Corrective Action Plans

Finding 384318 (2023-001)

Significant Deficiency 2023

Erikson Institute

IL

Internal Control / Segregation of Duties Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

Finding 2023-001: Gramm-Leach Bliley Act—Student Information Security While the Institute does have various policies addressing information security, the Institute did not have written policies to address the required safeguards for the eight required elements under the Gramm-Leach Bliley Act (GL...

Finding 2023-001: Gramm-Leach Bliley Act—Student Information Security While the Institute does have various policies addressing information security, the Institute did not have written policies to address the required safeguards for the eight required elements under the Gramm-Leach Bliley Act (GLBA) by June 9, 2023, the required date of compliance. Of the eight required elements under the GLBA, the Institute did have six written and formally documented safeguards, one is not applicable (assess apps developed by institution) and one had safeguards designed (dispose of customer information securely) but not a written policy in place. Corrective Action Plan A comprehensive formal Information Security Policy that addresses all required safeguards under the GLBA has been drafted, and as of March 2024 is in its final institutional review with approval expected in April 2024. Contact Person Ed Baker IT Director ebaker@erikson.edu Anticipated Completion Date April 2024

View Audit 297439

Finding 384307 (2023-002)

Significant Deficiency 2023

Desert Community College District

CA

Student Financial Aid Reporting Significant Deficiency

The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS w...

The District concurs with the finding. The District will establish new procedures to verify student Enrollment Reporting Roster data before submission. This will allow the district to identify discrepancies and make necessary adjustments and to ensure accurate information is reflected in the NSLDS website.

View Audit 297438

Finding 384306 (2023-001)

Significant Deficiency 2023

Desert Community College District

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

The District concurs with the finding. The District will establish procedures such as monthly reconciliation for return to Title IV calculations to identify the funds that need to be returned and ensure that funds are returned within 45 days.

View Audit 297438

Finding 384299 (2023-004)

Material Weakness 2023

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Material Weakness

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over HQS failed inspections to ensure they are following up timely on correction or properly abating HAP for the unit until correction. Explanation of disagr...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over HQS failed inspections to ensure they are following up timely on correction or properly abating HAP for the unit until correction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As noted above, the Authority has contracted the services of a third-party vendor and hired a Senior Quality Control Inspector to assist with the completion of inspections. As part of the Quality Control Plan the Authority tracks failed inspections. In addition to monitoring failed inspections, The Authority has required trainings or HCVP Department staff and partner agency staff, including HQS standards and HUD’s National Standards for the Physical Inspection of Real Estate (NSPIRE). Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024

View Audit 297428 Questioned Costs: $1

Finding 384296 (2023-003)

Significant Deficiency 2023

Virginia Housing Development Authority

VA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their processes over annual and quality-control inspections to ensure they are completed timely and in compliance with HUD’s requirements. Explanation of disagreement with...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their processes over annual and quality-control inspections to ensure they are completed timely and in compliance with HUD’s requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has contracted the services of a third-party vendor to assist with completing overdue inspections. The Authority has also hired a Senior Quality Control Inspector to assist with the completion of overdue inspections. The Senior Quality Control Inspector will develop a Quality Control Plan by [date]. The Authority is currently making software upgrades to align with HUD’s National Standards for the Physical Inspection of Real Estate (NSPIRE). In addition, the Authority is assessing technology needs of inspectors and considering possible technological improvements. Currently, The Authority PCOs have begun to monitor late inspections monthly. PCOs work with the LHAs to develop a plan to address late inspections and include a due date. Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024.

View Audit 297428

Finding 384293 (2023-002)

Material Weakness 2023

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Material Weakness

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over reasonable rent determination to ensure that it is done timely, and that the approved rent is properly carried forward to the HUD-50058 and HAP Contract/...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process over reasonable rent determination to ensure that it is done timely, and that the approved rent is properly carried forward to the HUD-50058 and HAP Contract/HAP Contract Amendment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has developed a checklist system for each step in the process for determining and documenting rent reasonableness. The checklist includes each step of the process, along with due dates, and responsible entities. As part of the development and implementation of the quality control process for the HAP process, noted above, the Authority will also include a process for ensuring approved rent reasonableness match contract rents on all supporting documentation. The Authority will implement monthly reviews of HUD-50058 forms, HAP contracts and rent reasonableness documentation by the Housing Choice Voucher Program Compliance Manager. The Authority PCOs and/or HCVP’s accounting staff will work closely together, coordinate and follow the procedures for correcting any issues identified during the reviews. The Authority will also develop and implement a monitoring plan to ensure Local Housing Agencies (LHAs) are correctly following all the Authority established policies and procedures and adhering to Federal Regulations. The monitoring plan will outline how The Authority will conducts a risk analysis to target monitoring resources to the highest risk LHAs. Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024

View Audit 297428 Questioned Costs: $1

Finding 384290 (2023-001)

Significant Deficiency 2023

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Eligibility

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend that the Authority review their internal controls over the eligibility requirements to ensure all documentation is maintained at the time of recertification. We recommend the Authority review t...

Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend that the Authority review their internal controls over the eligibility requirements to ensure all documentation is maintained at the time of recertification. We recommend the Authority review their internal controls over the HAP process to ensure the correct amounts are paid each month. We recommend the Authority review their process for uploading data to PIC to ensure each recertification gets submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has begun the assessment, development and implementation of several internal controls to address recertification documentation, HAP processes, and PIC data submission to ensure compliance with Federal regulations. The Authority will develop and implement a quality control process on or before June 30, 2024, to ensure all documentation is maintained, signed and dated by all required parties at the time of certification. Currently, the Authority has developed a checklist system for each step of the recertification process. The checklist includes each step of the recertification process, along with due dates, and responsible entities. While not a Federal Requirement, the Authority did establish the discretionary policy to require housing specialists sign and date the Housing Information Forms. This policy was implemented after this audit finding and would not have been a requirement of the one file reviewed by the audit team. However, this step is included in the checklist process. The Authority is actively working to modify the electronic documentation and record retention system and process. Planned implementation of new electronic documentation and record retention processes is contingent on system updates managed by third party venders, however new written internal procedures are under development. The Authority will develop and implement a quality control process for the HAP process on or before June 30, 2024. This will include procedures for Program Compliance Officers (PCOs) and HCVP’s Accounting Team to work closely and coordinate to ensure each responsible person fully understands their roles and responsibilities. The Authority will implement monthly reviews of HAP payments, by the Housing Choice Voucher Program Compliance Manager. The Authority PCOs and/or accounting staff will follow the procedures for correcting any issues identified during the reviews. Over the past year, the Authority has created a System and Reporting Team that is now responsible for timely PIC submissions and addressing discrepancies and/or errors in the PIC and/or EIV system. By having a dedicated team, the Authority now exceeds the HUD requirement of submitting PIC data within 60 days of the effective date of any action. The Authority submits PIC monthly, performs monthly reviews of PIC data, and ensures staff addresses all fatal errors. In addition to these processes, the System and Reporting Team receives one on one training to address specific and challenging errors and discrepancies. Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: June 30, 2024

View Audit 297428 Questioned Costs: $1

Finding 384289 (2023-002)

None 2023

Trinity Bible College and Graduate School

ND

Student Financial Aid Reporting Internal Control / Segregation of Duties

2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporti...

2023-002 FISAP Reporting Planned Corrective Action: Trinity Bible College and Graduate School has implemented policies and procedures to address the gaps in reporting Perkins information related to the FISAP report. A new director of Financial Aid has been put in place to help ensure proper reporting. Person Responsible for Corrective Action Plan: Executive Vice President Vaughn Jordan, Director of Financial Aid Wesley Brothers, and Coordinator of Financial Aid Shannon Pool. Anticipated Date of Completion: CAP has already been implemented regarding this issue.

View Audit 297426

Finding 384251 (2023-002)

Significant Deficiency 2023

Manhattan School of Music

NY

Subrecipient Monitoring Internal Control / Segregation of Duties

During the spring 2023, the Interim SVP and CFO recognized the School’s Trial Balance needed to better distinguish between Net Assets without Donor Restrictions and Net Assets with Donor Restrictions. That enhanced viewing was accomplished during the spring 2023 and the Interim SVP and CFO believes ...

During the spring 2023, the Interim SVP and CFO recognized the School’s Trial Balance needed to better distinguish between Net Assets without Donor Restrictions and Net Assets with Donor Restrictions. That enhanced viewing was accomplished during the spring 2023 and the Interim SVP and CFO believes that effort and Management’s Response to Finding 2023-001 will improve the accounting and reporting of net assets including the endowment.

View Audit 297400

Finding 384240 (2023-001)

Significant Deficiency 2023

Santa Ana Unified School District

CA

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

1) The HR Master is the source report that will be used to report FTEs. The report is accessible through the Human Resources module as a download request, and has been modified to reflect a column for actual FTEs with a disclaimer of what positions to exclude from that report to generate the correct...

