Corrective Action Plans

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FINDING 2023-005 Finding Subject: Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Finding: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness. The School Corporation had not properly de...
FINDING 2023-005 Finding Subject: Education Stabilization Fund - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: Finding: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness. The School Corporation had not properly designed and implemented internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles. There was not an oversight or review to ensure that the vendor claims were properly approved. The vendor claims were reviewed and approved by the department head and the Treasurer. However, during our review of the 40 vendor claims, there were 17 Accounts Payable Vouchers that were not approved by the department head and the Treasurer. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place regarding vendor claims. Contact Person Responsible for Corrective Action: Dr. Tim Garland Contact Phone Number and Email Address: 574-626-2525 / garlandt@lewiscass.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: During the audit period, internal control opportunities were in place but not followed. To address and ensure vendor claims are properly approved by the department head and treasurer Lewis Cass Schools has an internal control process that is in place but was not followed by the treasurer who in the position during the audit period. The treasurer who did not follow the internal control process is no longer employed by Lewis Cass Schools. To ensure the internal control process is currently being followed, several vendor claims were pulled and reviewed. This review found there to be no vendor claims that were not verified by the department head and treasurer. Anticipated Completion Date: July 1, 2023V
FINDING 2023‐003 Finding Subject: Child Nutrition Cluster ‐ Internal Controls Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles, Activities ...
FINDING 2023‐003 Finding Subject: Child Nutrition Cluster ‐ Internal Controls Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles, Activities Allowed and Unallowed. Recommendation: We recommended that management of the School Corporation design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place regarding vendor claims. Contact Person Responsible for Corrective Action: Tim Garland, Superintendent Contact Phone Number: 574‐626‐2525 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Lewis Cass Schools makes every effort to ensure proper documentation is obtained before processing vendor claims. To prevent oversight and strengthen internal controls, each level of management oversight has implemented stringent safeguards. All food service vendor claims will not be processed for payment without the authorization of the Food Service Director. Upon confirmation of the Food Service Director’s documented authorization, the Deputy Treasurer will document the authorization, and prepare the claim for the Treasurer. The Treasurer will ensure documented authorization of the Food Service Director and the Deputy Treasurer, along with the proper budget account code applied before releasing authorization for payment. The application of the procedures above will apply to all vendor claims for payment. Therefore, vendors meeting the thresholds for suspension and debarment will also be included. Anticipated Completion Date: Q2 2024 (6/30/2024)
Finding 387414 (2023-003)
Significant Deficiency 2023
Finding Summary: Change, Inc. has an internal control process designed to review and sign the eligibility forms, but the controls did not operate as designed. Personnel at Change Inc. Were unable to produce documentation supporting the review of participant files for participant eligibility. Respo...
Finding Summary: Change, Inc. has an internal control process designed to review and sign the eligibility forms, but the controls did not operate as designed. Personnel at Change Inc. Were unable to produce documentation supporting the review of participant files for participant eligibility. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: We are working to formalize this process by creating a written participant file review policy and procedure. Anticipated Completion Date: March 31, 2024
Finding 387391 (2023-001)
Significant Deficiency 2023
Finding Summary: The organization has a lack of segregation of duties in the cash receipts process. One individual deposits the cash, enters the receipts in the accounting system, and prepares the bank reconciliation. Change Inc. Is missing a step in the internal controls as designed. Responsible...
Finding Summary: The organization has a lack of segregation of duties in the cash receipts process. One individual deposits the cash, enters the receipts in the accounting system, and prepares the bank reconciliation. Change Inc. Is missing a step in the internal controls as designed. Responsible Individuals: Jill Johnson, Associate Director Corrective Action Plan: We will be updating our cash receipts process as part of an overall review of our accounting and financial policies and procedures that will include improvements in our internal control system. Anticipated Completion Date: Updated accounting and finance policies and procedures will be completed and implemented by the end of FY24.
Description of Corrective Action Plan: The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying detail. The Director of Grants will make sure this is done in a time...
Description of Corrective Action Plan: The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying detail. The Director of Grants will make sure this is done in a timely manner to comply with the reporting deadlines for each fiscal year. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Superintendent, Dr. Angela Piazza and the Director of Grants, Eric Knebel. The corrective action will be implemented starting immediately.
Description of Corrective Action Plan: The Superintendent, Corporation Treasurer, Director of Grants and the Director of Facilities and / or Director of Technology will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities and / or Director of Technolo...
