Corrective Action Plans

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Finding 2025-001 Condition: Semi-annual time and effort certifications were not maintained for grant employees whose salaries and wages were not supported by detailed time records. Corrective Action Planned: Controls will be implemented to ensure all time and effort certifications are completed and ...
Finding 2025-001 Condition: Semi-annual time and effort certifications were not maintained for grant employees whose salaries and wages were not supported by detailed time records. Corrective Action Planned: Controls will be implemented to ensure all time and effort certifications are completed and maintained by the appropriate grant administrators for all grant employees. Anticipated Completion Date: June 30, 2026 Contact: Larry Azer, School Business Manager
Management acknowledges the audit finding related to the absence of a formally documented written information security program. While VEEB has implemented certain administrative and technical safeguards to protect sensitive information, these practices have not been consolidated into a single, writt...
Management acknowledges the audit finding related to the absence of a formally documented written information security program. While VEEB has implemented certain administrative and technical safeguards to protect sensitive information, these practices have not been consolidated into a single, written information security program as required. Management is committed to addressing this matter and plans to formalize its existing information security practices into a written information security program that is appropriate to the size, complexity, and risk profile of the organization. Management expects to complete the development and implementation of the written program during the upcoming fiscal year. Management believes that this condition does not reflect a failure to safeguard information, but rather a documentation gap that will be remedied through the actions described above.
Management Response The University concurs with this finding. Management has reviewed its processes for monitoring and issuing Title IV credit balance refunds and has implemented procedures to ensure refunds are processed within the required 14-day timeframe. The Financial Aid and Student Accounts o...
Management Response The University concurs with this finding. Management has reviewed its processes for monitoring and issuing Title IV credit balance refunds and has implemented procedures to ensure refunds are processed within the required 14-day timeframe. The Financial Aid and Student Accounts offices will review credit balance reports on a regular basis to identify students eligible for refunds and confirm timely disbursement. In addition, staff have been reminded of federal requirements related to credit balance refunds. Management will monitor this process periodically to ensure ongoing compliance. Corrective Action The University reviewed the federal requirements for refunds with applicable members of the Business Office and Financial Aid departments to ensure a thorough understanding of the refund rules. The University enhanced its weekly credit balance review process to require explicit review by the Controller and Director of Financial Aid if uncertainty exists on whether a student is eligible for a refund. This review must be completed within the 14 day period with either the refund issued or the loan removed from the student’s account. Contact Person Responsible Name – Richard Jones Title – Controller Phone – 410-532-5367 Email – rjones13@ndm.edu Anticipated Completion Date – April 30, 2026
Management Response The University concurs with this finding and has implemented corrective actions to prevent recurrence. The entrance counseling loan processing rule parameters within the Colleague financial aid module have been updated to prevent loan authorization and disbursement if entrance co...
Management Response The University concurs with this finding and has implemented corrective actions to prevent recurrence. The entrance counseling loan processing rule parameters within the Colleague financial aid module have been updated to prevent loan authorization and disbursement if entrance counseling has not been received and posted to the student's loan record. The system update was implemented in February 2026. In addition, the University reviewed loans processed during the affected period to confirm no additional instances of noncompliance occurred. Financial aid staff have been reminded of federal entrance counseling requirements, and management will periodically monitor system controls to ensure continued compliance. Corrective Action In February 2026, the University updated the entrance counseling loan processing rule parameters within the Colleague financial aid module. From February 2026 forward, the rule parameters would prevent a loan from disbursing if the entrance counseling was not performed. The University reviewed loans processed during the period July 2024 – Feb 2026 to ensure there were no additional loans processed without entrance counseling. Contact Person Responsible Name – Justin Pichey Title – Director of Financial Aid Phone – 410-532-5735 Email - jpichey@ndm.edu Anticipated Completion Date – March 31, 2026
Improve Controls over Earmarking Name of contact person: Connie DeKemper Anticipated completion date: 06/30/2026 Condition – During our audit, we noted that the County utilized 74.4% of the expenditures on out-of-school youth, a deficiency of .6%. Furthermore, the County utilized 15.8% of youth expe...
