Corrective Action Plans

Finding 369367 (2023-004)

Significant Deficiency 2023

OK

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

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Univers...

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. We also recommend the University disburse the proper Pell award to these students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Check Pell Calculation settings in banner and adjust, if needed, to achieve maximum accuracy based on student criteria (COA, EFC/SAI, Enrollment Status). Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24

View Audit 290586

Finding 369355 (2023-001)

Significant Deficiency 2023

Oklahoma Panhandle State University

OK

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend that the Col...

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 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: OPSU will communicate closely with OSU IT and the Office of Internal Audit regarding changes made at the system level to satisfy GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Elizabeth McMurphy and Dasha Smith Planned completion date for corrective action plan: May 2024

View Audit 290586

Finding 369346 (2023-004)

Material Weakness 2023

Drug Prevention Resource Center D/b/a Inneract Alliance

FL

Material Weakness Reporting Internal Control / Segregation of Duties

Timely Reporting Condition: There was a lack of evidence of timely remittance of two PPG reports. There was also one instance of board listing report not submitted by required due date. Recommendation: We recommend documenting and retaining all submittal support when reports are submitted each year....

Timely Reporting Condition: There was a lack of evidence of timely remittance of two PPG reports. There was also one instance of board listing report not submitted by required due date. Recommendation: We recommend documenting and retaining all submittal support when reports are submitted each year. CLA also recommends that the Center keep track of relevant due dates to insure timely submittal of reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: PPG reports were submitted on time whenever possible however there were instances where changes were requested and there were subsequent reports which made the submission date appear to be tardy. For future clarification, the staff will add date submitted on the bottom of those reports to be saved in our own database with additional dates for 2nd or 3rd submissions due to change requests. Name(s) of the contact person(s) responsible for corrective action: Angie Ellison Planned completion date for corrective action plan: Staff will add date submitted to the Quarterly reports already submitted for the 23/24 year and will include the submittal date to all future quarterly reports for ppg and all reports requested by managing entity. If the Oversight Agency has question"s regarding this plan, please call Angie Ellison at (863) 802-0777 .

View Audit 290570

Finding 369345 (2023-003)

Material Weakness 2023

Drug Prevention Resource Center D/b/a Inneract Alliance

FL

Material Weakness Reporting Matching / Level of Effort / Earmarking

Matching Calculation Condition: During review of yearly match calculation report, It was noted the match was not correctly reported. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating who is preparing and who is reviewing match form. Expla...

Matching Calculation Condition: During review of yearly match calculation report, It was noted the match was not correctly reported. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating who is preparing and who is reviewing match form. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Match reports are input into a data document that includes providers in 14 counties. For this reason, our managing entity was requested to send our version without the other counties. The wrong version was sent (quarter 3 instead of final year end version) therefore from this date forward we will keep each quarterly version in our database with added line items that list the preparer and tile approval w/date. Name(s) of the contact person(s) responsible for corrective action: Angie Ellison Immediate: Staff will go back to quarter 1 of 23/24 year and make these changes with copies in database as well as preparer and approval lines w/date. These documents will be prepared in this fashion from this date forward.

View Audit 290570

Finding 369344 (2023-002)

Material Weakness 2023

Drug Prevention Resource Center D/b/a Inneract Alliance

FL

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management

Lack of Review Condition: During review of employee timesheets and related grant reimbursement requests, and annual match report, there was a lack of evidence of review of these documents. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating...

Lack of Review Condition: During review of employee timesheets and related grant reimbursement requests, and annual match report, there was a lack of evidence of review of these documents. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating who is preparing and who is reviewing reimbursement forms and match reports. We also recommend that those approving timesheets document their approval via a signature. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned: While some of these documents (example: match) are not in our control, we will save them in a file for our use with the added lines that include preparer's name, approval line and signature Name(s) of the contact person(s) responsible for corrective action: Angie Ellison Planned completion date for corrective action Rian: All form revisions will begin March 1 2024

View Audit 290570

Finding 369330 (2023-004)

Material Weakness 2023

Great Plains Food Bank

ND

Special Tests & Provisions Material Weakness Equipment & Real Property Management

U.S. Department of Agriculture CFDA # 10.569 Food Distribution Cluster Finding Summary: Great Plains Food Bank does not have consistent and effective controls in place over inventory to properly track and record receipts and distributions due to changes in staff, facilities and inventory programs....