Description of Corrective Action Plan: The Superintendent, Corporation Treasurer, Director of Grants and the Director of Facilities and / or Director of Technology will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities and / or Director of Technology will tag the equipment and notify the Director of Grants, Treasurer and Superintendent when the fixed asset inventory is completed and updated. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Director of Grants, Eric Knebel, Director of Technology Brandon Shafter, Director of Facilities Zac Moore, Superintendent, Dr. Angela Piazza. The corrective action will be implemented starting immediately.
Description of Corrective Action Plan: The Director of Grants prepares the Annual Data Report as well as tracks the expenditures pertaining to the Education Stabilization Funds (ESF). The Director of Grants will ensure that disbursements and receipts are recorded to the appropriate funds in order to...
Description of Corrective Action Plan: The Director of Grants prepares the Annual Data Report as well as tracks the expenditures pertaining to the Education Stabilization Funds (ESF). The Director of Grants will ensure that disbursements and receipts are recorded to the appropriate funds in order to track the ESF activity for each year. The Treasurer will use the underlying funds ledgers to then determine the amount of ESF draws to request in each respective period. This will ensure that funds are not drawn in advance of expenditures taking place. Employee contracts will be maintained on file and when applicable, timecards will be completed and reviewed timely to ensure the time recorded to the ESF grant is accurate. Responsible Party and Timeline for Completion: Treasurer, Jill Wagoner, Director of Grants, Eric Knebel and Superintendent, Dr. Angela Piazza. The corrective action will be implemented starting immediately.
View Audit 299547 Questioned Costs: $1
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: Corrective action has been taken to ensure that when students have a spring start date in the prior academic year, the enrollment start date is updated to the correct enrollment start date. A cross check with a selection ...
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: Corrective action has been taken to ensure that when students have a spring start date in the prior academic year, the enrollment start date is updated to the correct enrollment start date. A cross check with a selection set has been added to capture any incorrect records and adjust accordingly. Anticipated Completion Date: January 3, 2024
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: For the 2023-2024 academic year Cost of Attendance Budgets were reviewed and tested to correct any miscalculations and omissions. Pell Budgets were updated to correctly differentiate program tuition and fees. Testing for ...
Contact Person: Cynthia McCarthy, Director of Financial Aid Corrective Action: For the 2023-2024 academic year Cost of Attendance Budgets were reviewed and tested to correct any miscalculations and omissions. Pell Budgets were updated to correctly differentiate program tuition and fees. Testing for 2024-2025 academic year has been updated and reviewed to accurately calculate Cost of Attendance Budgets. In some of the findings it was later found that due to changes made in the student’s record, the record should have run through the dynamic redetermination process to update the budget. The staff has been retrained in this process. The process for summer periods of enrollment has been reviewed and revised to flag students who initially applied and or registered for summer classes and subsequently did not register or dropped the classes during the add/drop period and the summer period of enrollment remained thereby calculating a Cost of Attendance for summer. Anticipated Completion Date: January 3, 2024
Condition: The University did not return all Title IV funds in a timely manner due to a lack of communication and review. Planned Corrective Action: Management has implemented the following corrective actions: -Beginning with the spring 2024 semester, an internal peer review process was implemented ...
Condition: The University did not return all Title IV funds in a timely manner due to a lack of communication and review. Planned Corrective Action: Management has implemented the following corrective actions: -Beginning with the spring 2024 semester, an internal peer review process was implemented to verify that Title IV funds are returned within the required timeframe. This involves segregation of duties between the completion of each of the following: 1) official and unofficial withdrawal review, 2) verification of this review, and 3) return of the Title IV funding. -Beginning in February 2024, the process team leader within the Office of Student Aid is monitoring system reports on a periodic basis (weekly for official withdrawals, within 45 days of date of determination for unofficial withdrawals) to ensure procedures are being followed. -Beginning in February 2024 for the fall 2023 semester, quality control reviews are being conducted by the Office of Student Aid’s Compliance and Training Team in which withdrawn students are sampled to monitor compliance. These reviews will be conducted at the end of each semester going forward. -Management will update its Return to Title IV (“R2T4”) procedures to reflect these additional controls. Additionally, job aids related to R2T4 have been reviewed and updated where appropriate and ongoing training has been occurring with the R2T4 specialists. Contact person responsible for corrective action: Melissa J. Kunes, Assistant Vice President for Enrollment Management and Executive Director for Student Aid Anticipated Completion Date: 03/31/2024
View Audit 299535 Questioned Costs: $1
2023-004 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College implement policies and procedures to identify these requirements and timely report to the appropriate regulators. Explanation of disagreement with audit finding: There is no d...
2023-004 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend the College implement policies and procedures to identify these requirements and timely report to the appropriate regulators. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will monitor Dear Colleague Letters and the Federal Student Aid Handbook to ensure compliance with disclosures and reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Jacob Wheeler Planned completion date for corrective action plan: 6/30/24
2023-003 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department develop a process to identify all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with ...