1) The HR Master is the source report that will be used to report FTEs. The report is accessible through the Human Resources module as a download request, and has been modified to reflect a column for actual FTEs with a disclaimer of what positions to exclude from that report to generate the correct count and/or sum of FTE totals. This revised HR Master reports is being shared with staff who are responsible for fulfilling FTE count requests. Having everyone informed of what source document to use for FTE reporting ensures that errors in FTE reporting are averted and minimized. 2) Requests for FTE counts should come directly to the Position Control office. The request must include specific instructions as to what FTE counts are being requested and what the purpose for the request is. Where applicable, the requesting department must provide the Position Control office with an excerpt of the report delineating the type of FTE counts request for the pertinent figures to be provided. 3) If the Position Control office staff is out, Human Resources is responsible for providing FTE counts to the requesting department by generating the HR Master report above, for the date range being requested; a copy of that report must be saved in a centralized electronic repository (Business Shared drive) with the corresponding program label and date range of the data requested. The downloaded reports serving as supporting documentation will then be accessible for providing to auditors, upon request, and the source documentation must be retained in compliance with federal/state/local program retention policies (in this instance, for subsequent 3 years. 4) As an added preventative measure, the department tasked with filing reports should always seek supporting documentation (if not already provided), and save it on the designated shared drive. This practice ensures accessibility for new staff members responsible for a particular program, allowing them to review past actions. It is essential to consistently attach supporting documentation to the filed report to preserve the audit trail and record-keeping procedures. Management understands the importance of addressing these issues promptly and effectively to ensure the integrity of our internal controls and compliance processes. Our team is fully committed to implementing the corrective actions above.

View Audit 297392

Finding 384236 (2023-001)

Significant Deficiency 2023

Town of Easton (the Easton Utilities Commission)

MD

Internal Control / Segregation of Duties Significant Deficiency Equipment & Real Property Management § 200.303

2023-001 ReConnect Program: Rural Assistance – Assistance Listing No. 10.752 Recommendation: We recommend the Commission continue with established policies and procedures implemented in March 2023 over internal controls to ensure review and approval of inventory expenditures are properly documented...

2023-001 ReConnect Program: Rural Assistance – Assistance Listing No. 10.752 Recommendation: We recommend the Commission continue with established policies and procedures implemented in March 2023 over internal controls to ensure review and approval of inventory expenditures are properly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In July 2022, EUC implemented a process in which the Supervisor of Velocity Plant Operations reviews material requisitions before the paper requisitions move to Accounting for entry into the accounting system. In March of 2023, EUC implemented the requirement for material requisitions to be initialed in order to document the review process. In May 2023, EUC moved to an electronic material requisition process which does not allow material requisitions to be available for Accounting to enter until they have been approved by a designated approver. All costs are additionally reviewed by the Senior Staff Accountant and the Chief Financial Officer before being submitted for reimbursement to the USDA. Name of the contact person responsible for corrective action: Steve J. Ochse Planned completion date for corrective action plan: Corrective action was taken March 2023.

View Audit 297379

Finding 384231 (2023-003)

Significant Deficiency 2023

St. Luke's Home and St. Luke's Home Foundation

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve funds or debt service coverage ratio for the federal program ....

Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve funds or debt service coverage ratio for the federal program .. Responsible Individual: Amy Kreidt, CEO/Administrator and Brenda Thronburg, Accountant Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the Organization's reserve fund and debt service coverage ratio is completed with formal documentation noting the review. Anticipated Completion Date: 3/31/2024

View Audit 297360

Finding 384228 (2023-001)

Material Weakness 2023

White Castle Housing Authority

LA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

WHITE CASTLE HOUSING AUTHORITY 55050 Veteran St. White Castle, LA 70788 Phone No. (225) 545-3967 Fax No. (225) 545-9951 HOUSING AUTHORITY OF WHITE CASTLE, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2023 Corrective Action Plan Finding: Finding 2023-001-Contractor Payments-Spe...

