cancelled or let out early. The Student Employment Program holds annual training sessions for and provides updated publications to these responsible individuals. As part of the University student employment application process, students must submit their class schedule with their application. The University expects supervisors to utilize the student class schedules provided and keep work schedules distinct. The University also expects that supervisors continue to obtain students class schedules each semester and updates students work schedules accordingly each semester to ensure students are not working during times they are in class. The University continues to use the internal audit process it instituted in February 2023. A sample of student work records from the previous semester will be compared to students’ class schedules to ensure students are not working during class hours. This review will be performed by Michael Peeler, Vice President for Financial Affairs. Any violations of the school’s student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Corrective Action Plan: The University’s Student Employment Office continues to send monthly emails to student employee supervisors and to the student staff, reminding them of the student employment guidelines they are expected to abide by. This communication reminds them of their responsibility to adhere to student employment guidelines and their responsibility to keep their supervisor informed of any changes they may make to their class schedule that could require their work schedule to be adjusted. Since the hours of overpayment appeared to be resulting from students failing to clock out and managers failing to catch inaccurate hours of record (working for eight or more hours in a day, working overnight, etc.), further training and instruction to pay closer attention to these discrepancies so they are corrected at the time of approving timesheets has been provided to student employee supervisors as part of the monthly email communication. Student employee supervisors will continue to be expected to hold a mandatory meeting with their student staff at or before the start of each semester.The University’s internal audit process is also being expanded to be performed quarterly, twice each semester. This process will continue to sample student work records at the midpoint and end of the fall and spring semesters, where students’ class schedules are compared to hours worked to ensure students are not working during class hours. Michael Peeler, Vice President for Financial Affairs, will perform this review. Any violations of the school’s student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services; Sandra Fantauzzi, Student Employment Program Manager; Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs Anticipated Completion Date: March 31, 2025

View Audit 344215 Questioned Costs: $1

Finding 524858 (2024-001)

Significant Deficiency 2024

High Point University

NC

Cash Management Internal Control / Segregation of Duties Questioned Costs

Finding 2024-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely mann...

Finding 2024-001 Program: Federal Family Education Loans Assistance Listing No.: 84.032 Federal Agency: Department of Education Award Year: Various Compliance Requirement: C – Cash Management – The University must return all excess cash received from the U.S. Department of Education in a timely manner, if funds are not credited to an enrolled student’s account within 3 business days following the receipt of funds. University’s Response: The University has continued to ensure these funds are not comingled and has protected them from spending. Because of the discrepancies identified, each student’s loan history had to be reviewed and compared between the University Information System, the lender rosters, and the National Student Loan Database System (NSLDS) records. This individual review and reconciliation have proven to be a tedious but necessary process to identify the funds never posted to student records, returned to lenders, or entered incorrectly in the three separate systems of record. Corrective Action Plan: The University, working with an external financial aid consulting firm with experience in reconciling FFEL loan programs, has finished researching all related accounts against the National Student Loan Database System (NSLDS) records. Our next steps include consolidating student returns to each of the different lenders, working with the Department of Education to determine how to return funds in instances where the last lender used is no longer available to process student loan funds, and lastly, book the appropriate entries for any funds determined to belong to the University that were not moved to the University operating accounts properly at the time of the transactions. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services Anticipated Completion Date: May 31, 2025

View Audit 344215

Finding 524822 (2024-001)

Significant Deficiency 2024

The College of New Jersey

NJ

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.403 § 200.430

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administra...

Corrective Action Plan for Current Year Findings June 30, 2024 Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Responsible Person: Karen Miller, Controller 609-771-2203 Jeanette Vega, Director of Grant Financial Administration 609-771-2847 Corrective Action Plan: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions from July 1, 2023, to December 31, 2023, in the fiscal year being audited. The effort was certified after the fiscal year, as part of the year-end process which was not in line with the semi-annually time frames as historically done with guidance in our Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). The timing delays occurred due to staffing vacancies and knowledge transfer of current staff as well as misalignment of staffing. Once the staffing was realigned, trained, and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed. This task occurred during the months between August 2024 and November 2024 which was outside the policy time frames. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance by taking corrective action steps to improve monitoring and oversight, strengthen training and communications, and develop an action plan for corrective timing. The College implemented part of the corrective action on August 01, 2024, retroactive to July 1, 2023, and will complete the remaining items by the end of the next fiscal year. Anticipated Completion Date: June 30, 2025

View Audit 344210

Finding 524808 (2024-001)

Significant Deficiency 2024

Corban University

OR

Questioned Costs Student Financial Aid Significant Deficiency

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The academic calendar has been updated between academic catalog and website ensuring better accuracy. Policies and procedures surrounding the date of withdrawal and what constitutes an academic break have also been corrected and u...

