Corrective Action Plans

Finding 371149 (2023-002)

Significant Deficiency 2023

PA

Reporting Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has evaluated its policies and procedures around reporting student status changes and will make the following changes to ensure proper data capture and timely reporting: Following the conclusion of a graduation cycle, the NSC Degree Verify extract will be verified via a cross-check with the BANNER ERP system information on degrees awarded to assure no one is missing or mis-reported. Further, the BANNER de-activation process (SHRDEGS) will be run for the proper semester parameters, so that the student record will reflect proper periods of activity and graduation for those who graduated. BANNER’s registration processor has been configured to update time status dynamically. No longer will there be any discrepancy between the status date in BANNER and the date reported to the NSC and subsequently to NSLDS. The NSC extract of enrollment data will be matched to a separate report of registered students for the given semester to assure that no one is being missed. Name(s) of the contact person(s) responsible for corrective action: Gerard J Donahue Planned completion date for corrective action plan: Completed and effective as of February 28, 2024

View Audit 292767

Finding 371148 (2023-003)

Significant Deficiency 2023

La Salle University

PA

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

Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action ...

Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate its procedures and policies around recordkeeping and record retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will generate a master list of all prior students with Perkins Loans. That master list will track location of files/documentation and provide the tracking to have all files secured all in one properly secured location. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt Planned completion date for corrective action plan: In progress as of February 28, 2024. A complete master list of students who received Perkins loans will be cross checked against the student’s actual file contained in fire proof cabinets, verifying each student’s master promissory note is on site. This process will be completed no later than August 1, 2024. If the United State Department of Education has questions regarding this plan, please contact Michele McDevitt at mmartin@lasalle.edu or 215.951.1651

View Audit 292767

Finding 371143 (2023-001)

Significant Deficiency 2023

La Salle University

PA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are retur...

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the University evaluate its procedures and review policies in overseeing student credit balances to ensure that any credit balances as a result of Title IV aid are returned within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will evaluate the current refund process and make revisions to process to ensure any credit balances of Title IV aid are returned within the required timeframe. The university’s goals is to automate the refund process to reduce the chance of human error, and placing the refund process on a schedule to ensure refunds are processed within the appropriate window of time. Name(s) of the contact person(s) responsible for corrective action: Michele McDevitt Planned completion date for corrective action plan: September 9, 2024 – first rounds of Fall 2024 refunds

View Audit 292767

Finding 371142 (2023-001)

Significant Deficiency 2023

Our Lady of the Lake University of San Antonio

TX

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Our Lady of the Lake University of San Antonio FY 2023 Single Financial Audit Finding Response Corrective Action Plan – Reconciliation of COD Monthly School Account Statement Compliance Finding: The Department of Education’s (DoE) School Account Statement (SAS), downloaded electronically from the C...

Our Lady of the Lake University of San Antonio FY 2023 Single Financial Audit Finding Response Corrective Action Plan – Reconciliation of COD Monthly School Account Statement Compliance Finding: The Department of Education’s (DoE) School Account Statement (SAS), downloaded electronically from the Common Origination Destination (COD) website, was not being reconciling monthly as required by the Student Financial Aid/ Direct Loan Program. Criteria or Specific Requirement: Per the Student Financial Aid/ Direct Loan Program requirements with the DoE, every school is required to reconcile their SAS to their accounting system records at least monthly. This statement is issued to each participating school through the SAIG mailbox monthly. The auditors noted 34 CFR 685.102(b), 385.300(b), 685.301, and 303 as the compliance regulation. Cause of Noncompliance: It appears that the SAS was reconciled monthly per the compliance requirement in recent years, but with high turnover and periods of under-staffing in the Accounting department this procedure was changed to one that did not meet the above requirement. Although OLLU did regularly reconcile the accounting system records with reports from COD, it was not the official monthly SAS statement. OLLU’s modified procedures did not completely meet the compliance requirement but did offer some mitigating procedures. Institution Response: OLLU has already begun coordinating processes between its Accounting and Financial Aid departments to download the monthly SAS into the university’s system electronically, where Accounting will then reconcile the statement monthly as a part of its month-end close procedures. The Financial Aid Director will be responsible for ensuring that the statement is downloaded monthly as a part of the regular electronic data file transfer between OLLU and the Department of Education. The Senior Accountant in the Accounting department will generate the report in Colleague via the DRSS process and reconcile the SAS statement to cash records. The Director of Accounting and Reporting will review the reconciliation monthly.

