Corrective Action Plans

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December 27, 2024 Finding Number: 2024-003 Material Weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) (Wagner Peyser) Finding Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (req...
December 27, 2024 Finding Number: 2024-003 Material Weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) (Wagner Peyser) Finding Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Planned Corrective Action: The Consortium has carefully reviewed our policies and procedures and have made the necessary changes to ensure that cash draws are based on expenditures already incurred and that they are supported by transactions recorded in the general ledger. Cash draws continue to be “necessary and reasonable”. We strive to improve the timing of our cash draws, our grant reconciliations and to continually monitor our cash management to ultimately eliminate this issue. Responsible Contact Person: Shamar Herron (Executive Director) Sherron@mwse.org Anticipated Completion Date: March 2025 Respectfully, Shamar Herron
FSTC will submit the SF-SAC Single Audit Data Collection Forms within the required timeframes in the future or agency will request an extension to file.
FSTC will submit the SF-SAC Single Audit Data Collection Forms within the required timeframes in the future or agency will request an extension to file.
The District has revised its drop protocol documentation to provide a clearer, more streamlined process for staff, ensuring all required documentation is collected before processing drop codes in CALPADS. Additionally, comprehensive training has been provided to all staff responsible for this task t...
The District has revised its drop protocol documentation to provide a clearer, more streamlined process for staff, ensuring all required documentation is collected before processing drop codes in CALPADS. Additionally, comprehensive training has been provided to all staff responsible for this task to support accurate and efficient implementation.
The District will be updating its process and procedures to ensure that adequate written documentation for all students removed from the cohort is maintained and the data accurately inputted into the CALPADS system. Our Director who oversees CALPADS will be responsible for ensuring training is prov...
The District will be updating its process and procedures to ensure that adequate written documentation for all students removed from the cohort is maintained and the data accurately inputted into the CALPADS system. Our Director who oversees CALPADS will be responsible for ensuring training is provided to staff responsible for this task.
Finding 519209 (2024-002)
Significant Deficiency 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Special tests and Provisions - Enrollment Corrective Action Plan: The Admissions and Records Office is currently responsible for reporting student enrollment to National Student Cle...
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Special tests and Provisions - Enrollment Corrective Action Plan: The Admissions and Records Office is currently responsible for reporting student enrollment to National Student Clearinghouse (NSC). Once enrollment is validated and certified, it is reported directly to the National Student Loan Data System (NSLDS). Grayson College does not report enrollment directly in NSLDS. The OFA requests a copy of the validated and certified NSC enrollment report from the Admissions and Records Office to double check accuracy by performing a random selection of students to confirm they have been reported correctly in NSLDS. If, for some reason, a student’s enrollment is not correct in NSLDS, the OFA contacts NSC to get an understanding as to why it is not reported correctly to NSLDS. This happens after each validated and certified cycle, including all module terms (8-week and mini-mester). The College is investigating how to conduct a batch validation, which will be more robust than the sampling method. GC Financial Aid staff have received additional training and understand the importance of V4 and V5 verification coupled with accurate reporting to the NSLDS. They are committed to making sure these actions as stated occur each semester. Name of Contact Persons: Carolyn Kasdorf - Vice President of Business Services. Stephanie Martin - Director of Financial Aid and Veteran Services Projected Completion Date: 2025
Finding 519205 (2024-001)
Significant Deficiency 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Special Tests and Provisions - Verification Corrective Action Plan: The Office of Financial Aid (OFA) has begun to monitor students that are selected for V4 and V5 verification by t...