U.S. Department of Agriculture CFDA # 10.569 Food Distribution Cluster Finding Summary: Great Plains Food Bank does not have consistent and effective controls in place over inventory to properly track and record receipts and distributions due to changes in staff, facilities and inventory programs. Responsible Individuals: Melissa Sobolik, CEO and David Stachon, CFO Corrective Action Plan: The GPFB has taken steps to continue to learn more about our new inventory software, P2, and will continue to educate ourselves in the best use of this program. Also, we will do a quarterly catch-up inventory reconciliation within the program to avoid large year end adjustments. The Inventory Control Manager has a set schedule for audits including quarterly inventory in Bismarck, a twice a year full audit and inventory counts by program quarterly. Anticipated Completion Date: On going

View Audit 290553

Finding 369320 (2023-005)

Significant Deficiency 2023

Great Plains Food Bank

ND

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring

U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individu...

U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Responsible Individuals: Melissa Sobolik, CEO and David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP and CSFP programs have proper signatures by necessary parties going forward. An electronic signature process has been implemented to make the dissemination, review and storage of this process easier. Anticipated Completion Date: Immediate

View Audit 290553 Questioned Costs: $1

Finding 369318 (2023-005)

None 2023

Cleary University

MI

Student Financial Aid Internal Control / Segregation of Duties

Detailed Reconciliations Between Common Origination and Disbursement (COD) and University Records Planned Corrective Action: The University understands and concurs with the auditors finding to the lack of a detailed reconciliation between the Common Origination and Disbursement (COD) and Univers...

Detailed Reconciliations Between Common Origination and Disbursement (COD) and University Records Planned Corrective Action: The University understands and concurs with the auditors finding to the lack of a detailed reconciliation between the Common Origination and Disbursement (COD) and University Records. While Cleary was reconciling monthly totals between the COD and University Records; it was brought to our attention during the audit that it needed to be in greater detail. Going forward, the plan of action will be that on a monthly basis; reports will be generated from the COD (Loan and Pell Disbursement Detail Reports) and compared to the Student Information System (SIS). This will be completed monthly on a student-by-student detailed basis. This will be completed by the Financial Aid Department with the assistance of the Business Office to ensure that accuracy. A copy of the monthly reconciliation will be saved in our Month End Folder; for Leadership to review at any time. Person Responsible for Corrective Action Plan: Michael Mathis, Director of Financial Aid Anticipated Date of Completion: January 2024

View Audit 290552

Finding 369315 (2023-004)

Material Weakness 2023

Cleary University

MI

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: The University understands and concurs with the incorrect and untimely return of some Title IV funds. In response, the University has taken three (3) immediate steps to address this deficiency in the futu...

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: The University understands and concurs with the incorrect and untimely return of some Title IV funds. In response, the University has taken three (3) immediate steps to address this deficiency in the future. First, the institution has added financial aid staff with significant expertise and experience in the administration of the R2T4 process to periodically review standard and modular students R2T4 to ensure accurate, timely and compliant returns and reporting. Second, the University has identified policy and procedure improvements that align with best practice approaches to R2T4 administration in support of Pell recalculations and accurate return of funds. Finally, the institution has identified professional development opportunities for all financial aid, and associated personnel, to improve theoretical and practical awareness and implementation of the return process i.e., conference/webinar participation, in-house training workshops and discussions, identified liaison/unit champion roles, etc. Person Responsible for Corrective Action Plan: Michael Mathis, Director of Financial Aid Anticipated Date of Completion: January 2024

View Audit 290552 Questioned Costs: $1

Finding 369307 (2023-002)

Significant Deficiency 2023

Union Parish School Board

LA

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Finding 2023-002 Internal Controls Over Reporting Conditions Identified: Testing the annual ESSER performance report with data on expenditures, subrecipients, uses of funds including mandatory reservation, expenditures, number of key positions, and criteria used to allocate the funds to the schools ...