2023-003 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the student financial aid department develop a process to identify all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will conduct a manual review of all refund holds to ensure they are removed to allow timely pay of Title IV credit balances. Name(s) of the contact person(s) responsible for corrective action: Katelyn Dawson Planned completion date for corrective action plan: 6/30/24
2023-001 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Action taken in response to finding – As a result of the audit finding, the Col...
2023-001 Student Financial Assistance Cluster – ALN. 84.007; 84.033, 84.063, 84.268 Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Action taken in response to finding – As a result of the audit finding, the College has updated the WISP with all required elements and will incorporate into board policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Name(s) of the contact person(s) responsible for corrective action: Linda Andres Planned completion date for corrective action plan: 6/30/24
FINDING: 2023-005 Internal Control and Compliance over Special Tests and Provisions Recommendation: We recommend the Partnership establish policies and procedures to ensure that the Tri-Partite board requirements are followed. Action taken: Our state association, CAAP, is working with Community Pa...
FINDING: 2023-005 Internal Control and Compliance over Special Tests and Provisions Recommendation: We recommend the Partnership establish policies and procedures to ensure that the Tri-Partite board requirements are followed. Action taken: Our state association, CAAP, is working with Community Partnership and the Board of Directors on several technical assistance items. Board Development and recruitment of new board members is one of these technical assistance items.
View Audit 299505 Questioned Costs: $1
FINDING: 2023-004 Internal Control and Compliance over Period of Performance Recommendation: We recommend the Partnership establish procedures to ensure the funds are obligated and utilized in the proper period of performance. Action taken: Community Partnership is working with our state associa...
FINDING: 2023-004 Internal Control and Compliance over Period of Performance Recommendation: We recommend the Partnership establish procedures to ensure the funds are obligated and utilized in the proper period of performance. Action taken: Community Partnership is working with our state association, CAAP, to update internal controls and fiscal policies. Procedures to ensure that obligated funds are spent and utilized within the proper period of performance will be included in updated fiscal policies. Most of these issues resulted from the separation with our previous accounting/fiscal services provider who managed our fiscal and accounting services in the 2022 funding period. CP has worked to satisfy almost all outstanding obligations from this separation during the 2023 CSBG funding period, and currently has no outstanding obligations from the 2023 CSBG funding period. Moving forward, CP staff will work diligently with our selected vendor and board of directors to ensure that all funds are spent down within their designated funding periods.
View Audit 299505 Questioned Costs: $1
Planned Corrective Action: Meals on Wheels of the Monterey Peninsula (MOWMP) will address the finding by taking the steps outlined below: 1. Expenditure Allocation: Controller and/or bookkeeper will allocate expenditures based on the number of meals prepared each month and the percentage of meals pr...
Planned Corrective Action: Meals on Wheels of the Monterey Peninsula (MOWMP) will address the finding by taking the steps outlined below: 1. Expenditure Allocation: Controller and/or bookkeeper will allocate expenditures based on the number of meals prepared each month and the percentage of meals prepared for each program and funding. Yearly reviews of the allocation process will be conducted to ensure accuracy and relevance. Adjustments may be made based on changes in meal demand, program requirements, funding sources, or other factors affecting meal preparation costs. 2. Payroll Reporting: On a yearly basis, Managers and/or Directors will allocate the amount of time each employe works based on tasks performed and the amount of time worked on federal award activities. This allocation will be expressed as a percentage of total work hours performed. Periodic adjustments to time allocations may be necessary to reflect changes in project priorities, staffing levels, or other factors affecting workload distribution. Person Responsible for Corrective Action Plan: Leadership Oversight – Christine Winge, Executive Director Operational Oversight – Kay Smith, Controller Anticipated Date of Completion: MOWMP will complete the Corrective Action Plan by June 1, 2024. We will implement the Corrective Action Plan beginning July 1, 2024.
View Audit 299502 Questioned Costs: $1
2023-001 U.S. Department of Housing and Urban Development CFDA # 14.182, 14.195, 2023 Award Year, Award Number: Not Provided Section 8 Project – Based Cluster Compliance Requirement: Reporting Type of Finding: Compliance Finding Summary: As part of the testing for wait list applicants, the auditors ...