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The academic calendar has been updated between academic catalog and website ensuring better accuracy. Policies and procedures surrounding the date of withdrawal and what constitutes an academic break have also been corrected and understood across the Registrar and Financial Aid offices. Financial Aid professionals have also been added to internal meetings where decisions on programs, academic calendars, and other significant timing decisions are made to better enhance our ability to comply. Person Responsible for Corrective Action Plan: Jordan Lindsey, Vice President for Enrollment Management and Marketing Anticipated Date of Completion: 2/1/25

View Audit 344190 Questioned Costs: $1

Finding 524791 (2024-003)

Significant Deficiency 2024

University of Dubuque

IA

Questioned Costs Subrecipient Monitoring Equipment & Real Property Management § 200.303

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive securi...

Finding: The University has not created or implemented a comprehensive information security policy. Corrective Actions Taken or Planned: These policies are currently in place and regularly practiced. Currently the University of Dubuque is in the process of formally writing up a comprehensive security policy. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 10/01/2024

View Audit 344180

Finding 524786 (2024-001)

Significant Deficiency 2024

Villanova University

PA

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

Villanova University agrees with this finding. During the year, there was turnover at the University, and we acknowledge the training of new staff must be a priority to ensure continuity of key controls. Appropriate training and new internal control processes that would have detected this error hav...

Villanova University agrees with this finding. During the year, there was turnover at the University, and we acknowledge the training of new staff must be a priority to ensure continuity of key controls. Appropriate training and new internal control processes that would have detected this error have been implemented. The department has created a submission file consisting of new graduates only to be transmitted to the National Student Clearinghouse at the end of May and another at the end of June to identify any additional students to report. In addition, the University has created a Graduation Audit Report to be used internally to verify the change in status for students who graduated, and a final validation check performed by the Senior Assistant Registrar for Student History to confirm accuracy of student status. Name of contact person: Susan Morgan, Director of Technical Student Systems, Registrars Office Anticipated Completion date: May 2025 in conjunction with the next submission of graduation files

View Audit 344168

Finding 524785 (2024-003)

Significant Deficiency 2024

Bethel University and Affiliates

MN

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no dis...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On October 26, 2024, three modifications were made to the reporting tool the financial aid office uses for Return of Title IV Funds calculations to draw attention to situations when the “student completed more than 49% of a course” exception applies. First, we added a formula to the "5 - Title IV Checklist Revised" sheet in cell D16:F17. If the answer to question 11 "Exemption 3b: Successfully complete >49%?" is Yes, the following narrative will appear in blue, bold, font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Second, we modified a formula in cell J34 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, red font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Third, we added a formula to cell E36 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, blue font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." In addition, we completed additional training with the financial aid staff who complete R2T4 calculations to ensure they (a) understand rules related to the “student completed more than 49% of a course” exception, and (b) are aware of the additional warning messages that will appear in our R2T4 calculation spreadsheet. Name of the contact person responsible for corrective action: Jeffrey D Olson, Interim Director of Financial Aid Planned completion date for corrective action plan: October 26, 2024.

View Audit 344164 Questioned Costs: $1

Finding 524779 (2024-002)

Material Weakness 2024

Bethel University and Affiliates

MN

Questioned Costs Student Financial Aid Material Weakness

Student Financial Assistance Cluster – Assistance Listing No. Various 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: ...