Finding 2023-002 Internal Controls Over Reporting Conditions Identified: Testing the annual ESSER performance report with data on expenditures, subrecipients, uses of funds including mandatory reservation, expenditures, number of key positions, and criteria used to allocate the funds to the schools was not complete and did not agree with information submitted to the LDOE. Corrective Action Plan: The staff member who is responsible for preparing and completing the necessary ESSER reports has received a copy of this finding and will make the necessary changes when future information is submitted to the LDOE.

View Audit 290539

Finding 369243 (2023-001)

Material Weakness 2023

Dubuque County

IA

Material Weakness Reporting Internal Control / Segregation of Duties § 200.303

Finding 2023-001 Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Federal Agency Name: Department of the Treasury Program Name: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Finding Summary: The County’s quarter...

Finding 2023-001 Reporting Material Weakness in Internal Control Over Compliance and Material Noncompliance Federal Agency Name: Department of the Treasury Program Name: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Finding Summary: The County’s quarterly Project and Expenditure Reports were not reviewed and approved by a separate individual outside of the preparer. The reports submitted in fiscal year 2023 did not contain obligation and expenditure information for $10,000,000 in revenue replacement expenditures allocated to fiscal year 2023 eligible employee wages. Responsible Individuals: Stella Runde, Budget Director Corrective Action Planned: Moving forward, the Finance Director will review and approve the reports prior to being submitted by the Budget Director. Anticipated Completion Date: June 30, 2024

View Audit 290531

Finding 369237 (2023-004)

Material Weakness 2023

Community Crisis Services and Food Bank

IA

Cash Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Recommendation: We recommend the Organization implement a documented review process for reimbursement requests before submitting the requests monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has p...

Recommendation: We recommend the Organization implement a documented review process for reimbursement requests before submitting the requests monthly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has put into place an added month end process that includes verification that all billing has been reviewed. Name(s) of the contact person(s) responsible for corrective action: Angie Meiers Planned completion date for corrective action plan: February 2024

View Audit 290497

Finding 369236 (2023-003)

Material Weakness 2023

Community Crisis Services and Food Bank

IA

Cash Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Recommendation: We recommend the Organization documents review of all payroll reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has put into place an added payroll process that includes monthly ver...

Recommendation: We recommend the Organization documents review of all payroll reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CommUnity has put into place an added payroll process that includes monthly verification that all reports have been reviewed. Name(s) of the contact person(s) responsible for corrective action: Angie Meiers Planned completion date for corrective action plan: February 2024

View Audit 290497

Finding 369128 (2023-003)

Significant Deficiency 2023

Oklahoma State University

OK

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disag...

US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.038, 84.063, 84.268, 84.379, 84.033 Recommendation: CLA recommends that the University 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 planned/taken in response to finding: OSU is creating a GLBA management program to govern security of GLBA data and ensure compliance with associated requirements. Name(s) of the contact person(s) responsible for corrective action: Aaron Smith, Director of Information Security Services/Information Security Officer. Planned completion date for corrective action plan: March 31, 2024

View Audit 290482

Finding 369081 (2022-009)

None 2023

Wheeling Jesuit University INC

WV

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

FINDING 2022 – 009: Repeat of Prior Year Finding 2021-012 Type of Finding: Allowable Costs and Activities Name of Responsible Individual: Gregory Bloomfield (304-243-2233) Criteria: Reporting: The American Rescue Plan (ARP) established two new required uses of HEERF III institutional portion grant f...

FINDING 2022 – 009: Repeat of Prior Year Finding 2021-012 Type of Finding: Allowable Costs and Activities Name of Responsible Individual: Gregory Bloomfield (304-243-2233) Criteria: Reporting: The American Rescue Plan (ARP) established two new required uses of HEERF III institutional portion grant funds for public and private nonprofit institutions in which a portion of funds must be used to: (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances. Condition: The University did not use any portion of the HEERF III institutional funds to conduct direct outreach to financial aid applicants. Corrective Action: The University will formalize and document financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this will create a reasonable transition plan during employee turnover, as well as ensure proper and timely filings. Anticipated Completion Date: Correction Action complete as this Federal program has been since exhausted; no further disbursements nor reporting requirements to date.