View Audit 292763

Finding 371140 (2023-002)

Significant Deficiency 2023

Bradley University

IN

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

2023-002 Student Financial Assistance Cluster- Assistance Listing Number: 84.063, 84.268 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 w...

2023-002 Student Financial Assistance Cluster- Assistance Listing Number: 84.063, 84.268 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 finding. Action taken in response to finding: The Office of the Registrar will continue to submit enrollment data to the National Student Clearinghouse via the current schedule. The Office of the Registrar will investigate and resolve any errors returned by the National Student Clearinghouse. After the enrollment data is transferred from the NSC to NSLDS a University representative will review the data in NSLDS for any discrepancies including cross-checking graduation files and complete withdrawals. Any inconsistencies will be discussed and timely resolved by the applicable units and officially updated in NSLDS and NSC respectively. The University will keep track of any changes manually made within the NSLDS or NSC database by university representatives, so that the student information system, NSC, and NSLDS records are in-sync. Name of the contact person responsible for corrective action: Dennis Koch, Associate Vice President of Financial Services Planned completion date for corrective action plan: 3/15/2024 If the Department of Education has questions regarding this plan, please call Dennis Koch at 309-667-3119.

View Audit 292762

Finding 371135 (2023-001)

Significant Deficiency 2023

Bradley University

IN

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

2023-001 Student Financial Assistance Cluster- Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 93.364 Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Educatio...

2023-001 Student Financial Assistance Cluster- Assistance Listing Number: 84.007, 84.038, 84.063, 84.268, 84.379, 93.364 Recommendation: We recommend that the University review its procedures related to outstanding student refund 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 finding. Action taken in response to finding: The Financial Services Division of the University (FSD) has implemented a new process to better track the status of student refund checks. After the first week of the month, all outstanding checks from the prior month are investigated in order to identify student refund checks that were the result of Title IV funds (e.g. January outstanding checks are reviewed after the first week of February). A representative from FSD will contact the borrower within 45 days of the original issuance date via email to inform them that the check remains outstanding and provide them with the option to EFT the funds directly to the student or void the check and reduce the borrowing with the Department of Education. The original check will remain valid for the 90 days stated on the face of the check. After 90 days, no additional communication will be made to the borrower. The check will be voided and borrowing will be updated with the Department of Education after 90 days of the original issuance, but prior to the 240 days allowed by the Department of Education. In additional to establishing a process to handle any future refund checks, the University.is also in contact with the Department of Education to provide process clarity on how to return funds related to refund checks for years where the financial aid year has been closed. Name of the contact person responsible for corrective action: Mark Young, Assistant Controller Planned completion date for corrective action plan: 2/29/2024

View Audit 292762

Finding 371107 (2023-002)

Significant Deficiency 2023

Lincoln Christian University

IL

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

Student Financial Aid – Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program Recommendation: We recommend a secondary review be done by someone other than the SFA Director to ensure disbursements and verifications are completed accurately and timely. Explanation of disagre...

Student Financial Aid – Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program Recommendation: We recommend a secondary review be done by someone other than the SFA Director to ensure disbursements and verifications are completed accurately and timely. 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 will notify the Vice President of Operations of disbursements and verifications, and the Vice President will complete a secondary review. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name(s) of the contact person(s) responsible for corrective action: Nancy Siddens, Director of Financial Aid. Planned completion date for corrective action plan: November 1, 2023.

View Audit 292743

Finding 371103 (2023-001)

Significant Deficiency 2023

Lincoln Christian University

IL

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

Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as suppo...

Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as support for the review and approval process. 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 will document each change to an award by printing a new award offer and saving to document tracking. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name(s) of the contact person(s) responsible for corrective action: Nancy Siddens, Director of Financial Aid. Planned completion date for corrective action plan: November 1, 2023.

View Audit 292743

Finding 371100 (2023-001)

Material Weakness 2023

Umatilla Morrow Head Start, Inc.

OR

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302

Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding o...

Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing Reconciliations and Material Adjustments Corrective Action Plan Umatilla Morrow Head Start, Inc. (UMHS, Inc.) partnered with an independent accounting firm to streamline processes and develop templates for year-end closure. The agency used this opportunity to increase knowledge and understanding of needs associated with this task. As the fiscal department moves forward, systems and tools have been implemented to ensure timely closing and accurate tracking of this process. UMHS will continue to utilize the checklists put in place last fiscal year to guide month-end processes and reconciliations. Fiscal Management will review, monthly, the completion of said duties and will address any issues with staff immediately. Ongoing training will be done to ensure all fiscal staff members understand their role and duties within the agency. Bank reconciliations will continue to be completed monthly. The Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee will review the information and approval will be documented. UMHS will focus on segregation of duties within the fiscal department and ensure proper documentation is maintained. Person(s) Responsible: Executive Director, Director of Finance, Treasurer of the Board of Directors, or Other Designee Timing for Implementation: Immediately and Ongoing

View Audit 292742

Finding 371066 (2023-001)

Significant Deficiency 2023

Furman University

SC

Significant Deficiency Internal Control / Segregation of Duties

Department of Education 2023-001 Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their Written Information Security Program (WISP) includes all required elements. We do note that after June 30, 2023 the University has upd...

Department of Education 2023-001 Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their Written Information Security Program (WISP) includes all required elements. We do note that after June 30, 2023 the University has updated the WISP to include all of the required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Updated WISP to include all required elements. Name(s) of the contact person(s) responsible for corrective action: Dawn Durham Planned completion date for corrective action plan: 10/19/2023

View Audit 292738

Finding 371047 (2023-001)

Material Weakness 2023

Keokuk County, Iowa

IA

Internal Control / Segregation of Duties

Segregation of Duties Name of contact person - Christy Bates, County Auditor Corrective Action - The duties will be separated as much as possible and alternative contro...

Segregation of Duties Name of contact person - Christy Bates, County Auditor Corrective Action - The duties will be separated as much as possible and alternative controls will be considered to compensate for lack of separation. Proposed Completion Date - Ongoing.

View Audit 292713

Finding 371043 (2023-001)

Significant Deficiency 2023

Davis County, Iowa

IA

Internal Control / Segregation of Duties

Segregation of Duties Name of contact person - Linda Humphrey, County Auditor Corrective Action - The duties will be separated as much as possible and alternative controls will be co...

Segregation of Duties Name of contact person - Linda Humphrey, County Auditor Corrective Action - The duties will be separated as much as possible and alternative controls will be considered to compensate for lack of separation. Proposed Completion Date - Ongoing.

View Audit 292702

Finding 371041 (2023-001)

Significant Deficiency 2023

Island Park Union Free School District

NY

Cash Management Reporting Internal Control / Segregation of Duties

Island Park UFSD Corrective Action Plan in Response to Single Audit Report For The Fiscal Year Ended June 30, 2023 CURRENT YEAR FINDINGS AND RECOMMENDATIONS Federal Award Findings And Questioned Costs Finding # 2023-001 U.S. Department of Education-Passed-throug...