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Special Tests and Provisions - Verification Corrective Action Plan: The Office of Financial Aid (OFA) has begun to monitor students that are selected for V4 and V5 verification by the U.S. Department of Education. Once available on FSA Partner Portal, the OFA reports any students that have or have not submitted necessary paperwork to finalize verification. After initial reporting, the OFA continues to monitor and report new V4 & V5 students within the 60-day timeframe requirement. Once students fulfill the verification request, the OFA updates the Verification of Identity portal as applicable. As of December 2, 2024, the Verification of Identity portal is not available for either 2024-25 or 2025-26 reporting for any Institution of Higher Education. At this time, it is unknown when the portal for reporting will be available. Name of Contact Persons: Carolyn Kasdorf - Vice President of Business Services. Stephanie Martin - Director of Financial Aid and Veteran Services Projected Completion Date: 2025
Finding 519191 (2024-009)
Significant Deficiency 2024
Finding: 2024-009 Name of contact person: Dr. Justin Hoggard, Board President and CFO Corrective Action: Management will review invoice documentation. Proposed Completion Date: April 30, 2025 Anticipated Completion: April 30, 2025
Finding: 2024-009 Name of contact person: Dr. Justin Hoggard, Board President and CFO Corrective Action: Management will review invoice documentation. Proposed Completion Date: April 30, 2025 Anticipated Completion: April 30, 2025
2024-001 Investments for Public Works and Economic Development Facilities – Assistance Listing No. 11.300 Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timel...
2024-001 Investments for Public Works and Economic Development Facilities – Assistance Listing No. 11.300 Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Routine communication between program directors and accounting staff will include discussion of reporting timeline in order to ensure timely submission. The Finance Department will review and approve required reports that are prepared by grant program directors. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler, Chief Financial Officer Planned completion date for corrective action plan: February 28, 2025.
2024-002 Student Financial Assistance Cluster - Assistance Listing No. 84.007; 84.033; 84.063; 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Expla...
2024-002 Student Financial Assistance Cluster - Assistance Listing No. 84.007; 84.033; 84.063; 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The records identified with incorrect R2T4 calculations have been recalculated, reported to COD and funds returned. In order to best ensure policies and procedures for R2T4 calculations, additional staff have been trained to ensure calculations are checked and double checked to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson, Director of Financial Aid, Veteran Services & Student Employment Planned completion date for corrective action plan: All corrections have been submitted as of October 9, 2024. Training of additional staff in progress – to be completed by February 28, 2025.
This segregation of duties weakness is impratical to totally correct due to the limited resources and staff available to the district. The District will continue to use other controls, where practical, to compensate for this limitation.
This segregation of duties weakness is impratical to totally correct due to the limited resources and staff available to the district. The District will continue to use other controls, where practical, to compensate for this limitation.
Title funds reporting responsibilities and timeline Meeting attendants: Cynthia Marrero[grant coordinator], Janira Gonzalez[accounting supervisor], Parth Patel [senior accountant], and Xin Yi [CFO] Date: 11/19/2024 Below the clarification regarding Title Funds grant reporting:  In May, PDE issues a...
Title funds reporting responsibilities and timeline Meeting attendants: Cynthia Marrero[grant coordinator], Janira Gonzalez[accounting supervisor], Parth Patel [senior accountant], and Xin Yi [CFO] Date: 11/19/2024 Below the clarification regarding Title Funds grant reporting:  In May, PDE issues a preliminary award for the following school year  In the first week of July, Grant Coordinator submits consolidated application with grant budget o Grant Budget (eGrants) prepared by Grant Coordinator needs to match with school-wide plan (FRCPP) by Principals o Grant coordinator will request salaries and benefits information from Payroll Director and vendor information based on plans o THe positions listed in the plan and budget need to meet twice a year. The school principals need to document it. The Grant Coordinator will communicate it. o Grant Coordinator needs to provide the award letter and the consolidated application/agreement to the Accounting Department as soon as it’s approved.  In July, Senior Accountant needs to accrue the revenues based on the preliminary allocation o The Senior Accountant needs to update the AR workpaper to reflect the allocation.  Starting in January during the school year, the Senior Accountant needs to file the quarterly cash on hand report (three reports) based on estimated expenses. The report is due by the 10th of the month following the conclusion of each quarter. o When grant expenses need to be reconciled and reclassified between Grant Coordinator and Accounting Supervisor monthly. The Accounting Supervisor sets up the recurring calendar invite. o Accounting Supervisor needs to review and confirm o The Accounting Supervisor sets up a calendar reminder for the Senior Accountant to prepare the quarterly cash on hand report and another one for the due date.  In January, Grant Coordinator will collect time and efforts certificates for positions included in the plan and budget from July (or whenever the grant period starts) to December  In February, PDE issues the revised allocation. The Grant Coordinator needs to forward those revised award letters to the Accounting Department as soon as they’re received.  In March, Senior Accountant needs to reconcile and accrue revenues based on revised allocation. If needed, a retroactive adjustment is made for year to date revenues o Senior Accountant needs to update AR work paper to reflect the revised allocation  By April, Grant Coordinator needs to submit the revised application along with the budget to match the school wide plan o The Grant Coordinator needs to send a copy of the revised consolidated agreement to the accounting department as soon as they’re approved.  In July, Grant Coordinator needs to compile the expenses for final expenditure report (FER) and submit the reports o A copy of the FER needs to be provided to the accounting department.  In July, Grant Coordinator will collect time and efforts certificates for positions included in the plan and budget from January to June  In August, the AR workpaper needs to reconciled to be audit ready in both cash receipts and revenue accrual
CORRECTIVE ACTION PLAN: Staff transitions in Financial Aid and the Enrollment Center at the onset of the Fall 2023 term contributed to the later-than-usual submission/certification of First of Term enrollment reporting. Financial Aid and the Enrollment Center experienced staff shortages with resign...