View Audit 290469

Finding 369077 (2022-007)

Significant Deficiency 2023

Wheeling Jesuit University INC

WV

Reporting Significant Deficiency Internal Control / Segregation of Duties

FINDING 2022 – 007 Repeat of Prior Year Finding 2021-011 Type of Finding: Significant Deficiency - Reporting Federal Award Program: COVID – 19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID – 19 HEERF Institutional Portion Federal Agency: U.S. Department of Education As...

FINDING 2022 – 007 Repeat of Prior Year Finding 2021-011 Type of Finding: Significant Deficiency - Reporting Federal Award Program: COVID – 19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion and COVID – 19 HEERF Institutional Portion Federal Agency: U.S. Department of Education Assistance Listing Number: 84.425E, 84.425F Federal Award Year: June 30, 2022 Name of responsible Individual: C.F.O., Gregory Bloomfield Criteria: Reporting: The University was required to submit to the Department of Education an annual report of its HEERF expenditures using the Annual Report Data Collection System by May 6, 2022. Additionally, the institution is required to post accurate and completed quarterly HEERF information to its primary website. Condition: The annual report was not completed or submitted. Additionally, certain amounts reported on submitted quarterly reports did not reconcile to underlying supporting documentation. Corrective Action: The University will formalize and document financial processes to establish internal controls in order to ensure accurate, timely and consistent reporting. In addition, this will create a reasonable transition plan during employee turnover, as well as ensure proper and timely filings. Anticipated Completion Date: Full implementation and documentation with current staffing is currently in process and estimate completion by March 31, 2024, however, HEERF has since ended so no further reporting is necessary.

View Audit 290469

Finding 369073 (2022-002)

Significant Deficiency 2023

Wheeling Jesuit University INC

WV

Student Financial Aid Reporting Significant Deficiency

FINDING 2022 – 002: Repeat of Prior Year Finding 2021-004 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Federal Award Findings and Questioned Costs Criteria: Recipients of federal awards are required to administer its federal programs with ...

FINDING 2022 – 002: Repeat of Prior Year Finding 2021-004 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Federal Award Findings and Questioned Costs Criteria: Recipients of federal awards are required to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition: The University did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year. Corrective Action: Wheeling University has implemented several significant corrective actions towards improving the reconciliation requirements for the Pell and Direct Loan Programs. A highly administratively capable staff person has been promoted to Assistant Director and demonstrates a level of financial aid leadership that is appreciated throughout the campus community. This individual has received extensive regulatory and technical training regarding the federal requirements to monthly reconcile cash received from the G5 account with disbursements submitted to the COD System. In addition to confirming the accuracy of monthly reconciliation efforts, this approach allows the FA office to compare internal awarding databases against COD’s database for Pell and Direct Loan awards and identify discrepancies that require further attention. Also, this assists the University to be better prepared to perform efficient and accurate closeout activities at year-end. Previous audit findings showed little evidence of accurate reconciliation efforts. In working with the University IT Department, monthly reconciliation files are now housed in a shared electronic file system, easily retrieved for review, and are confirmed for accuracy by the acting Director of Financial Aide each month. Anticipated Completion Date: This process was completed in March of 2023 and is ongoing.

View Audit 290469

Finding 369066 (2023-002)

Significant Deficiency 2023

Moberly Area Community College

MO

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disa...

2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required - usually within 1-5 days from the date it is discovered. This finding of a "late return" is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college's attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.

View Audit 290466

Finding 369065 (2023-001)

Significant Deficiency 2023

Moberly Area Community College

MO

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

2023-001 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with...