Improve Controls over Earmarking Name of contact person: Connie DeKemper Anticipated completion date: 06/30/2026 Condition – During our audit, we noted that the County utilized 74.4% of the expenditures on out-of-school youth, a deficiency of .6%. Furthermore, the County utilized 15.8% of youth expenditures for paid and unpaid work experience, a 4.2% deficiency. Response - Expenditures will be reviewed on a monthly basis to ensure earmarking requirements are met. If not, a waiver for the earmarking requirements will be requested from the grantor.
Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct ...
Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026
Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct ...
Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026
Finding: The company did not implement the HUD approved rent adjustments for October 2024 in a timely fashion. Corrective Actions Taken: Management subsequently made the retroactive adjustments to HUD which have been approved by and paid to HUD. In addition, management has implemented a formal revie...
Finding: The company did not implement the HUD approved rent adjustments for October 2024 in a timely fashion. Corrective Actions Taken: Management subsequently made the retroactive adjustments to HUD which have been approved by and paid to HUD. In addition, management has implemented a formal review and corss-verification process to ensure that rent adjustments are completed accurately and in a timely manner.
We have followed up with PaySchools and they have a target date of 4/30/26 for release of SOC Type II report, which should provide documentation on the effectiveness of their controls upon which we can rely when it comes to using their automated free and reduced application processing. In the meanti...
We have followed up with PaySchools and they have a target date of 4/30/26 for release of SOC Type II report, which should provide documentation on the effectiveness of their controls upon which we can rely when it comes to using their automated free and reduced application processing. In the meantime, our Food Service Supervisor will be reviewing all applications retroactive to the beginning of 2025-26.
HeadStart Assistance Listing No. 93.600 Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation o...
HeadStart Assistance Listing No. 93.600 Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation of supporting compliance should be readily available for review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The reporting has been completed. New employees will be trained in the procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation will be available for review during the audit period. Name(s) of the contact person(s) responsible for corrective action: Noah Abraham, DCHS Operations Director. Planned completion date for corrective action plan: Complete
Explanation of disagreement with audit finding: Prior finding was specific to change to withdrawal status not being timely reported in relation to students who never attended and/or stopped attending. Additional scenarios in this finding, to our knowledge, have not been found in a previous audit. We...
Explanation of disagreement with audit finding: Prior finding was specific to change to withdrawal status not being timely reported in relation to students who never attended and/or stopped attending. Additional scenarios in this finding, to our knowledge, have not been found in a previous audit. We acknowledge that they fall within the same finding, but the scenarios that fall within the overall finding are not repeats. Action taken in response to finding: WAU acknowledges the importance of effective internal controls in regards to compliance. As a result, the following corrective action steps will be implemented: • Enrollment Date Discrepancies: o The Registrar’s Office will review finding and determine the best course of action to ensure the degree conferral date for a graduate (Effective date per Institutional Record) and the Effective date per NSLDS Campus Record align. After determination of action an SOP will be created. o The Registrar’s Office will create an SOP and add to the withdrawal policy a statement regarding what the effective date will be when students are unofficially withdrawn for not attending and then later submit an official university withdrawal form. o The Registrar’s Office will research the option of continuous enrollment for students who receive a DG and/or Incomplete grade at the end of a term and do not enroll in the next term. Also, the DG and Incomplete policy will be reviewed to determine if the removal of DG and Incomplete deadline needs to be adjusted. • Program Start Date Discrepancies: o The Registrar’s Office will review finding and determine the best course of action to ensure academic program start dates in institutional records align with NSLDS program start dates. After determination of action an SOP will be created. • Missed Enrollment Certification: o See action plan for Enrollment date discrepancies above (bullet 3) • Enrollment Stats discrepancies: o The Registrar will confirm in NSC that all students who graduated but were not enrolled in the term they graduated from are reported as graduated in NSC in a timely manner and work with financial aid to determine the graduation information is recorded timely and accurately in NSLDS as well. After determination of action an SOP will be created. • Inaccurate Institutional Records: o The Registrar’s Office will review finding and determine the best course of action to ensure that students who we send University Withdrawal forms to, upon their request, get withdrawn even if the form is not returned in a timely manner. After determination of action an SOP will be created. Name(s) of the contact person(s) responsible for corrective action: • Team Lead: Registrar (Lynn Zabaleta) • Internal Control Team: Office staff • Senior Management: AVP Enrollment Management (Dirk Whatley) Planned completion date for corrective action plan: June 30, 2026
1. Drawdown- Financial Director will authorize drawdown with the AVP of Enrollment reviewing and approving the drawdown. 2. Reconciliation- An SOP will be developed having the Financial Advisor/Pell Grant Officer who manages reconciliation of Pelll, SEOG, and Federal work study. Director financial a...