Island Park UFSD Corrective Action Plan in Response to Single Audit Report For The Fiscal Year Ended June 30, 2023 CURRENT YEAR FINDINGS AND RECOMMENDATIONS Federal Award Findings And Questioned Costs Finding # 2023-001 U.S. Department of Education-Passed-through the NYS Education Department Finding: During our audit, we noted that certain figures used as inputs to the annual performance report could not be reconciled to supporting documentation and therefore, we were unable to substantiate certain amounts reported to NYSED. The review of the annual performance report was not performed at an appropriate level of precision such that the incorrect and/or incomplete information presented would be identified and corrected prior to submission to NYSED. Recommendation: We recommend that the District reevaluate the system of internal control for the review and approval of the annual performance report prior to submission to NYSED, including the reconciliation of amounts included within the support to appropriate supporting documentation. District Response: The District will ensure that, prior to submission to NYSED, the annual performance report will be reviewed by an individual other than the preparer and reconciled to the supporting documentation in order to confirm the completeness and accuracy of information reported. Mr. Salvatore Carambia, Business Administrator, is the person responsible for the planned corrective action. The completion date for this action is February 16th, 2024.

View Audit 292701

Finding 371027 (2023-002)

Significant Deficiency 2023

Betty Jean Kerr - People's Health Centers

MO

Subrecipient Monitoring Eligibility HUD Housing Programs

Item 2023-002 - Special Tests Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Repeat Finding Yes Action Taken 1. To train all staff involved with the calculation of sliding f...

Item 2023-002 - Special Tests Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Repeat Finding Yes Action Taken 1. To train all staff involved with the calculation of sliding fees on the policies and procedures to ensure: ► The sliding fee guidelines document is known. ► Understanding of the methodology for calculating fees, including how family size and income are considered. ► Documentation required to support income and family size information provided by clients. This may include tax returns, pay stubs, or other relevant documents. ► To use the standardized form (checklist) to ensure all necessary information is collected and verified. 2. To perform a monthly audit review, utilizing a selected sample to identify any discrepancies and make necessary corrections in a timely manner. 3. To ensure the sliding fee scale is clearly communicated to clients. Responsible Party: Director of Patient Services/RCM Director Target Completion Date: 04/30/2024 If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Hewart Tillett, CFO at 1-314-882-1463, or email at htillett@phcenters.com.

View Audit 292688

Finding 370982 (2023-002)

Material Weakness 2023

Mill Creek Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing...

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by the Assistant Superintendent without an oversight or review process in place to prevent, or detect and correct, errors. Furthermore, the reported data on two of the reports could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the reports could not be verified. Contact Person Responsible for Corrective Action: Jim Diagostino, Superintendent, and Lori Bennett, Treasurer Contact Phone Number: 317-539-9200 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Superintendent, or designee, will prepare the annual data reports to be reported to the IDOE by using records that accumulate or summarize the data. Prior to the submission of the reports, the Treasurer will review the records and annual data report. The Treasurer will initial and date a hard copy of the report to ensure accuracy and completeness. Anticipated Completion Date: March 31, 2024

View Audit 292601

Finding 370969 (2023-003)

Material Weakness 2023

Dodgeville School District

WI

Internal Control / Segregation of Duties

Finding#2023-003 - Cash Reconciliations (Prior Year Finding #2022-004) Condition: The main checking account of the District was not reconciled to the general ledger throughout 2022-2023. Effect: Not reconciling cash accounts on a timely basis could lead to errors or other problems not being recogniz...

Finding#2023-003 - Cash Reconciliations (Prior Year Finding #2022-004) Condition: The main checking account of the District was not reconciled to the general ledger throughout 2022-2023. Effect: Not reconciling cash accounts on a timely basis could lead to errors or other problems not being recognized and resolved in a timely manner. General ledger cash balances should be reconciled to monthly bank statements shortly after bank statements are received. Cause: The District's main checking account was not reconciled to the general ledger at the time of the onsite audit. After all audit entries were recorded, no significant cash difference exists. Criteria: Internal controls should be kept in place to make sure that cash is reconciled timely and that reconciliations are tied to the general ledger on a monthly basis. Recommendation: We recommend the District develop procedures to reconcile all cash accounts to the general ledger in a timely manner. The reconciliations should be reviewed by someone other than the person preparing the reconciliation. The reviewer should initial and date the reconciliations when the review is complete. Response: The District will begin reconciling cash to the general ledger on a timely basis during the 2023-2024 fiscal year.