2023-001 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with audit finding: As a standard, regular practice, communicates disbursement information for Federal Pell and Federal loans to COD no less than once per week; therefore, we believe we have an adequate way to report disbursements to COD within 15 days of the disbursement date. MACC transitioned to new financial aid processing software (Jenzabar Financial Aid - JFA) in summer 2022 while other areas of the college were still using the "old" system (Jenzabar CX). We experienced a glitch during the transition in which the files did not update as expected, we worked with our software vendor to correct the issue. Below is the timeline of action taken:This finding pertains to one student with Sub and Unsub Loans. We posted aid and sent the original batch on Friday, 07/15/2022; we discovered the issue on Wednesday, 07/20/2022, and reached out to Jenzabar immediately; we followed up with Jenzabar on Thursday, 07/28/2022 because the records were not updated; the records were updated on Monday, August 1. Action taken in response to finding: MACC continues to submit disbursement information at least once per week and review student details for posting accuracy. We took the necessary steps to fix the issue. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We believe this finding was an anomaly due to the system conversion. We have no evidence of this happening since.

View Audit 290466

Finding 369061 (2023-003)

Material Weakness 2023

White Oak Independent School District

TX

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties

White Oak ISD has been in a period of transition since the Spring of 2023. A new Superintendent was hired in April 2023. Operational areas were assessed, and corrective actions were and continue to be taken to address weak and critical need areas, including the Business Office. The current CFO, at t...

White Oak ISD has been in a period of transition since the Spring of 2023. A new Superintendent was hired in April 2023. Operational areas were assessed, and corrective actions were and continue to be taken to address weak and critical need areas, including the Business Office. The current CFO, at that time, left in May of 2023 and was replaced with a Business Manager in June of 2023. The Business Manager began assessing specific deficiencies within the department. New procedural manuals were adopted in August of 2023. The business manager left in December of 2023 due to personal reasons and a new CFO was hired. A new payroll coordinator was also onboarded during December 2023. Between the new staff members and the new Superintendent all systems have been turned over and are trying to get back to an effective and efficient level of function. The new plan of action is to allow the CFO to set goals and make necessary changes regarding business operations and procedures. The audit findings will be our guide for making corrective actions. The CFO and Superintendent will continue to update processes, written procedures, and establish appropriate internal controls to ensure appropriate oversight and compliance with laws, rules, and regulations. Business Office staff will continue working to adequately segregate duties and establish additional monthly and annual reconciliation processes with oversight by the CFO, program directors, andSuperintendent as appropriate. Responsible Party: Carrie Howard, CFO Estimated Completion Date: August 31, 2024

View Audit 290464

Finding 369060 (2023-002)

Material Weakness 2023

White Oak Independent School District

TX

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties

White Oak ISD has been in a period of transition since the Spring of 2023. A new Superintendent was hired in April 2023. Operational areas were assessed, and corrective actions were and continue to be taken to address weak and critical need areas, including the Business Office. The current CFO, at t...

White Oak ISD has been in a period of transition since the Spring of 2023. A new Superintendent was hired in April 2023. Operational areas were assessed, and corrective actions were and continue to be taken to address weak and critical need areas, including the Business Office. The current CFO, at that time, left in May of 2023 and was replaced with a Business Manager in June of 2023. The Business Manager began assessing specific deficiencies within the department. New procedural manuals were adopted in August of 2023. The business manager left in December of 2023 due to personal reasons and a new CFO was hired. A new payroll coordinator was also onboarded during December 2023. Between the new staff members and the new Superintendent all systems have been turned over and are trying to get back to an effective and efficient level of function. The new plan of action is to allow the CFO to set goals and make necessary changes regarding business operations and procedures. The audit findings will be our guide for making corrective actions. The CFO and Superintendent will continue to update processes, written procedures, and establish appropriate internal controls to ensure appropriate oversight and compliance with laws, rules, and regulations. Business Office staff will continue working to adequately segregate duties and establish additional monthly and annual reconciliation processes with oversight by the CFO, program directors, and Superintendent as appropriate. Responsible Party: Carrie Howard, CFO Estimated Completion Date: August 31, 2024

View Audit 290464

Finding 369047 (2023-005)

Significant Deficiency 2023

Connors State College

OK

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Federal Program Title Student Financial Aid Cluster (SFA), GLBA info. security plan ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: The college was missing all of the requirements from the Gram-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of cu...