1. Drawdown- Financial Director will authorize drawdown with the AVP of Enrollment reviewing and approving the drawdown. 2. Reconciliation- An SOP will be developed having the Financial Advisor/Pell Grant Officer who manages reconciliation of Pelll, SEOG, and Federal work study. Director financial aid will review and approve reconciliation. For Direct Loans the Direct of Financial aid will prepare the reconciliation to review by the Controller and AVP of Enrollment on a monthly basis. 3. Financial aid Packages- Third party service provider Financial Aid Services (FAS) will complete all financial aid packages with the Director of Financial aid reviewing packaging accuracing by pulling samples of at minimum 25 students for both fall and spring semester. 4. Professional Judgement- An SOP for professional judgment will be created. The Financial aid Director or Pell Grant Officer will prepare the professional judgement. The review and approval to complete by AVP of Enrollment. 5. RT24- Third party service provider (FAS) will prepare RT24 calculations with review and approval by Director of Financial aid and the Associate Vice President of Enrollment. 6. Credit Balances- An SOP will be created to ensure that credit balances are distributed to students within 14 days by verifying enrollment during disbursement. 7. Incentive Compensation – We were unable to verify whether the control to ensure that no incentive compensation is made to employees in the student recruiting and admission, and financial aid departments, is designed and operating effectively. 8. Eligibility – We identified instances in which the Cost of Attendance (COA) used to calculate financial need was inaccurate due to insufficient review and oversight over COA calculations. 9. NSLDS – We noted instances where the University’s records do not match the information shown in the Colleague system, particularly the effective withdrawal dates. Name(s) of the contact person(s) responsible for corrective action: Team Lead: Interim Director of Financial Aid (Alfred Taylor), Director of Student Accounts (Keisha Dublin) ● Internal Control team: Associate Director of Financial Aid (Associate Director of Student Accounts (Arlene Joy Canong), Financial Aid Advisor (Don Lodenquai) ● Senior Management: AVP of Enrollment Management (Dirk Whatley), Controller (Ronald Somervell) ● Financial Aid Services (FAS) Planned Completion Date for Corrective Action Plan: April 26, 2026
The town notified the U.S. Treasury Department of the error in reporting on 01/20/26, requesting to update the FY25 Project & Expenditure Report. The U.S. Treasury Department stated “Prior submitted reports are not eligible to be reopened for revisions since the reporting deadline has passed. The SL...
The town notified the U.S. Treasury Department of the error in reporting on 01/20/26, requesting to update the FY25 Project & Expenditure Report. The U.S. Treasury Department stated “Prior submitted reports are not eligible to be reopened for revisions since the reporting deadline has passed. The SLFRF Project and Expenditure Reports are cumulative reports and any adjustments needed can be made in the current reporting period if it is still open or next open reporting period.” In addition, the town has implemented quarterly reconciliation procedures to ensure all eligible expenditures for the project reporting period are reported correctly. These procedures include a secondary review of all expenditures, reporting parameters and requirements.
Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will...
Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will be acquired by District purchasing agents on the ND DPI Capital Expenditure Prior Approval For Use of Federal Funding form before capital purchase is made using federal funding. Anticipated Completion Date: Fiscal Year 2025-2026
The District will work with the contractors to get the proper payroll records to meet the prevailing wage requirements agreed upon in the contract.
The District will work with the contractors to get the proper payroll records to meet the prevailing wage requirements agreed upon in the contract.
Corrective Action Plan Reporting Finding 2025-007 Roof Above will ensure the review of all grant invoices is documented through the signature of the reviewer on the grant cover sheet. Roof Above will institute a policy that grant invoices will not be submitted without the corresponding review signat...
Corrective Action Plan Reporting Finding 2025-007 Roof Above will ensure the review of all grant invoices is documented through the signature of the reviewer on the grant cover sheet. Roof Above will institute a policy that grant invoices will not be submitted without the corresponding review signature. Contact person responsible for corrective action: Tonya Frye, Chief Financial Officer Anticipated completion date: September 30, 2026
Corrective Action Plan Special Tests: Housing Quality Standards Finding 2025-003 Roof Above will document review of the inspection by sending an email to the grants administrator stating the inspection has been reviewed. Contact person responsible for corrective action: Katie Church, Vice President ...
Corrective Action Plan Special Tests: Housing Quality Standards Finding 2025-003 Roof Above will document review of the inspection by sending an email to the grants administrator stating the inspection has been reviewed. Contact person responsible for corrective action: Katie Church, Vice President of Scattered Site Housing Anticipated completion date: June 30, 2026
Corrective Action Plan Eligibility Finding 2025-002 Roof Above will add signature lines to current client eligibility checklist, to include the name, signature and date for both the person preparing and the person reviewing tenant eligibility. Contact person responsible for corrective action: Katie ...
Corrective Action Plan Eligibility Finding 2025-002 Roof Above will add signature lines to current client eligibility checklist, to include the name, signature and date for both the person preparing and the person reviewing tenant eligibility. Contact person responsible for corrective action: Katie Church, Vice President of Scattered Site Housing Anticipated completion date: June 30, 2026
VIEWS OF RESPONSIBLE OFFICIALS Corrective Action Plan: • The Youth Committee of the Northwest Local Board will be composed of representatives from finance, Budget and Planning staff (Youth Program and Executive), who will measure compliance with 20% work experience expenditure requirement on a month...
VIEWS OF RESPONSIBLE OFFICIALS Corrective Action Plan: • The Youth Committee of the Northwest Local Board will be composed of representatives from finance, Budget and Planning staff (Youth Program and Executive), who will measure compliance with 20% work experience expenditure requirement on a monthly and quarterly basis using updates financial reports. • An immediate review of current fund expenditure will be conducted to determine the exact percentage of compliance and to establish an accelerated spending plan, to ensure compliance with the 20%. • The committee will provide the Executive Director with recommendations to operation areas to meet required expenditure targets in accordance with section 20CFR 681.590, 684.00(a), and 681.600 of WIOA, including specific corrective actions when deviations are identified. • The Northwest Local Area will strengthen outreach strategies for youth program services through social media (Facebook, ticktock, Instagram) radio, television, and the official website, with the goal of increasing recruitment of eligible participants, particularly out of school youth. • Job Fair and Educational fairs for the Youth Program will be developed and implemented to recruit out-of-school youth and increase participation in work experience activities. • Efforts will continue through mass outreach campaigns with an effective strategic plan to expand the reach of the youth program, ensuring a measurable increase in enrollment and participation. • Ongoing monitoring with performance indicators will be implemented, including the percentage of expenditures on work experience and services to out-of-school Youth, with periodic reviews. • If necessary, technical assistance will be requested form the Youth Program Specialist of the Workforce Development Program (PDL) at the Department of Economic Development and Commerce (DDEC). IMPLEMENTATION DATE Immediately RESPONSIBLE PERSONS Executive Director, Finance Director, Youth Program Staff
Finding 2025-004 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Participation of Private School Children Summary of Finding: The School Corporation did not provide supporting documentation for the amounts disbursed for Participation of Private School C...