View Audit 292599

Finding 370968 (2023-002)

Material Weakness 2023

Dodgeville School District

WI

Material Weakness Reporting Internal Control / Segregation of Duties

Finding #2023-002 - Material Adjustments (Prior Year Finding #2022-002)Condition: Johnson Block and Company, Inc. proposed numerous adjusting journal entries to adjust District account balances. We deem these entries to be significant in relation to the financial statements. Since the District did n...

Finding #2023-002 - Material Adjustments (Prior Year Finding #2022-002)Condition: Johnson Block and Company, Inc. proposed numerous adjusting journal entries to adjust District account balances. We deem these entries to be significant in relation to the financial statements. Since the District did not make these adjustments in the accounting system prior to the audit, a material weakness exists in the District's internal controls. Effect: This means that the proper recording and reporting of financial information may not occur within a timely manner. Cause: Financial information was not recorded in a timely manner and material adjustments were needed in order to correct various transactions. Criteria: Material adjusting journal entries not prepared by the District before the audit are considered an internal control weakness. Recommendation: Policies and procedures should be implemented to ensure account balances are properly recorded in a timely manner. Response: The District will work to establish policies and procedures to reduce the number of adjusting journal entries proposed by the auditor.

View Audit 292599

Finding 370967 (2023-001)

Material Weakness 2023

Dodgeville School District

WI

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

Finding #2023-001 -Segregation of Duties <Prior Year Finding #2022-001) Condition: Management is responsible for the design, installation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. The limited size of the ...

Finding #2023-001 -Segregation of Duties <Prior Year Finding #2022-001) Condition: Management is responsible for the design, installation and maintenance of an appropriate system of internal control. Proper segregation of duties is an important aspect of any control system. The limited size of the District's office staff prevents the ideal segregation of functions. The Business Manager is the only employee that records transactions in the general ledger, records cash receipt adjustments in the general ledger, prints accounts payable checks using electronic signatures, performs bank reconciliations, and has access to process payroll. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: We recommend that the Board of Education and the District Administrator continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportunities to improve the design of the internal control structure. Response: We agree with this finding but do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The District Administrator approves purchase orders and the Board of Education approves monthly accounts payable checks. Also, the Building Principals review payroll timesheets prior to processing payroll. The Board of Education, District Administrator, and Building Principals will continue to monitor transactions of the District.

View Audit 292599

Finding 370958 (2023-004)

Significant Deficiency 2023

Bethel University and Affiliates

MN

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

2023-004 Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no d...

2023-004 Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With one year until the program is fully sunset, we will continue to manage and safeguard the promissory notes that we have in our possession. We do not disagree that some MPNs were not able to be found, but with only 90 accounts remaining, we are confident that we have the grand majority of MPN’s needed to close the program in the near future. Name(s) of the contact person(s) responsible for corrective action: Michael Johnson, Controller Planned completion date for corrective action plan: March 1, 2024

View Audit 292587

Finding 370949 (2023-003)

Significant Deficiency 2023

Bethel University and Affiliates

MN

Questioned Costs Student Financial Aid Significant Deficiency

2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagree...

2023-003 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review its procedures related to outstanding student refund 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: We are working with IT to allow for the auditing of uncashed checks to be an action that can be fulfilled with minimal human resource used. We have resumed the monthly audit of student uncashed Title IV resources. Name of the contact person responsible for corrective action: Michael Johnson, Controller Planned completion date for corrective action plan: February 29, 2024

View Audit 292587 Questioned Costs: $1

Finding 370948 (2023-002)

Significant Deficiency 2023

Bethel University and Affiliates

MN

Student Financial Aid Reporting Significant Deficiency

2023-002 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 ...

