Corrective Action Plans

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2025-013 West Virginia School of Osteopathic Medicine (WVSOM) response: As of December 2025, WVSOM updated the program enrollment date within the graduation spreadsheet processed out of the Banner system. Going forward, WVSOM registrar will create a calendar reminder to confirm program enrollment on...
2025-013 West Virginia School of Osteopathic Medicine (WVSOM) response: As of December 2025, WVSOM updated the program enrollment date within the graduation spreadsheet processed out of the Banner system. Going forward, WVSOM registrar will create a calendar reminder to confirm program enrollment on the spreadsheet. The reminder function will be used to ensure this step is not missed in the future. WVSOM registrar will check the report diligently for accuracy. Southern West Virginia Community and Technical College (SWVCTC) response: SWVCTC is consulting with the Clearinghouse to better understand and identify any data elements of concern. SWVCTC is working to resubmit enrollment files and will review each file to ensure the data and processes are correct. An internal review by the CIO and Registrar will be done on each submission for a period of at least six months or until all parties are satisfied with the submissions. REPORTING – SPECIAL REPORTING – LIHEAP CARRYOVER AND REALLOTMENT REPORT DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.568 To strengthen internal controls, the Office of Grants Management will reevaluate its current process for tracking LIHEAP program reporting requirements and meeting deadlines. This evaluation, which will be completed by July 1, 2026, will aim to identify specific staff training needs.
2025-011 SPECIAL TESTS AND PROVISIONS: GRAMM-LEACH-BLILEY ACT SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WEST VIRGINIA STATE UNIVERSITY (WVSU) Assistance Listing Numbers: 84.003/84.007/84.038/84.063/84.268/84.379 WVSU has begun the process of developing a written cyber...
2025-011 SPECIAL TESTS AND PROVISIONS: GRAMM-LEACH-BLILEY ACT SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WEST VIRGINIA STATE UNIVERSITY (WVSU) Assistance Listing Numbers: 84.003/84.007/84.038/84.063/84.268/84.379 WVSU has begun the process of developing a written cybersecurity policy. However, due to the recently fluctuating landscape of cybersecurity, security needs involved, and the number of staff available for the task, WVSU has not yet completed, nor approved any policy beyond the preliminary stages. WVSU is committed to having a written cyber security policy by the end of 2025-2026 which will have been approved by WVSU administration. Further delaying the process was a change in CFO during FY 2026.
2025-008 SPECIAL TESTS AND PROVISIONS: UI PROGRAM INTEGRITY - OVERPAYMENTS SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WORKFORCE WEST VIRGINIA (WFWV) Assistance Listing Number: 17.225 The overpayment in question was caused by an appeal decision made by an Administrative...
2025-008 SPECIAL TESTS AND PROVISIONS: UI PROGRAM INTEGRITY - OVERPAYMENTS SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WORKFORCE WEST VIRGINIA (WFWV) Assistance Listing Number: 17.225 The overpayment in question was caused by an appeal decision made by an Administrative Law Judge (ALJ). The overpayment was established and coded correctly based on the ALJ decision in September 2024, even though an overpayment memo was not available. In October 2024, the Benefit Payment Control Overpayment Policy was revised to include instructions to create overpayment memos for all lower and higher authority appeal decisions which result in an overpayment of benefits. Benefit & Technical Support unit staff, who process appeal decisions, were made aware of the requirement.
2025-007 SPECIAL TESTS AND PROVISIONS: UI BENEFIT PAYMENT WORKFORCE WEST VIRGINIA (WFWV) Assistance Listing Number: 17.225 WFWV acknowledges and agrees with the finding that Benefit Accuracy Measurement (BAM) cases were not reviewed and closed within the time limits established by ET Handbook No. 39...
2025-007 SPECIAL TESTS AND PROVISIONS: UI BENEFIT PAYMENT WORKFORCE WEST VIRGINIA (WFWV) Assistance Listing Number: 17.225 WFWV acknowledges and agrees with the finding that Benefit Accuracy Measurement (BAM) cases were not reviewed and closed within the time limits established by ET Handbook No. 395. During the performance year, the BAM team faced significant staffing challenges, which delayed the timely completion of audits and restricted the availability of personnel for reviewing completed cases. To address this issue, WFWV has implemented the following corrective measures: 1. Trained a support staff member in November 2024 to assist BAM analysts with administrative tasks, including setting up new case files, issuing second and third requests for information, and calculating wages based on employer-provided verification forms. This support enables analysts to dedicate more time to core investigative work. 2. Hired an additional BAM analyst in November 2025 to reduce management’s workload in completing audits, allowing them to prioritize the review of completed cases. Furthermore, as of January 2026, management and the BAM support staff now use a shared redesigned spreadsheet to track the progress of assigned cases. This tool provides real-time visibility into case statuses, ensuring more effective monitoring of completion timeliness and preventing future delays.
2025-006 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) Assistance Listing Number: 15.252 The finding states that the DEP did not report subaward information in accordance with reporting requirements. Specifically, two reports sel...