CORRECTIVE ACTION PLAN: Staff transitions in Financial Aid and the Enrollment Center at the onset of the Fall 2023 term contributed to the later-than-usual submission/certification of First of Term enrollment reporting. Financial Aid and the Enrollment Center experienced staff shortages with resignations and leave. The initial fall enrollment (First of Term) was certified by the Institution and submitted to the National Student Clearinghouse (NSC) on October 18, 2024 within 60 days of the start of the term on August 21, 2023, but the National Student Loan Data Systems (NSLDS) did not receive the submission within the 60-day requirement. Although we anticipate this to be a one-time incident, to prevent any recurrence and ensure enrollment changes are reported to NSLDS within 60 days, Financial Aid provided additional staff training in the Enrollment Submission process, and Early Registration enrollment submissions will be submitted within the first week of classes with the First of Term enrollment submission sent during the third week of classes. Financial Aid also updated the Institution’s NSLDS profile to ensure that records submitted for NSLDS Transfer Monitoring and Financial Aid History are added to the Enrollment Roster submitted to NSC. Financial Aid and the Registrar established an updated policy to ensure that Financial Aid is informed of students who graduate after the graduation process runs each term. After that, the Registrar will report late graduations to the National Student Loan Data System (NSLDS) via the National Student Clearinghouse (NSC). Financial Aid updated the student in question’s graduation status in NSLDS. Person(s) Responsible: Angela Weaver Timing for Implementation: Immediate
CORRECTIVE ACTION PLAN: At Lewis & Clark, the Direct Loan acceptance process switched from affirmative confirmation to passive confirmation to streamline the student loan process for students. For loans accepted via affirmative confirmation, the loan notification must be sent no earlier than 30 day...
CORRECTIVE ACTION PLAN: At Lewis & Clark, the Direct Loan acceptance process switched from affirmative confirmation to passive confirmation to streamline the student loan process for students. For loans accepted via affirmative confirmation, the loan notification must be sent no earlier than 30 days before and no later than 30 days after crediting the student’s account. The student or parent has 14 days from the notification date to request the loan cancellation. For loans accepted via passive confirmation, the loan disbursement notification must be sent no earlier than 30 days before or 7 days after crediting the student’s account. The student or parent then has 30 days from the date of the notification to request cancellation of the loan. Although the new timeline for a student to cancel a loan was reviewed prior to the process change to passive confirmation, Financial Aid neglected to update the notification letter at the time of implementation. The loan notifications now reflect the 30 days for loan cancellation. Cancellation requests of loan funds are processed promptly. Although the timeline to request a cancellation of all or a portion of a loan previously indicated a 14-day deadline, the Financial Aid office accepts most requests beyond the 14 to 30 days. However unlikely, if more than 120 days have elapsed since loan funds were disbursed, loan funds cannot be returned on the borrower’s behalf. In Spring 2024, Financial Aid established a process to send loan notifications in conjunction with weekly financial aid transmittals to ensure compliance with sending loan notifications within 7 days of crediting a student’s account. A Direct Loan transmittal report (TFAR-Transmitted FA Report) is generated through Colleague (ERP Software) weekly throughout each term, and loan notifications are emailed weekly to students whose student loans are credited to their accounts during that weekly process. To prevent Post-withdrawal disbursements of loan funds from updating and transmitting to student accounts before receipt of acceptance of post-withdrawal disbursements (PWD), upon completion of the Return of Federal Funds calculation, Financial Aid will delay updating student accounts until confirmation of acceptance within the established 14-day timeframe; this is a change from the previous practice of updating the student record and then denying the PWD until acceptance of loan funds. Person(s) Responsible: Angela Weaver Timing for Implementation: Immediate
Federal Program, Assistance Listing Number and Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility dete...