WHITE CASTLE HOUSING AUTHORITY 55050 Veteran St. White Castle, LA 70788 Phone No. (225) 545-3967 Fax No. (225) 545-9951 HOUSING AUTHORITY OF WHITE CASTLE, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2023 Corrective Action Plan Finding: Finding 2023-001-Contractor Payments-Special Tests Condition: Federal regulations require that monitoring of construction or rehabilitation type expenses be documented in writing. Monitoring notes of construction progress, lack of progress, or issues such as contractor delay must be timely made and available for third parties. There are not required forms or format. However, the more they correlate to field reports prepared by architects, the more reliable they are. In addition, contractors must present proof of insurance before they are allowed to work on Authority jobs. Corrective Action Planned I will comply with the auditor’s recommendation. Person responsible for corrective action: Don O’Bear, Executive Director Telephone: (225) 545-3967 White Castle Housing Authority Fax: (225) 545-9951 55050 Veteran St. White Castle, LA 70788 Anticipated Completion Date- September 30, 2024

View Audit 297336

Finding 384220 (2023-001)

Significant Deficiency 2023

Electric Division - Bowling Green Municipal Utilities

KY

Reporting Internal Control / Segregation of Duties

The following is the Management's Response to Auditor's Findings, Summary Schedule of Prior Audit Findings and Corrective Action Plan. This document was prepared by management of Bowling Green Municipal Utilities.Significant deficiency in lnternal Control, resulting from adjusting entries relating t...

The following is the Management's Response to Auditor's Findings, Summary Schedule of Prior Audit Findings and Corrective Action Plan. This document was prepared by management of Bowling Green Municipal Utilities.Significant deficiency in lnternal Control, resulting from adjusting entries relating to grants received which were not made prior to audit process. Finding Summary: During the 2023 audit, auditors identified adjusting entries relating to grants received by certain divisions of BGMU, which were proposed and recorded through the audit process but not prior to audit performance Explanation of Agreement/Disagreement: Management concurs with the finding and understands that adjusting entries should be made timely for proper financial statement reporting. Because the Electric division of BGMU, which is where these expenditures occurred, is regulated by FERC, grant monies are not recorded as an income item on the income statement. The adjustment in question merely moved the dollars subject to FEMA reimbursement from the Construction in Progress account to a grant receivable account, both balance sheet asset accounts. The subsequent receipt of the funds were recorded against the CIP asset, therefore there was no bottom line effect. Officials Responsible for Ensuring Corrective Action: The BGMU CFO and Controller will be responsible for corrective and future action Planned Completion for Corrective Action: September,2022 Plan to Monitor Completion of Corrective Action: BGMU management will review and record all adjusting journal entries throughout the year, including fiscal year-end journal entries, prior to the beginning of the audit engagement.

View Audit 297324

Finding 384218 (2023-001)

Material Weakness 2023

Pitt County Board of Education, North Carolina

NC

Procurement, Suspension & Debarment Equipment & Real Property Management Internal Control / Segregation of Duties § 200.16 § 200.216 § 200.322

Name of contact person: Michael Hardy, Chief Finance Officer. Corrective action: The Board is reviewing their procedures and policies to include a detailed review of all construction contracts that are funded by federal awards is completed by a designated member of senior management to ensure the co...

Name of contact person: Michael Hardy, Chief Finance Officer. Corrective action: The Board is reviewing their procedures and policies to include a detailed review of all construction contracts that are funded by federal awards is completed by a designated member of senior management to ensure the contracts contain the provisions required by 2 CFR Appendix II, 2 CFR 200.216, and 2 CFR 200.322. Proposed completion date: The Board will implement the above procedures immediately.

View Audit 297323

Finding 384217 (2023-004)

Significant Deficiency 2023

Hill Top Home of Comfort, Inc.

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding 2023-004 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund or financial covenant calculations...

Finding 2023-004 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund or financial covenant calculations. Responsible Individuals: Gerry Leadbetter, Administrator Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the program’s reserve fund and financial covenant calculations is completed with formal documentation noting the review. The Business Office Manager will reconcile the bank statement and sign off on the bank statement, along with the Administrator for the USDA Loan Reserve Bank Account and on the financial covenant calculation worksheets. Anticipated Completion Date: 03/31/2024

View Audit 297302

Finding 384209 (2023-002)

Significant Deficiency 2023

Illinois Wesleyan University

IL

Student Financial Aid Special Tests & Provisions Significant Deficiency

2023-002 Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program),...

