Corrective Action Plans

Finding 370261 (2023-002)

Significant Deficiency 2023

Ave Maria University, Inc. and Subsidiaries

FL

Questioned Costs Subrecipient Monitoring Eligibility § 200.328 § 200.329

The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of ...

The University filed four quarterly HEERF reports for the year that accurately reflected the spending and accounting of federal funds. The report in question is the annual report, which, by its design (it cannot be saved prior to submission, and the only way to print it is to print a screen shot of each of the 48 pages) makes review before submission extremely difficult. There were literally hundreds of entries in this report, and there were three errors, each of which reflected information that was reported accurately in the quarterly reports posted on the University’s website. Despite the unfortunate design constraints, the University will endeavor to identify a practical way to conduct a review of the annual report before submission next spring. Anticipated Completion Date: Continuing Responsible Contact Person: Eugene L. Munin

View Audit 291876

Finding 370252 (2023-004)

Significant Deficiency 2023

Association House of Chicago

IL

Questioned Costs Reporting Significant Deficiency

Action taken in response to finding: Management will ensure authorizations are reflected on monthly expenditure reports. Policies will be updated to include alternative methods of documenting review and approval, such as an email to keep on file with the calculation. Name of contact person responsib...

Action taken in response to finding: Management will ensure authorizations are reflected on monthly expenditure reports. Policies will be updated to include alternative methods of documenting review and approval, such as an email to keep on file with the calculation. Name of contact person responsible for corrective action: Juan Carlos Linares, President and CEO Planned completion date for corrective action plan: December 31, 2023

View Audit 291860

Finding 370251 (2023-003)

Significant Deficiency 2023

Association House of Chicago

IL

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency

Action taken in response to finding: Management will develop and implement a process whereby payroll costs for staff are supported by a system of internal controls which will provide reasonable assurance that the charges are accurate, allowable, and properly allocated. Name of contact person respons...

Action taken in response to finding: Management will develop and implement a process whereby payroll costs for staff are supported by a system of internal controls which will provide reasonable assurance that the charges are accurate, allowable, and properly allocated. Name of contact person responsible for corrective action: Juan Carlos Linares, President and CEO Planned completion date for corrective action plan: December 31, 2023

View Audit 291860

Finding 370250 (2023-002)

Significant Deficiency 2023

Association House of Chicago

IL

Reporting Internal Control / Segregation of Duties

Action taken in response to finding: Management will implement a process to evaluate grant agreements and properly identify federal funding which will be reviewed to ensure the final SEFA is accurate and free of errors. Name of contact person responsible for corrective action: Juan Carlos Linares, P...

Action taken in response to finding: Management will implement a process to evaluate grant agreements and properly identify federal funding which will be reviewed to ensure the final SEFA is accurate and free of errors. Name of contact person responsible for corrective action: Juan Carlos Linares, President and CEO Planned completion date for corrective action plan: December 31, 2023

View Audit 291860

Finding 370243 (2023-001)

Significant Deficiency 2023

Simpson Housing Services, Inc.

MN

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

Simpson management hired additional staff to allow management the additional time necessary to prepare and review internal financial statements in a timely and efficient manner so that the audit can begin and be completed in a timely and efficient manner. Management believes their processes are prop...

Simpson management hired additional staff to allow management the additional time necessary to prepare and review internal financial statements in a timely and efficient manner so that the audit can begin and be completed in a timely and efficient manner. Management believes their processes are properly designed to ensure timely filing of the Single Audit Reporting Package in future years.

View Audit 291844

Finding 370242 (2023-001)

Significant Deficiency 2023

Housing Authority of the City of Richmond

IN

Allowable Costs / Cost Principles Questioned Costs Internal Control / Segregation of Duties § 200.514

2023-001 ALN 14.850 Public and Indian Housing – Allowable Costs/Cost Principles Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. The Authority requires all checks to be signed by the Executive Director as pr...