2025-006 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) Assistance Listing Number: 15.252 The finding states that the DEP did not report subaward information in accordance with reporting requirements. Specifically, two reports selected for testing were not reported in a timely manner. Based on the previous year’s finding, DEP implemented standard operating procedures on January 24, 2024, to ensure compliance with the FFATA reporting requirements. DEP concurs that the two reports found to be in noncompliance were, in fact, submitted after the required deadline. This oversight was primarily due to the understaffing of the Sub Grants Unit at the time these reports were to be submitted. DEP currently has sufficient standard operating procedures to ensure compliance with FFATA reporting. DEP will temporarily reassign staff responsibilities to ensure reporting compliance timelines are met until the current vacancy in the Sub Grants Unit can be filled to provide additional support to the existing staff.
2025-005 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF EDUCATION (DOE) Assistance Listing Numbers: 10.553/10.555/10.556/10.559/10.582 During FY 2025, the FFATA reporting system changed from the FSRS site to SAM.gov. Many transactions that were originally enter...
2025-005 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF EDUCATION (DOE) Assistance Listing Numbers: 10.553/10.555/10.556/10.559/10.582 During FY 2025, the FFATA reporting system changed from the FSRS site to SAM.gov. Many transactions that were originally entered into the FSRS site did not transfer over and had to be re-entered into SAM.gov, making those entries appear late. In addition, we had trouble getting the SAM.gov site to accept our FFATA entries. DOE worked with SAM.gov customer support to eventually get the issues resolved, but this also resulted in late reporting. Subsequent to the systematic issues being resolved, all FFATA reports have been completed timely and will continue to be reported timely going forward.
Common Origination and Disbursement (COD) Reporting Recommendation: We recommend the College evaluate its policies and procedures around reporting to the COD to ensure that information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...
Common Origination and Disbursement (COD) Reporting Recommendation: We recommend the College evaluate its policies and procedures around reporting to the COD to ensure that information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: A PELL reconciliation report will be pulled monthly to check that the disbursement dates/amounts on COD match the disbursement dates/amounts on PowerFAIDS and Bionic. Name of the contact person responsible for corrective action: Shannon Braccili, Associate Director of Financial Aid Planned completion date for corrective action plan: Effective starting August 2025 with the first Fall 2025 PELL disbursement and continuing through the end of the academic year. This procedure will continue to be followed in subsequent academic years.
U.S. Department of Education National Student Loan Data Systems (NSLDS) Enrollment Reporting - Federal Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that a...
U.S. Department of Education National Student Loan Data Systems (NSLDS) Enrollment Reporting - Federal Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An investigation that uncovered a National Student Clearinghouse enrollment transmission proofing error related to program-level effective date for graduated students. Name of the contact person responsible for corrective action: James Keane, Registrar Planned Corrective Action Plan: The Registrar's Office will ensure that the program level effective date for graduates is accurate prior to submission. The Registrar will also partner with IITS to ensure that the program-level effective date for graduates is generated in the submission file as expected. Planned completion date for corrective action plan: May 2026, prior to the June 2026 submission date.
To Whom It May Concern: This letter is in response to the audit finding identified in the annual district financial report for fiscal year ending June 30, 2025 issued by Leo Riley & Co. This letter addresses the compliance findings 2025-001 and 2025-002 regarding internal controls. Weston County Sch...
To Whom It May Concern: This letter is in response to the audit finding identified in the annual district financial report for fiscal year ending June 30, 2025 issued by Leo Riley & Co. This letter addresses the compliance findings 2025-001 and 2025-002 regarding internal controls. Weston County School District #7 acknowledges that, due to the small office staff, it makes it impractical for the district to achieve full separation of the accounting functions in the business office. The District believes it has mitigated the risks associated with this limitation through use of various controls and segregation of functions to the greatest extent possible. The governing board is also involved in the approval process being the final authority over accounts payable expenditures. The District utilizes the accounting manual as provided by the Wyoming Department of Education. The business office staff, district administrative staff, and the school board are fully aware of the limitations in this area and have a heightened awareness when performing their duties to further mitigate risks. Gina Barritt WCSD7 Business Manager 307-468-2461
Finding Synopsis: One employee's payroll disbursement made under the Child Nutrition Cluster was improperly calculated. Action Steps: A district staff member will review the payroll calculations so no transpositions or errors occur. Contact Person(s): Dr. Jennifer Garrison, Superintendent Anticipate...
Finding Synopsis: One employee's payroll disbursement made under the Child Nutrition Cluster was improperly calculated. Action Steps: A district staff member will review the payroll calculations so no transpositions or errors occur. Contact Person(s): Dr. Jennifer Garrison, Superintendent Anticipated Completion Date: February 11, 2026
Management is cognizant of this limitation and will implement additional procedures where possible.
Management is cognizant of this limitation and will implement additional procedures where possible.
Segregation of Duties – Child Nutrition Cluster Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Explanation of disagreement with audit findi...