Student Financial Assistance Cluster – Assistance Listing No. Various 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. Background: The Bethel University Registrar is responsible for ensuring timely and accurate reporting to NSLD via the National Student Clearinghouse. Cheryl Fisk was appointed to serve as University Registrar on August 1, 2022. While new to Bethel, she is not new to Clearinghouse reporting. She assumed the oversight of the Clearinghouse reporting and is working to ensure timely, accurate submissions. • Bethel reports student enrollment to NSLDS via the National Student Clearinghouse • Currently, the people involved in the process include: o Data Management Team: Ana Ortiz, Records and Data Specialist o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Bethel Information Technology Staff Based on the previous audit, adjustments were made to standardize the submissions to the Clearinghouse. Extra efforts were made to ensure that needed corrections were done within the required time frame. We have started to simplify our degree conferral policy to improve the accuracy of the reporting of graduates. However, because of major changes in the Information Technology Department staffing, we were not able to research how the submission reports are compiled or the automatic process that is used to clean and prepare the data before it is added to the submission reports. We have reviewed the Clearinghouse training. We have also sought the advice from other institutions who report to the Clearinghouse. We originally thought that the frequency of our batches was the problem. However, it appears that the issues may be in the way the submission data are prepared and compiled into the submission reports. Multiple reports must be compiled and then combined to create the submission for both branches. Corrective Action: Our corrective action will involve several parts. • First, we will work ITS staff to determine which fields and tables the submissions are using to create the Clearinghouse reports. Currently, the submission batches are reporting on two branches where multiple terms (i.e. termcodes) are involved. The reports may need to some revision. • Second, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner • Third, we will monitor closely what the Clearinghouse records show for graduation and withdrawal dates for students in comparison to what is in our student information system to ensure they are in sync. Then we will double check that information to what is showing at NSLDS. Corrections will be made if needed. • Fourth, we will continue to adjust our conferral process to ensure that graduation information is reported in a timely way • Fifth, we will confer with the Financial Aid Office when dealing with complicated registration changes. This will ensure we are in sync in our interpretations of the situation. • Sixth, we will continue to take advantage of Clearinghouse, Banner, and any other related training opportunities. Name of Contact person Responsible for Corrective Action: Cheryl Fisk Planned completion date for the correction action plan: June 1, 2025. This will provide time to test corrective measures to ensure everything is submitting properly.

View Audit 344164

Finding 524777 (2024-001)

Significant Deficiency 2024

Mercyhurst University

PA

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

Finding: During testing of Perkins Loan Recordkeeping and Record Retention, the University could not provide a signed promissory note for three out of four loans selected for testing. View of responsible officials and corrective action: Management understands the recommendation and the need to ret...

Finding: During testing of Perkins Loan Recordkeeping and Record Retention, the University could not provide a signed promissory note for three out of four loans selected for testing. View of responsible officials and corrective action: Management understands the recommendation and the need to retain the records of former students. While we are certain that required documentation exists or existed at one time, the passage of time and lack of digital backups impaired our ability to produce the documents. Since the loans related to the missing documents are currently in repayment status, we feel that provides assurance that the former students did sign the loan agreement. However, we understand the need to retain all critical forms for our students.

View Audit 344161

Finding 524775 (2024-002)

Significant Deficiency 2024

Mercyhurst University

PA

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Finding: During the course of testing return of Title IV funds, the calculation was not accurate for one student from the sample and therefore the proper amount of funds to be returned in the appropriate time required was not accurate. View of responsible officials and corrective action: Managemen...

Finding: During the course of testing return of Title IV funds, the calculation was not accurate for one student from the sample and therefore the proper amount of funds to be returned in the appropriate time required was not accurate. View of responsible officials and corrective action: Management understands the need for accurate calculation of funds to be returned. An additional step has been added to the process for the return of Title IV funds process. All calculations are now reviewed by a manager before release to ensure funds are calculated correctly and returned in the appropriate timeframe.

View Audit 344161 Questioned Costs: $1

Finding 524761 (2024-004)

Significant Deficiency 2024

Resources for Human Development, INC

PA

Questioned Costs Special Tests & Provisions Significant Deficiency § 200.302

Management will review the SFDS protocols and processes with the appropriate staff in order enable the consistent application of sliding fees. This will be completed by June 30, 2025.