2023-001 ALN 14.850 Public and Indian Housing – Allowable Costs/Cost Principles Management acknowledges the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. The Authority requires all checks to be signed by the Executive Director as primary signer or Financial Operations manager / Director of Finance as secondary signer as well as chairman of Board in emergency role if primary or secondary is unavailable, all of whom are approved as a bank signatory. All checks under $10,000 require one signature from primary check signer (Executive Director / President-CEO) and All non-recurring monthly expenses over $10,000 require two signatures for approval consisting of any combination Executive Director as primary signer or Financial Operations manager / Director of Finance as secondary signer, or as chairman of Board in emergency role if primary or secondary is unavailable. Person Responsible for Correction of Finding: Mr. Keon Jackson, Executive Director Projected Completion Date: June 30, 2024

View Audit 291840

Finding 370240 (2023-002)

Significant Deficiency 2023

Lutheran Social Service of Minnesota and Affiliates

MN

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Chafee Education and Training Vouchers Program – Assistance Listing No.93.599 Recommendation: We recommend the Organization put procedures in place to retain documentation of supervisory approval of time and effort reports. Explanation of disagreement with audit finding: There is no disagreement wit...

Chafee Education and Training Vouchers Program – Assistance Listing No.93.599 Recommendation: We recommend the Organization put procedures in place to retain documentation of supervisory approval of time and effort reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures and systems will be adjusted to maintain report approval submissions, along with additional reviews to ensure that documentation is maintained. Name(s) of the contact person(s) responsible for corrective action: Drew Erickson, Controller Planned completion date for corrective action plan: 01/31/2024

View Audit 291833

Finding 370217 (2023-002)

Significant Deficiency 2023

Woodbury University

CA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Date: November 11, 2023 From: Verletta Jackson, Registrar To: Moss Adams Subject: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Item: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Def...

Date: November 11, 2023 From: Verletta Jackson, Registrar To: Moss Adams Subject: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Item: Finding 2023-002 Special Tests and Provisions Enrollment Reporting: Significant Deficiency In Internal Control Over Compliance. Corrective Action: The University has updated the status of all students in our latest batch send. That includes and is not limited to all students selected In the Single Audit. Steps/Policies Implemented to avert problem: The process for reporting information to NSLDS through the Clearinghouse works efficiently. The problem in this case, is that the University has always had two individuals with access to the upload data into the Clearinghouse. When one of the individuals responsible for uploading's position was eliminated, authorization was not given to anyone else as a backup. So, when the then Registrar resigned, no one on-site was authorized to upload the already prepared "send". That issue has been resolved and there will always be, once again, two individuals with access to upload. Although the process to resolve this Issue was extremely timely, permission to access the Clearinghouse site was eventually provided. Contact Person: The Registrar, Verletta Jackson is the responsible person. Her contact information is, Verletta Jackson, email Verletta.Jackson@woodbury.edu, phone 818 252 5277. Anticipated Completion Date: Completed as of 10.15.2023

View Audit 291795

Finding 370216 (2023-002)

Significant Deficiency 2023

Lewis-Clark State College

ID

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit find...

Student Financial Aid Cluster: Federal Perkins Loan Program – Assistance Listing No. 84.038 Recommendation: We recommend the college implement a checklist to reference to ensure all required elements of the Perkins loan records are retained as required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reports from third-party servicer will be reviewed monthly and notifications of paid in full will be processed per requirements. A copy of the promissory note stamped paid in full will be retained according to recordkeeping requirements. Name(s) of the contact person(s) responsible for corrective action: Laura Hughes Planned completion date for a corrective action plan: Immediate Implementation

View Audit 291793

Finding 370200 (2023-002)

Significant Deficiency 2023

Independent School District No.15

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Questioned Costs

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 2023-002 Internal Control Over Compliance With Federal Suspension and...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, SPECIAL EDUCATION CLUSTER (INCLUDING COVID-19 FUNDING) – FEDERAL ALN 84.027 AND 84.173 2023-002 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Summary of Finding Criteria – 2 CFR § 180 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the special education cluster. Condition – The District did not have sufficient controls or documentation in place within its special education cluster to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – The District’s Director of Business Services, Ron Meyer. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – There is no disagreement with the finding. Plan to Monitor – The District’s Director of Business Services, Ron Meyer, will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.