Finding 2025-004 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Participation of Private School Children Summary of Finding: The School Corporation did not provide supporting documentation for the amounts disbursed for Participation of Private School Children. No time sheets or logs were provided to support the hours paid to employees for working with the Private School Children. Contact Person Responsible for Corrective Action: Randi Libby, Chief Operating Officer Contact Phone Number and Email Address: (260)431-2030, rlibby@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement procedures to ensure consistent documentation supporting Title I services provided to non-public school students. All Title I staff providing services to non-public schools will be required to submit consistent, detailed timesheets documenting hours and/or days worked by non-public school, activity, and grant year. Timesheets will be completed, reviewed, and approved prior to payroll processing. The Payroll Manager will not process payroll for Title I non-public services unless the required timesheets are submitted and approved. Approved timesheets will be retained in the payroll files and organized by payroll dates, and will be made available for audit review. Anticipated Completion Date: July 1, 2026 _________________________ _Randi Libby (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)
Finding 2025-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: The School Corporation and we could not verify the unused Homeless set-aside funds were transferred to the next grant award. Contact Person Responsible for Corrective Action: Randi Libby, ...
Finding 2025-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: The School Corporation and we could not verify the unused Homeless set-aside funds were transferred to the next grant award. Contact Person Responsible for Corrective Action: Randi Libby, Chief Operating Officer Contact Phone Number and Email Address: (260)431-2030, rlibby@sacs.k12.in.us Views of Responsible Official: We disagree with the finding. Explanation and Reasons for Disagreement The School Corporation respectfully disagrees with the conclusion that it failed to comply with Title I homeless setaside requirements. Title I, Part A requires local educational agencies to reserve “such funds as are necessary” to serve homeless children and youth (20 U.S.C. § 6313(c)(3)). Neither the statute nor implementing regulations require that homeless set-aside funds be fully expended each fiscal year, nor do they require unspent homeless set-aside funds to be rolled forward and maintained as a cumulative earmark across successive grant years. During the audit period, the School Corporation increased its homeless set-aside allocation each year based on annual needs assessments. The existence of unspent balances is attributable to year-over-year increases in allocation rather than failure to reserve or obligate funds. Requiring the perpetual rollover of unspent homeless set-aside funds would be inconsistent with Title I’s annual reservation framework and would eventually consume the full 15% Title I carryover limitation, a result not contemplated by federal statute or guidance. While the auditors were unable to verify homeless set-aside expenditures to their satisfaction due to documentation and monitoring gaps, the School Corporation does not agree that this constitutes noncompliance with the earmarking requirement itself. The statutory obligation is to reserve funds based on need, which the School Corporation did. Description of Corrective Action Plan: Although the School Corporation disagrees with the compliance conclusion, it recognizes the need to strengthen internal controls and documentation related to Title I set-aside monitoring. Going forward, the School Corporation will implement enhanced procedures to document: • the annual determination of the homeless set-aside amount, • periodic monitoring of expenditures against the approved reservation, and • year-end reconciliation of reserved versus expended funds within each grant year. These procedures are intended to improve audit transparency and documentation while maintaining compliance with Title I statutory requirements. INDIANA STATE BOARD OF ACCOUNTS 31 Preparing today’s learners for tomorrow’s opportunities. Anticipated Completion Date: January 31, 2026 _________________________ _Randi Libby (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)
Finding 2025-002 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or dete...