2023-002 Student Financial Assistance Cluster – Assistance Listing No. 84.007 (Federal Supplemental Educational Opportunity Grants Program), 84.033 (Federal Work Study Program), 84.038 (Federal Perkins Loan Program), 84.063 (Federal Pell Grant Program), 84.268 (Federal Direct Student Loans Program), 93.364 (Nursing Student Loans) Recommendation: We recommend that the University designate an individual to oversee the information security function and work to update the University’s written security program to ensure compliance with all the standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Illinois Wesleyan University will designate an individual to be the Information Security Officer. The information security policy will be updated as applicable for GLBA standards. Name(s) of the contact person(s) responsible for corrective action: David Myron Planned completion date for corrective action plan: Updates for the information security policy will be made on an as-needed basis for applicable changes. The Information Security Officer will be named in Spring 2024. If the Department of Education has questions regarding this plan, please call Scott Seibring at (309) 556-3096.

View Audit 297294

Finding 384162 (2023-001)

Significant Deficiency 2023

Capitol Technology University

MD

Reporting Internal Control / Segregation of Duties

Finding 2023-001 Significant Deficiency over Financial Reporting Management agrees with the finding. Corrective action plan follows. The College acknowledges that it did not complete a full close and review of the trial balance accounts by the start of the audit and that multiple trial balances we...

Finding 2023-001 Significant Deficiency over Financial Reporting Management agrees with the finding. Corrective action plan follows. The College acknowledges that it did not complete a full close and review of the trial balance accounts by the start of the audit and that multiple trial balances were generated. It acknowledges that net assets were not properly rolled at year end and the balance did not reconcile to the trial balance, and that trial balance adjustments were booked after the close process was completed. Management has reviewed its yearend close procedures and has implemented the following guidelines to ensure an accurate and timely close: The College can better prepare for yearend close by reinforcing its month end close procedures. Month end close procedures and reconciliations were inconsistent throughout the year. The College has established a checklist of monthly processes, recurring journal entries, and the support needed to complete the reconciliation process. Reconciling accounts on a monthly basis allows for the identification and correction of errors in a timely manner. Monthly reconciliations are kept on a shared network and can be accessed by all Business Office team members. The VP of Finance will review monthly bank reconciliations to ensure accuracy and timeliness. Net Assets have been reviewed and agreed to the prior year audit report. The College has a detailed yearend checklist which includes a list of yearend journal entries, and a detailed list of the schedules provided to auditors. The College will prepare a close schedule identifying important dates, activities and responsibilities to ensure items are completed in a timely manner and that all necessary deadlines are met. Yearend schedules are on a shared network drive so that progress and accuracy can be monitored. The VP of Finance will hold regular meetings with the Business Office team to monitor yearend close progress. Once the yearend close has been established, all reports will be reviewed and compared to previous year’s figures to identify any unexpected changes, and agreed to the final trial balance prior to uploading to the audit portal. No adjustments will be allowed once the trial balance has been finalized without consultation with the auditors. The Business Office team will continue to reevaluate any processes or systems used during the previous yearend closes and update them as needed, such as setting up new accounts, reviewing current statements for accuracy, or revising account coding. Contact Person: Kathleen Werner, Interim VP Finance Completion Date: June 30, 2024

View Audit 297272

Finding 384139 (2023-006)

Significant Deficiency 2023

Concordia University, St. Paul

MN

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

deral Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to p...

deral Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the University implement a procedure with the third party servicer to ensure that their Title IV compliance report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will communicate with our third party servier to understand when they believe their SSAE 18 report will be issued. If it will be late, we will coordinate with them to perform the necessary testing to ensure we can perform the due diligence. Name of the contact person responsible for corrective action: Financial Aid Director Amanda McCaughan Planned completion date for corrective action plan: June 30, 2024

View Audit 297264

Finding 384133 (2023-005)

Significant Deficiency 2023

Concordia University, St. Paul

MN

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

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have taken all of the findings and placed it on our risk register. Each Wednesday, we have a vulnerability call with our VCISCO. Over the last year, we have reduced the number of vulnerabilities in our systems. Over the last month, we have begun to work on the items on our risk register. We have a working session set for April 8, 2024 to update all findings that relate to the policies that were not to standard. For the other items, we will work on our weekly calls to set up the necessary SOPs to address the deficiencies. Name of the contact person responsible for corrective action: Director of Computer Services of Network Jonathan Breitbarth Planned completion date for corrective action plan: June 30, 2024

View Audit 297264

Finding 384127 (2023-004)

Significant Deficiency 2023

Concordia University, St. Paul

MN

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate the students’ status each semester. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financi...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate the students’ status each semester. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial Aid Counselors receive a list of students with enrollment adjustments and review for required adjustments to cost of attendance and aid, including but not limited to reviewing for any required allocations for Subsidized to Unsubsidized loans. Additionally, a report is being created to run with the Census to identify reallocation adjustments due to enrollment. Name of the contact person responsible for corrective action: Financial Aid Director Amanda McCaughan Planned completion date for corrective action plan: Now in place and ongoing process.