Segregation of Duties – Child Nutrition Cluster Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The District has implemented procedures to ensure that Child Nutrition claims are reviewed and approved prior to submission by an individual knowledgeable of grant requirements. This review includes verification of claim accuracy, supporting documentation, and compliance with applicable federal regulations. Name of the contact person responsible for correction action: Kristin Sobocinski Planned completion date for corrective action: Ongoing, June 30, 2026
Finding Reference Number: Finding 2025-004: Significant Deficiency in Internal Control and Compliance over Reporting – Medicaid Cluster Corrective Action: The District submitted corrected versions of the Quarterly Financial Summaries to SBS after audit fieldwork. The District plans for the Finance D...
Finding Reference Number: Finding 2025-004: Significant Deficiency in Internal Control and Compliance over Reporting – Medicaid Cluster Corrective Action: The District submitted corrected versions of the Quarterly Financial Summaries to SBS after audit fieldwork. The District plans for the Finance Director to review Quarterly Financial Summaries and Annual Cost reports and document this review before submitting to SBS. The payroll coordinator will prepare the quarterly financial summaries and they will be reviewed by the Business Manager prior to submission to ensure accuracy. Responsible Person: Shannon Grindell, Sharon Weise Anticipated Completion Date: Ongoing
Jeff Cottingham, Management agent, and Father Elia, sponsor of the project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Jeff Cottingham, Management agent, and Father Elia, sponsor of the project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Jeff Cottingham, Management agent and Father Elia, sponsor of project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Jeff Cottingham, Management agent and Father Elia, sponsor of project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Jeff Cottingham, Management agent and Wes Clanton, board president of project will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Jeff Cottingham, Management agent and Wes Clanton, board president of project will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the ...
Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the expenditure reports against the budget items before submitting. Management Response: The District will add a verification process to reconcile the general ledger to the budget and expenditure reports before submitting. The District will consider implementing a detailed grant tracking sheet to ensure the general ledger expenditures agree to the expenses reported to ISBE by grant. Anticipated Date of Completion: June 30, 2026
Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the ...
Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the expenditure reports against the budget items before submitting. Management Response: The District will add a verification process to reconcile the general ledger to the budget and expenditure reports before submitting. The District will consider implementing a detailed grant tracking sheet to ensure the general ledger expenditures agree to the expenses reported to ISBE by grant. Anticipated Date of Completion: June 30, 2026
Condition: We noted that two of the five required expenditure reports were not filed in a timely manner. Recommendation: 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. Management Response: Mana...
Condition: We noted that two of the five required expenditure reports were not filed in a timely manner. Recommendation: 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. Management Response: Management will take the necessary steps to file all quarterly reports on time in the future. Anticipated Date of Completion: June 30, 2026
Condition: The Organization lacked adequate controls to ensure reviews were performed by a different individual than the one responsible for preparing monthly financial reporting, calculations of per-unit activity, and requests for reimbursement. Planned Corrective Action: 1. Standardization of Fina...
Condition: The Organization lacked adequate controls to ensure reviews were performed by a different individual than the one responsible for preparing monthly financial reporting, calculations of per-unit activity, and requests for reimbursement. Planned Corrective Action: 1. Standardization of Financial Reporting Workflow: A formal segregation of duties for all federal and pass-through reimbursement requests and financial reports has been implemented. Effective immediately, the individual responsible for accumulating cost data and calculating per-unit activity (preparer) is prohibited from being the reviewer. 2. Implementation of Approval Process: All reports must now be submitted by the preparer to the designated reviewer for approval via email prior to submission. An approval response from the reviewer is required prior to submission to the awarding agency. 3. Staff Training: All grants management and accounting personnel have been briefed on the requirements of 2 CFR 200.303, specifically regarding the necessity of documented internal controls to provide reasonable assurance of compliance. Contact person responsible for corrective action: Erin Nordmann (Controller) Chiyoko Yokota (Chief Financial Officer) Anticipated Completion Date: Fully Corrected
The City has separated duties to the extent possible and has implemented compensating controls to monitor the account activities
The City has separated duties to the extent possible and has implemented compensating controls to monitor the account activities
Finding 2025-003 See response to finding 2025-001.
Finding 2025-003 See response to finding 2025-001.
Condition: There were no controls in place for the annual report [FAA Form 5100-126] for the fiscal year ending September 30, 2025 to ensure the report contained accurate infor-mation and was sent timely to the appropriate FAA airports office. Planned Corrective Action: A review of FAA Form 5100-126...
Condition: There were no controls in place for the annual report [FAA Form 5100-126] for the fiscal year ending September 30, 2025 to ensure the report contained accurate infor-mation and was sent timely to the appropriate FAA airports office. Planned Corrective Action: A review of FAA Form 5100-126 will be conducted with ap-propriate personnel, such as the Controller or Vice President, Treasury Management prior to submitting to the FAA. Review and timely submission will be evidenced via time-stamped DocuSign or other electronic means such as an acknowledgment via email. Contact person responsible for corrective action: Sr. Grants Manager Anticipated Completion Date: 03/31/2026
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all exp...
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all expenses claimed are for expenses paid during the year. Managements Response: The District will take the necessary steps to only claim allowable expenses on future expenditure reports.
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all exp...
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all expenses claimed are for expenses paid during the year. Managements Response: The District will take the necessary steps to only claim allowable expenses on future expenditure reports.
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