View Audit 344160

Finding 524737 (2024-002)

None 2024

Resources for Human Development, INC

PA

Questioned Costs Reporting Internal Control / Segregation of Duties

Management agrees that the closing process needs to be improved to allow for timely closing of the general ledger and financial reporting in compliance with federal and other regulatory deadlines. Effective May 2024, RHD has implemented a shortened monthly and year-end closing schedule to assist in ...

Management agrees that the closing process needs to be improved to allow for timely closing of the general ledger and financial reporting in compliance with federal and other regulatory deadlines. Effective May 2024, RHD has implemented a shortened monthly and year-end closing schedule to assist in meeting this goal. Management also believes that audit timing for the fiscal year ended June 30, 2023 was an anomaly based on the identified need for corporate restructuring that was occurring concurrently with audit process. This added complexity to the subsequent event disclosures and testing required. Additionally, RHD formally affiliate with Inperium as disclosed in Note 3 of the accompanying financial statements. The affiliation was closed on December 11, 2024. Systems and closing procedures will be evaluated and redesigned as part of the affiliation integration process.

View Audit 344160

Finding 524706 (2024-002)

Significant Deficiency 2024

Housing and Redevelopment Authority of Austin

MN

Cash Management Internal Control / Segregation of Duties Questioned Costs

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Complia...

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Recommendation: We recommend that the HRA continue to evaluate their procedures and controls in place over the draw down of funds. Management’s Response: Management agrees with the finding and will continue to monitor the draws to ensure they are spent within the required timeframe. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will ensure that all draws of funds are spent within the required timeframe. Official Responsible for Ensuring CAP: Angela Maiden, Finance Director, is the official responsible for ensuring corrective action of the deficiency. Planned Completion Date for CAP: September 30, 2025 Plan to Monitor Completion of CAP: Taggert Medgaarden, Executive Director, will ensure that the draw downs are properly managed through discussions with the Finance Director.

View Audit 344136 Questioned Costs: $1

Finding 524703 (2024-001)

Significant Deficiency 2024

Abbotsford Housing Authority

WI

Internal Control / Segregation of Duties Reporting

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongo...

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing

View Audit 344133

Finding 524683 (2024-001)

Significant Deficiency 2024

Texas Association for the Education of Young Children, Inc.

TX

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

Management Response: TXAEYC’s Payroll Processing section of the Accounting Manual will be updated to reflect the following changes: “Direct supervisors will review and approve their direct reports’ timesheets to ensure time is accurately recorded and all hours worked are assigned a cost allocation...

Management Response: TXAEYC’s Payroll Processing section of the Accounting Manual will be updated to reflect the following changes: “Direct supervisors will review and approve their direct reports’ timesheets to ensure time is accurately recorded and all hours worked are assigned a cost allocation. The Director of Operations conducts a second layer of approval for all employee timesheets and processes payroll via the payroll platform. The Director of Operations may not process payroll without ensuring Supervisor Approval has been entered for all timesheets within the payroll platform. Additionally, the Director of Operation shall approve the timesheet of the Executive Director/Chief Executive Officer.” Parties Responsible and Timeline Updates to the Accounting Manual will be approved by TXAEYC’s Finance Committee and Governing board by April 30, 2025. The Director of Operation will implement changes to approved by the Finance Committee and Governing Committee immediately following their approval.

View Audit 344111

Finding 524679 (2024-004)

Significant Deficiency 2024

La Salle University

PA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster-Assistance Listing No. 84.0007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Explanati...

Student Financial Assistance Cluster-Assistance Listing No. 84.0007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding 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 : La Salle University will identify outstanding not cashed checks for each term. A term is normally 4 months in total as each semester generates a list of uncashed checks. Within two weeks of establishing outstanding checks, we will send letters to students informing them that they have outstanding refund checks. For approximately six months, the process of reviewing the outstanding list repeats, and if a check has not been cashed, another letter of notice is mailed. After six months, finance will send the outstanding list to Student Financial Services for a 30-day final review/outreach. At 21 O days from original refund issuance, Finance will provide the list to Financial Aid who will return balances to DOE. Name(s) of the contact person(s) responsible for corrective action: Zak Thornton, Assistant Vice President of Finance Planned completion date for corrective action plan: Corrected as of Spring 2025.

View Audit 344109 Questioned Costs: $1

Corrective Action Plans

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