View Audit 291778

Finding 370198 (2023-001)

Significant Deficiency 2023

Multicultural Learning Center

CA

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.514

The Center became aware of a discrepancy between the annual ESSER financial reporting and the quarterly reports during the audit. While the quarterly reports to the CDE were accurately reported and expenditures accurately recorded, the annual performance report was created manually, and reported ful...

The Center became aware of a discrepancy between the annual ESSER financial reporting and the quarterly reports during the audit. While the quarterly reports to the CDE were accurately reported and expenditures accurately recorded, the annual performance report was created manually, and reported full allocations per fund, in error during 2023 by the Center’s back-office service providers without review from Center’s management. Upon the Center’s communication with the CDE, the CDE has notified that “according to the U.S. Department of Education for ESSER Annual Reporting, there will be an opportunity to correct the Year 3 report that was submitted in March of 2023. The U.S. Department of Education requires that we submit Year 4 data to them first. This data will be collected in March of 2024. At that time, the LEA should report to the best of their ability, based on the previously reported expenditures. Depending on the previous amount reported, this may mean the LEA is not yet able to fully report applicable expenditures. This will be corrected later. Following the initial Year 4 submission, the U.S. Department of Education will allow for a Year 3 correction period. At this time, the LEA will be able to correct the Year 3 report. Finally, there will be a Year 4 correction period. This correction period will be based on any changes reported during the Year 3 correction period, to allow for a final true up of Year 4 reporting based on actual expenditures.” Therefore, the correction will be made in March of 2024. In the future, the Center’s back-office service providers will be utilizing a stricter rule for cross-checking reports, and will send reports (quarterly and annual) to the Center for a third review before submitting. The Center will also make the correction in March of 2024 per the CDE’s and U.S. Department of Education direction.

View Audit 291776

Finding 370195 (2023-005)

Significant Deficiency 2023

Phoenix Elementary School District No. 1

AZ

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment

The District will review its internal control procedures over federal programs to ensure purchase orders and maintained to support the authorization of purchases before the goods or services are purchased.

View Audit 291755

Finding 370188 (2023-004)

Material Weakness 2023

Lake Region Special Education

ND

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.318 § 200.326

Finding 2023-004 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding summary: During the course of the engagement, Eide Bailly identified that the district did not have a procurement policy in compliance with Uniform Guidence. Responsible Individuals:...

Finding 2023-004 Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Finding summary: During the course of the engagement, Eide Bailly identified that the district did not have a procurement policy in compliance with Uniform Guidence. Responsible Individuals: Rhandi Knutson, Director Corrective action plan: A procurement policy in compliance with Uniform Guidance will be approved and implemented. Anticapted Completion Date: June 30, 2024.

View Audit 291744

Finding 370187 (2023-002)

Significant Deficiency 2023

Housing and Redevelopment Authority of Austin

MN

Internal Control / Segregation of Duties Questioned Costs HUD Housing Programs

Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance, Other Matters Recommendation: We recommend that the HRA continue to evaluate their procedures and controls in place over the submission of these forms. Explanation of Disagreement with Audit Finding: There ...

Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance, Other Matters Recommendation: We recommend that the HRA continue to evaluate their procedures and controls in place over the submission of these forms. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will ensure that all policies and procedures are followed to ensure that the proper submission is completed for all tenants. Official Responsible for Ensuring CAP: Angela Maiden, Finance Director, is the official responsible for ensuring corrective action of the deficiency. Planned Completion Date for CAP: September 30, 2024 Plan to Monitor Completion of CAP: Taggert Medgaarden, Executive Director, will ensure that the above reviews have been completed through discussions with the Finance Director.

View Audit 291732

Finding 370186 (2023-006)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency § 200.303

COVID‐19 Higher Education Emergency Relief Funds – Institution Share Department of Education Federal Financial Assistance Listing #84.425F Activities Allowed or Unallowed and Allowable Costs/Costs Principles Significant Deficiency in Internal Control Finding Summary: The University’s calculated lo...