Federal Program Title Student Financial Aid Cluster (SFA), GLBA info. security plan ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: The college was missing all of the requirements from the Gram-Leach-Bliley Act except for having a Written Information Security Program and secure disposal of customer information. Context: The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b)). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. These new GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Recommendation: We recommend that the College review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Office of Internal Audit is beginning work on another System-wide Information Technology (IT) Penetration Testing and Vulnerability Assessment at all institutions within the OSU/A&M System. They will be coordinating with local IT staff from each institution, as well as the OSU Chief Information Officer, Raj Murthy and the A&M System Chief Information Officer, Heath Hodges, to schedule the work. Name(s) of the contact person(s) responsible for corrective action: Heath Hodges and Kevin Isom, Planned completion date for corrective action plan: March 31, 2024

View Audit 290458

Finding 369043 (2023-004)

Significant Deficiency 2023

Connors State College

OK

Student Financial Aid Internal Control / Segregation of Duties § 200.303

Federal Program Title: Student Financial Aid Cluster (SFA), 240-day limitation on checks ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: Connors State College had 7 instance of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023 Recommendation: W...

Federal Program Title: Student Financial Aid Cluster (SFA), 240-day limitation on checks ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: Connors State College had 7 instance of Title IV refund checks to students that were outstanding longer than 240 days as of June 30, 2023 Recommendation: We recommend that the College start to reconcile stale checks to student disbursement info by check number. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Checks will only be re-issued for up to 180 days. A joint effort between the Bursar, Accounting and Financial Aid offices to reach the students via email, phone, and text before the 180-day deadline. After 180 days the check will be voided, and the funds returned. Name(s) of the contact person(s) responsible for corrective action: Mattie Keys, mattie.keys@connorsstate.edu Planned completion date for corrective action plan: Dec 31, 2023

View Audit 290458

Finding 369039 (2023-003)

Significant Deficiency 2023

Connors State College

OK

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

Federal Program Title: Student Financial Aid Cluster (SFA), COD posting and reconciling. ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD. Context: 1 of the 40 COD disbursements had applied dat...

Federal Program Title: Student Financial Aid Cluster (SFA), COD posting and reconciling. ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD. Context: 1 of the 40 COD disbursements had applied dates greater than 15 days from the disbursement dates. Recommendation: We recommend that the student financial aid department works to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Students identified in the weekly reconciliation that have not posted to COD will be highlighted. In the subsequent reconciliation if student still has not been posted in COD the Financial Aid Director will manually post the student to COD as well as fix any errors so that if can be posted. Name(s) of the contact person(s) responsible for corrective action: Mattie Keys, mattie.keys@connorsstate.edu Planned completion date for corrective action plan: Dec 31, 2023

View Audit 290458

Finding 369035 (2023-002)

Significant Deficiency 2023

Connors State College

OK

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

Federal Program Title: Student Financial Aid Cluster (SFA), 60-day status reporting ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: Fifteen exceptions were observed during Enrollment Reporting testing. The fifteen exceptions were reported beyond the sixty-day allowable timeframe. Context: 1...

Federal Program Title: Student Financial Aid Cluster (SFA), 60-day status reporting ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: Fifteen exceptions were observed during Enrollment Reporting testing. The fifteen exceptions were reported beyond the sixty-day allowable timeframe. Context: 15 of the 40 enrollment changes were reported to NSLDS greater than 60 days from the change Recommendation: CLA recommends implementing a formal review process that involves footing the report to verify clerical accuracy and detect errors during the preparation of the report. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: At the end of each semester a listing of all graduates will be given to the Financial Aid Office from the Registrar. Financial Aid will then go into NSLDS to manually update graduates status. This process will be done in conjunction with the submittion of graduates to the National Clearinghouse by the Registrar. Name(s) of the contact person(s) responsible for corrective action: Mattie Keys, mattie.keys@connorsstate.edu Planned completion date for corrective action plan: Dec 31, 2023

View Audit 290458

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