2023-001 U.S. Department of Housing and Urban Development CFDA # 14.182, 14.195, 2023 Award Year, Award Number: Not Provided Section 8 Project – Based Cluster Compliance Requirement: Reporting Type of Finding: Compliance Finding Summary: As part of the testing for wait list applicants, the auditors selected a sample of 60 applications. Of the 60, one instance of the required documentation for the applicant was not available by the property manager. Responsible Individuals: Cory Phelps, VP Project Finance Corrective Action Plan: IHFA Compliance staff will send a memo to all owner/agents in the Project Based Section 8 program that wait list applications must be retained. IHFA will further explain that failure to have proper documentation in the maintained will result in a deficiency on the Management and Occupancy Review. Anticipated Completion Date: December 30, 2023
Federal 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 report is completed timely so that the University can perform the necessary due diligence they need to perform. Explanatio...
Federal 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 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: Recognizing the importance of resolving this finding the University of St Thomas intends to leverage its Internal Audit function in review of its relationship with UAS and the regulations and compliance items therein. Name of the contact person responsible for corrective action: Wade Holmberg Planned completion date for corrective action plan: 6/1/2024
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.
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.
Finding 387179 (2023-001)
Significant Deficiency 2023
Auditor Description of Condition and Effect. Six students received disbursements that were not reported to the federal government within the required timeframe. As a result of this condition, the College did not fully comply with the requirements to report disbursements within 15 days of disbursing ...
Auditor Description of Condition and Effect. Six students received disbursements that were not reported to the federal government within the required timeframe. As a result of this condition, the College did not fully comply with the requirements to report disbursements within 15 days of disbursing funds. Auditor Recommendation. We recommend that the College implement policies and procedures, including designating an individual to oversee this reporting requirement, to ensure information is submitted to the Common Origination and Disbursement in a timely manner. Corrective Action. After recognizing the changes in Federal Regulations, financial aid went through structural changes and moved personnel around. Transitions allowed for a staff member to become the processing specialist. This individual is responsible for running the process of sending files to COD. These transactions happen every week as outlined in written procedures. Responsible Person. Andrew Spohn, Director of Financial Aid. Anticipated Completion Date. July 2023.
Ineligible Programs Planned Corrective Action: Additional training regarding program eligibility has been conducted with the Processing Team. Previously unknown functionality to designate a program as being ineligible for Title IV aid in the Colleague administrative system was identified and implem...
Ineligible Programs Planned Corrective Action: Additional training regarding program eligibility has been conducted with the Processing Team. Previously unknown functionality to designate a program as being ineligible for Title IV aid in the Colleague administrative system was identified and implemented. Title IV funds can no longer be disbursed for programs marked as ineligible. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: February 2024
View Audit 299440 Questioned Costs: $1
Finding 387142 (2023-005)
Significant Deficiency 2023
Fiscal Operations and Application to Participate (FISAP) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their procedures to implement a review process in place befo...
Fiscal Operations and Application to Participate (FISAP) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure that procedures are in place to ensure the FISAP data has a review by a second person prior to submission. The hiring of the Director of Financial Aid will greatly assist in ensuring accuracy of reporting. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: September 2024 filing.
Finding 387136 (2023-004)
Significant Deficiency 2023
Gramm-Leach-Bliley Act Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the requ...
Gramm-Leach-Bliley Act Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College appointed an Information Technology Point of Contact in 2023. Tabor College contracted with Tenfold Security to assist with the requirements of the Gramm-Leach-Bliley Act (GLBA). A Risk Assessment was performed in April 2023 and the final report issued in May 2023. Penetration testing has been completed on a regular basis beginning March 27, 2023. Multi-factor Authentication (MFA) implementation began in June with full implementation with the return of students in August 2024. MFA has been fully implemented for all employees, students, and Board members. The significant undertaking of establishing required Policies and Procedures began in June 2023. A GLBA Committee has been recently been formed to help ensure compliance with all of the established policies and procedures. Tabor continues to work with Tenfold to ensure compliance with the GLBA requirements as of June 9, 2023. Name(s) of the contact person(s) responsible for corrective action: Cathy Castle, Vice President for Business and Finance Planned completion date for corrective action plan: 2024 and ongoing. If the Department of Education has questions regarding this plan, please call Cathy Castle at 620-947-3121 x 1056.
Finding 387130 (2023-003)
Significant Deficiency 2023
National Student Loan Data System (NSLDS) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately re...
National Student Loan Data System (NSLDS) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately 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: Tabor College utilizes a clearing house for submitting student statuses. Enrollment is submitted on a monthly basis, at the beginning of the term, each month and then when the term has ended. Graduate students are reported at the end of the term. Tabor will ensure that all students statuses are filed accurately and timely. A Director of Financial Aid has been hired. This position had been filled by an interim person. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: April 2024
Finding 387124 (2023-002)
Significant Deficiency 2023
Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure...
Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure that ECAR is updated in a timely manner when there is a change in a position of an official for the institution. The two third-party collection agencies for Perkins were added to ECAR on October 31, 2023. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: March, 2024
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