2023-002 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. Action taken in response to finding: 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, Data Coordinator o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Kurt Jarvi, Systems Analyst Based on the previous audit, adjustments were made to the timing of the Clearinghouse enrollment submissions. This has been accomplished with enrollment being reported every month on the same date to enable automated submissions. As we tried to systematize graduation reporting, we encountered multiple technical issues. These issues involved both Information Technology and the Clearinghouse, which resulted in a delay in the reporting of graduates from May through August 2023. Additional training has been provided by the Clearinghouse and other sources which have been viewed by those involved in Clearinghouse reporting. We have also sought the advice from other institutions who report to the Clearinghouse. Our corrective action will involve several parts. • First, we will add more graduation only submissions to our Clearinghouse schedule to ensure they are getting reported in a timely manner. • Second, we will investigate where our Clearinghouse reports are pulling the graduation date form our Student Information System (Banner) to ensure those fields are accurate. • Third, we will review our process for determining degree conferral dates to ensure it aligns with our reporting schedule. • Fourth, over this past summer (2023) we worked with staff to clarify student withdrawal procedures. We will continue to do that. • Fifth, we will continue to take advantage of Clearinghouse training and other related training opportunities. • Sixth, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner. Name of the contact person responsible for corrective action: Cheryl Fisk, Registrar Planned completion date for corrective action plan: June 1, 2024

View Audit 292587

Finding 370849 (2023-002)

Significant Deficiency 2023

Miller Creek School District

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

We have reviewed the draft of our audit report and want to provide a formal answer to the audit finding #2023-002 related to Federal Compliance: Allowable costs/cos Principles - Time and Effort Reporting. In 2023-24 we are reinstating a process we had in place by which every employee partially paid ...

We have reviewed the draft of our audit report and want to provide a formal answer to the audit finding #2023-002 related to Federal Compliance: Allowable costs/cos Principles - Time and Effort Reporting. In 2023-24 we are reinstating a process we had in place by which every employee partially paid by a Federal Source was assigned a duty statement. The statement will describe: • Program Service • Program Code (Funding Source) • Description of Monthly or Yearly Activities • Hours Funded Each month the employee will fill out a timesheet logging their time based on the activities described in the duty statement. Time certifications will be reviewed monthly by the CBO and kept in a binder. If you have any questions about this response, please contact me directly.

View Audit 292507

Finding 370807 (2023-003)

Significant Deficiency 2023

The King's University

TX

Questioned Costs Eligibility Significant Deficiency

Incorrect Pell Calculations Planned Corrective Action: The University will provide oversight and review of Pell calculations on a weekly basis. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Services Anticipated Date of Completion: Effective Immediately, February...

Incorrect Pell Calculations Planned Corrective Action: The University will provide oversight and review of Pell calculations on a weekly basis. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Services Anticipated Date of Completion: Effective Immediately, February 15, 2024

View Audit 292492 Questioned Costs: $1

Finding 370805 (2023-002)

Significant Deficiency 2023

The King's University

TX

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Inaccurate Return of Title IV Funds Calculations Planned Corrective Action: The University will work with FA Solutions weekly to ensure funds are calculated correctly and timely returns of IV Funds are processed. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Ser...

Inaccurate Return of Title IV Funds Calculations Planned Corrective Action: The University will work with FA Solutions weekly to ensure funds are calculated correctly and timely returns of IV Funds are processed. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Services Anticipated Date of Completion: Effective Immediately, February 15, 2024

View Audit 292492

Finding 370801 (2023-002)

Significant Deficiency 2023

Northeastern Oklahoma Agricultural An Mechanical College

OK

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

Recommendation: CLA recommends someone other than the preparer of Return of Title IV calculations review said calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: All Return of Title IV calculation...

Recommendation: CLA recommends someone other than the preparer of Return of Title IV calculations review said calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: All Return of Title IV calculations will be reviewed by another person in the Financial Aid Department, other than the preparer, for accuracy, completeness, and timeliness. Name(s) of the contact person(s) responsible for corrective action: David Fisher, dlfisher@neo.edu Planned completion date for corrective action plan: November 2023

View Audit 292488

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