Federal Program, Assistance Listing Number and Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were reviewed by a contractor for the program. Contact Person Responsible for Corrective Action / Anticipated Completion Date - Julie Schneider; Anticipated completion date: June 2025 Planned Corrective Action - The City will implement a control for completeness and accuracy by hosting regular meetings with the contractor to review recent projects for which the contractor has documented their determinations of income eligibility. When a recently-reviewed project is not due for an annual review, staff will still have timely insight into the income eligibility of properties in its HOME portfolio, thereby maintaining compliance with HOME program regulations.
Federal Program, Assistance Listing Number and Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description - The City is required to track and report program income within HUD’s Integrated Disbursement and Information ...
Federal Program, Assistance Listing Number and Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description - The City is required to track and report program income within HUD’s Integrated Disbursement and Information System (IDIS) and the general ledger. The city reported fiscal 2024 program income in fiscal 2025. Contact Person Responsible for Corrective Action / Anticipated Completion Date - Regina Greear, Julie Schneider; Anticipated completion date: June 2025 Planned Corrective Action - The city is in the process of enhancing processes and controls to ensure timely, accurate and consistent receipts of the program income and the reconciliations.
Federal Program, Assistance Listing Number and Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description - The City’s on-site inspections for compliance with the housing quality standards are triggered by City’s proc...
Federal Program, Assistance Listing Number and Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description - The City’s on-site inspections for compliance with the housing quality standards are triggered by City’s process to audit developers for compliance with HOME eligibility requirements. This basis is more restrictive than Federal requirements for Housing Quality Inspections At the end of an inspection cycle a certificate of completion is completed and signed by the responsible inspector. The City did not have effective controls to ensure the certificate of completion, is reviewed for completeness and accuracy. The City did not inspect the 20% of the units, as required by their policy. Contact Person Responsible for Corrective Action / Anticipated Completion Date - Julie Schneider; Anticipated completion date: June 2025 Planned Corrective Action - The City will review its processes and implement additional controls to ensure certificates of completion are reviewed for completeness and accuracy and to verify 20% of the units are inspected to comply with the HOME Program manual and federal regulations related to Housing Quality Standards.
Federal Program, Assistance Listing Number and Name - ALN 97.036, Department of Homeland Security, Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Condition: Original Finding Description - The FEMA grant expenses are charged to various funds in the general ledger over...
Federal Program, Assistance Listing Number and Name - ALN 97.036, Department of Homeland Security, Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Condition: Original Finding Description - The FEMA grant expenses are charged to various funds in the general ledger over several years but is managed and tracked by project in a manual spreadsheet which agrees to the amount of expenses reported on the fiscal year 2024 Schedule of Expenditures of Federal Awards (SEFA). FEMA expenditures are reported on the SEFA when there is an award and expenditures. Given that the award is made subsequent to the expenditures being incurred a manual spreadsheet is used to track expenditures being charged to the grant. There were instances of duplicated costs in the manual spreadsheet. Contact Person Responsible for Corrective Action / Anticipated Completion Date - Istakur Rahman; Anticipated completion date: June 2025 Planned Corrective Action - The identified duplicate cost was an isolated occurrence caused by an oversight during the spreadsheet preparation process. While existing controls are in place, management will perform a secondary review of the end-to-end process to enhance these controls.
The District has implemented a secondary review of ESSER reports prior to final submission.
The District has implemented a secondary review of ESSER reports prior to final submission.
Federal Agency Name: U.S. Department of Housing and Urban Development Assistance Listing Number: 14.128 Program Name: Mortgage Insurance for Hospitals Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Over Compliance and Noncompliance Fi...