View Audit 297264 Questioned Costs: $1

Finding 384124 (2023-003)

Significant Deficiency 2023

Concordia University, St. Paul

MN

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their controls around eligibility. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The ...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review their controls around eligibility. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid receives a weekly report indicating the amount and type of notifications sent in the prior week to compare to the list of actual transactions in the system. This allows for a more frequent review and notification of any errors. On the IT side of the process, the notification process has been added to their checklist to check for any new server updates. Name of the contact person responsible for corrective action: Financial Aid Director, Amanda McCaughan Planned completion date for corrective action plan: Already in place and ongoing process.

View Audit 297264

Finding 384118 (2023-002)

Significant Deficiency 2023

Concordia University, St. Paul

MN

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: T...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Concordia University is reporting to the National Student Clearinghouse every 30 days regarding enrollment reporting and reporting to Degree Verify within 30 days from the end of a part of the term. If a student is awarded or has a petition for a late withdrawal that will be outside of the 30 days, the Registrar’s Office will manually go into the National Student Clearinghouse and update the student records to accurately reflect enrollment. The Registrar's Office has built automated reports to assist in tracking the students who fall outside of normal reporting. In addition, the Registrar’s Office has implemented a new process to catch students who have incorrect anticipated graduation dates in the system, so students are pulling more accurately on the awarding list. The Registrar’s Office, after initial reporting will be reviewing all students who are between 95%-100% program completion via Degree Works. The Registrar’s Office is researching how to clean up data within Banner to assist with accurate graduation dates. The Registrar’s Office is in constant communication with the National Student Clearinghouse regarding reporting deadlines, and the National Student Clearinghouse has provided when the data was submitted to NSLDS which is within the regulated timeframe. Name of the contact person responsible for corrective action: Registrar Lynn Lundquist Planned completion date for corrective action plan: Now in place and ongoing process

View Audit 297264

Finding 384112 (2023-001)

Material Weakness 2023

Concordia University, St. Paul

MN

Questioned Costs Student Financial Aid Material Weakness

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in respo...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4 calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As part of the 2022 Corrective Action Plan submitted in March 2023, a report was built to pull all withdrawals for the semester and broken down by module enrollment. This is reviewed and processed weekly after the initial aid disbursement for the semester. Financial Aid Counselors also review an Enrollment Change report daily and notify the Assistant Director and Director of Financial Aid of possible R2T4 calculations. Additionally, the Financial Aid Office is copied on all General Petition and University Withdrawal notifications to review for possible R2T4 requirements. The Loan Specialist, Assistant Director, and Director of Financial Aid have all passed the NASFAA U R2T4 course and hold the R2T4 Credential. The Director of Financial Aid also received the R2T4 Specialist designation from NASFAA. The 14 students found to be processed past the 45 days and the 5 students to have additional funds sent back, all R2T4s were processed prior to the 2022 Audit and Corrective Action Plan was put into place. Name of the contact person responsible for corrective action: Financial Aid Director Amanda McCaughan Planned completion date for corrective action plan: Now in place and ongoing process

View Audit 297264 Questioned Costs: $1

Finding 384110 (2023-003)

Significant Deficiency 2023

Municipality of Catano

PR

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2023 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accorda...

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2023 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 Fiscal Year: 2022-2023 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Interim Finance Director Phone: (787) 788-0404 Original Finding Number: 2023-003 Statement of Concurrence or Nonconcurrence : We concur with the finding. Corrective Action: In the month of January 2024, the Municipality of Cataño submitted a Letter to the ACUDEN Agency requesting additional time to be able to submit a closure report. This request is due to the fact that said agency has not disbursed the approved funds to the Program, to be able to carry out the breakdown of expenses and corresponding payments. To date we have not received a response to this request. The Municipality of Cataño (Federal Programs Office) undertakes to follow up with the relevant agency in future occasions to receive a response when an extension is requested for a compliance report. Implementation Date: Fiscal year 2023-2024 Responsible Person: Mrs. Yolanda Maldonado Oliver, Federal Programs Director

View Audit 297263

Corrective Action Plans

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