COVID‐19 Higher Education Emergency Relief Funds – Institution Share Department of Education Federal Financial Assistance Listing #84.425F Activities Allowed or Unallowed and Allowable Costs/Costs Principles Significant Deficiency in Internal Control Finding Summary: The University’s calculated lost revenue was based on average credit hours per semester prior to COVID-19 as compared to fiscal years 2020, 2021 and 2022. There was a formula error in the credit hours used during COVID-19 resulting in an understated amount of lost revenue from the intended methodology. Responsible Individuals: Tami Lansing, Controller Corrective Action Plan: The calculation underwent a review, yet the error eluded detection during the review. In any future COVID-19 lost revenue calculations, we will exercise more detailed scrutiny. The University was constrained by a predetermined threshold for lost revenue, and we had already surpassed that limit. The miscalculation, had it not been overlooked, would have only inflated that amount. It is important to note that the University intentionally approached lost revenue calculations with a conservative basis. Anticipated Completion Date: August 10, 2023

View Audit 291731

Finding 370183 (2023-005)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Enrollment...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Enrollment Reporting Significant Deficiency in Internal Control and Noncompliance Finding Summary: One instance was noted where the enrollment status reported to the National Student Clearing House was not the same as the student’s actual enrollment status. Responsible Individuals: Robert Hoover, Director of Financial Aid and Kristi Bagstad, Registrar, Registrar’s Office Corrective Action Plan: The Registrar’s office will review clearing house batch errors reports and the Financial Aid office will conduct quality sampling once a semester. Anticipated Completion Date: Commenced December 1, 2023

View Audit 291731

Finding 370180 (2023-004)

Significant Deficiency 2023

Clarke University of Dubuque, Iowa

IA

Special Tests & Provisions Questioned Costs Student Financial Aid

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: ...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program 2022/2023 P063P201430 Special Tests & Provisions: Verification Significant Deficiency in Internal Control over Compliance Finding Summary: Four instances were identified where there was no documented control over student verification. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: With the recent filling of vacant positions, newer staff were being trained on these processes. As such, multiple reviews were occurring simultaneously and were not documented in their usual manner as they would occur outside phases of training. Now that staff have been trained, review processes are being documented to enhance the visibility of control practices. Anticipated Completion Date: Commenced November 1, 2023

View Audit 291731

Finding 370177 (2023-003)

Material Weakness 2023

Clarke University of Dubuque, Iowa

IA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisio...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2022/2023 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2022/2023 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: Eight instances were identified where there was no documented control over the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: With the recent filling of vacant positions, newer staff were being trained in these processes. As such, multiple reviews were occurring simultaneously and were not documented in their usual manner as they would occur outside phases of training. Now that staff have been trained, review processes are being documented to enhance the visibility of control practices. Anticipated Completion Date: Commenced November 1, 2023

View Audit 291731

Finding 370163 (2023-001)

Material Weakness 2023

Community Mental Health Affilates, Inc.

CT

Cash Management Internal Control / Segregation of Duties

CMHA has revised its Selection and Hiring Policy to include certain mandatory alerts and action items whenever an OIG exclusion inquiry shows an individual has been excluded. In addition, the policy has been updated to explicitly referenceOIG exclusion inquiries as part of the screening process and ...

CMHA has revised its Selection and Hiring Policy to include certain mandatory alerts and action items whenever an OIG exclusion inquiry shows an individual has been excluded. In addition, the policy has been updated to explicitly referenceOIG exclusion inquiries as part of the screening process and requires regular inquires to be performed on the entire staff of active employees, interns, vendors, and independent contractors every 60 days. CMHA is also in the process of contracting with a vendor to perform these regular OIG exclusion inquiries. CMHA maintains the good faith belief that the corrective actions described above will mitigate the risk of hiring or retaining an individual who has been excluded from participating in Medicare, Medicaid, or any other Federal health care program going forward.

View Audit 291697

Finding 370156 (2023-002)

Significant Deficiency 2023

Culver-Stockton College

MO

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring § 200.303

The College implemented a policy where all special circumstance requests and income verification overrides must be reviewed by a second staff member effective September 2023. The second staff member reviews each override, either approves or denies the paperwork, then signs and dates the paperwork. T...

The College implemented a policy where all special circumstance requests and income verification overrides must be reviewed by a second staff member effective September 2023. The second staff member reviews each override, either approves or denies the paperwork, then signs and dates the paperwork. The paperwork is returned to the first staff member to make the changes in PowerFAIDS. The responsible college official is Tina Wiseman, Director of Financial Aid.