Federal Agency Name: U.S. Department of Housing and Urban Development Assistance Listing Number: 14.128 Program Name: Mortgage Insurance for Hospitals Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Over Compliance and Noncompliance Finding Summary: The Hospital has amounts due from affiliate of $697,310 that are older than 90 days and is in violation of a loan covenant from HUD. Responsible Individuals: Gail Jestila, CFO Corrective Action Plan: Management implemented a repayment plan with affiliate to reduce amounts outstanding. Anticipated Completion Date: Ongoing
2024-006 - Student Financial Aid Cluster- (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268...
2024-006 - Student Financial Aid Cluster- (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 - Year Ended June 30, 2024 Condition Found The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 2 of the 40 students in the sample (5%). We consider this condition to be an instance of noncompliance in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Corrective Action Plan Student Financial Services will work with PowerFaids to determine how records are returned to COD for a disbursement date update and ensure reporting is compliant. Responsible Person for Corrective Action Plan Kandi Molder, Registrar and Executive Director of Student Services Deb Beck, Managing Director of Student Financial Services Implementation Date of Corrective Action Plan January 31. 2025
Condition: We noted that 2 out of 11 quarterly expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Managem...
Condition: We noted that 2 out of 11 quarterly expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to file all quarterly reports on time in the future.
Corrective Action Plan: Anticipated Completion Date January 15, 2025 Prior to Mono County Office of Education (MCOE) taking over this program in 2022-23, another agency was responsible for the original eligibility determinations and special tests and provisions. MCOE investigated further, and it was...
Corrective Action Plan: Anticipated Completion Date January 15, 2025 Prior to Mono County Office of Education (MCOE) taking over this program in 2022-23, another agency was responsible for the original eligibility determinations and special tests and provisions. MCOE investigated further, and it was noted that the staff at the time were not following the procedures and forms that were in place. Items were either not completed or filled out correctly in many instances. When the audit finding was identified in the 2022-23 audit, MCOE took action to immediately implement new procedures to address the items noted. Although a few items were noted during the 2023-24 audit, MCOE has made significant efforts in putting procedures in place, and will continue efforts to ensure all required documentation is complete. MCOE has developed a corrective action plan as follows to adhere to strong internal control in meeting the program’s requirements: • MCOE will ensure that existing and new staff are trained to adhere to the policies and procedures for the program. • MCOE will be conducting annual reviews of all service providers and children served to ensure MCOE is maintaining the required documents on file. • MCOE has developed a double-check procedure to ensure that staff is keeping the required documentation on file for both providers and children served moving forward. I, Jennifer Weston, CBO, will be responsible for the implementation and monitoring of the corrective action plan. Sincerely, Jennifer Weston Chief Business Officer Mono County Office of Education
Controls will be implemented for future reporting and the Organization will have the opportunity to correct the reporting errors in the subsequent periods.
Controls will be implemented for future reporting and the Organization will have the opportunity to correct the reporting errors in the subsequent periods.
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. Adam Bov...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Moving to Work Demonstration Program to ensure that established internal control policies are being followed on a timely basis. Adam Bovilsky, Executive Director, is responsible for implementing this corrective action by March 31, 2025.
View Audit 337522 Questioned Costs: $1
HUD Section 202, Capital Advance – Assistance Listing No. 14.157 Recommendation: Management should implement a review process of the management fee rate upon any changes to that rate or system utilized to calculate that rate to ensure the HUD approved rate is utilized. Management should repay the am...
HUD Section 202, Capital Advance – Assistance Listing No. 14.157 Recommendation: Management should implement a review process of the management fee rate upon any changes to that rate or system utilized to calculate that rate to ensure the HUD approved rate is utilized. Management should repay the amount due the Organization. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The controller will annually review the calculation of the management fee that is being billed to the property by the accounting manager to validate the amount is in compliance with HUD form 9839-B. The overpayment from fiscal year 2024 was corrected in October 2024 Name of the contact person responsible for corrective action: Troy Marschel. Planned completion date for corrective action plan: 10/1/2024
View Audit 337517 Questioned Costs: $1
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