View Audit 291681

Finding 370118 (2023-001)

Significant Deficiency 2023

Coquille Valley Hospital District

OR

Questioned Costs Reporting Significant Deficiency

Provider Relief Fund Program – CFDA 93.498 Recommendation: CLA recommends the Health System perform review procedures over reporting expenses in a timely manner, so expenses are accurately reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Acti...

Provider Relief Fund Program – CFDA 93.498 Recommendation: CLA recommends the Health System perform review procedures over reporting expenses in a timely manner, so expenses are accurately reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Health System have input of information reviewed before it is submitted. After being filled out the preparer will have another review the inputs before submitting. Name(s) of the contact person(s) responsible for corrective action: Michelle Reyna and Jennifer Stine Planned completion date for corrective action plan: March 31, 2024 If there are any questions regarding this plan, please call Michelle Reyna at (541) 396- 1067.

View Audit 291628

Finding 370101 (2023-002)

Material Weakness 2023

Westmoreland County Community College

PA

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

Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities Westmoreland County Community College continued to provide the same Covid outreach programs as they had years one and two in year three to their Students and Employees and community. • Vaccination clinics were ...

Finding 2023-002: Education Stabilization Fund Allowable Costs and Allowable Activities Westmoreland County Community College continued to provide the same Covid outreach programs as they had years one and two in year three to their Students and Employees and community. • Vaccination clinics were continued and are still offered. However, these are at no cost to the University, student, or employee. • Hand sanitizer, masks and other items are always available to those who require, but were paid for from prior years funds. • When advertising for all Covid related events Westmoreland used sources which were at no cost to the college. • The staff time to organize and manage events did not get allocated to the grant, however would have been covered under the lost revenue recognition.

View Audit 291618 Questioned Costs: $1

Finding 370090 (2023-005)

Material Weakness 2023

Westmoreland County Community College

PA

Questioned Costs Internal Control / Segregation of Duties

Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act - Student Information Security WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines o...

Finding 2023-005: Student Financial Assistance Cluster Gramm-Leach-Bliley Act - Student Information Security WCCC created a written information security program that addresses the required minimum elements. The condition was corrected by implementing the security plan and following the guidelines of the GLBA. The plan was implemented as of 12/1/23. Moving forward we will continue to monitor the requirements of GLBA.

View Audit 291618 Questioned Costs: $1

Finding 370089 (2023-004)

Material Weakness 2023

Westmoreland County Community College

PA

Questioned Costs Special Tests & Provisions Student Financial Aid

Finding 2023-004: Student Financial Assistance Cluster Return of Title IV Funds As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Add...

Finding 2023-004: Student Financial Assistance Cluster Return of Title IV Funds As previously noted, the root cause was human error based on the manual processes. Similar to the previous finding, the College has implemented increased internal control through the review of the R2T4 calculations. Additionally, when using the automated functionality within the system for the return of funds calculation, an independent review of the calculation will be performed moving forward. In the future, the new ERP will increase the levels of control configured in the system. The President will ensure the controls are in place.

View Audit 291618 Questioned Costs: $1

Finding 370088 (2023-003)

Material Weakness 2023

Westmoreland County Community College

PA

Student Financial Aid Questioned Costs Internal Control / Segregation of Duties

Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility and SEOG Pell The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to...

Finding 2023-003: Student Financial Assistance Cluster Allowable Costs and Allowable Activities and Eligibility and SEOG Pell The findings noted three separate issues related to policies and procedures verifying the accuracy of the student eligibility for grant funding and the proper amount paid to the student based on financial need. After a review of Pell grants, Return To Title IV funds, and the award of SEOG after a return of Title IV calculation, it was determined that human error as a result of manual work was the root cause. To correct the root cause, an increased level of internal control via another level of review and a re-review of aid for the FY24 year was implemented. Further, for students who had an enrollment status of less than full time, we have had increased the number reviews for compliance. Moving forward, the College is implementing a new ERP system in which internal controls are configured to alleviate manual work thus human error and increase compliance. The President will ensure the controls are in place.

View Audit 291618 Questioned Costs: $1

Corrective Action Plans

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