Finding 2025-002 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting material noncompliance. Contact Person Responsible for Corrective Action: Erika Horner, Director of Food Service Contact Phone Number and Email Address: (260)431-2030, ehorner@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All direct certification information shall be initiated by the Director of Food Service: pulling the information monthly from CNP Web. The list of students to be directly certified will be printed, signed and dated by the Director of Food Service. Once information is imported into the student management system, the Assistant Food Service Director would then cross reference the printed list of information to benefits assigned in the student management system to ensure accuracy. The Assistant Food Service Director will initial next to the students they spot check on the list. The printed document with signatures of both parties will be retained with the school years applications.􀯗 The Director of Food Service has the responsibility to ensure that all vendors are free from suspension, debarment, or aren’t otherwise excluded. Suspension and debarment documents are to be collected on a yearly basis. If such documents are not available through the SFA Cooperative, it will be the responsibility of the Director of Food Service to acquire them through SAM.gov website or contacting the vendor directly. All documents are to be signed, dated, and retained by school year by both the Director of Food Services and the Asst. Director of Food Services. Anticipated Completion Date: January 31, 2026 _________________________ Randi Libby_ (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)
All free and reduced meal applications are completed electronically by the parent or guardian through the District's online application system. The parent/guardian inputs household and financial information used to determine eligibility in accordance with the income eligibility guidelines establishe...
All free and reduced meal applications are completed electronically by the parent or guardian through the District's online application system. The parent/guardian inputs household and financial information used to determine eligibility in accordance with the income eligibility guidelines established by the State of Ohio and the National School Lunch Program. To ensure internal controls are in place and that eligibility determinations are accurate, the District will implement a review process whereby all electronic applications submitted by parents or guardians will be reviewed by the Cafeteria Supervisor or a designated staff member prior to final approval. The reviewer will ensure that all required fields are completed, the information provided appears reasonable, and the eligibility determination generated by the system is appropriate based on the information provided on the application. If any application appears incomplete or contains questionable information, the Cafeteria Supervisor or designee will contact the parent or guardian for clarification or correction prior to approving the application. Documentation of the review will be maintained by a checklist or retained electronically to demonstrate that the review occurred. Periodic monitoring of the process will be performed to ensure the control procedures continue to operate as intended and that applications are properly reviewed before eligibility is finalized. Anticipated Completion Date Effective immediately and ongoing. Responsible Contact Person Cafeteria Supervisor Dawn Nelson
2025-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Pro...
2025-001 Eligibility, Reporting (Financial) and Special Tests (Disbursements to or on Behalf of Students) Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education and U.S. Department of Health and Human Services (DHHS), DHHS Health Resources and Services Administration Program Titles and Assistance Listing Numbers (ALN): Federal Supplemental Educational Opportunity Grants (ALN 84.007), Federal Work-Study Program (ALN 84.033), Federal Perkins Loans (ALN 84.038), Federal Pell Grant Program (ALN 84.063), Federal Direct Student Loans (ALN 84.268), Nurse Faculty Loan Program (ALN 93.264), Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students (ALN 93.342), Nursing Student Loans (ALN 93.364), Scholarships for Health Professions Students from Disadvantaged Backgrounds (ALN 93.925) Federal Grant Numbers: E P007A252602 (7/1/2024 – 6/30/2025), E P033A252602 (7/1/2024 – 6/30/2025), E P038A132602 (7/1/2024 – 6/30/2025), E P063P250272 (7/1/2024 – 6/30/2025), P268K260272 (7/1/2024 – 6/30/2025), E-01HP28821-02-02, E-01HP31830-01-00,(7/1/2024 – 6/30/2025), E4CHP42498-01-00 (7/1/2024 – 6/30/2025), E26HP25750, E36HP25751, E11HP27284, E36HP26092, E36HP25751, E26HP25748 (7/1/2024 – 6/30/2025) Contact Person: Robert Fahy, AVP of University Enrollment Services, 848-932-2603 Corrective Action: Since the audit period, the University has strengthened governance and oversight over OSFP by formalizing access controls and reinforcing monitoring practices. Management has established and documented OSFP system roles and responsibilities. A review of user access was performed to ensure alignment with job responsibilities, and users holding multiple or incompatible roles were corrected. In addition, the University implemented an audit log to track user provisioning and deprovisioning activity, providing documented evidence of access changes and removals. The University has also enhanced its change management process to ensure that all updates to OSFP follow the documented change management procedures. These measures collectively strengthen logical access and change management controls and support effective internal control over system operations. Management will continue to monitor the effectiveness of these controls. Anticipated Completion Date: Completed
Student Financial Assistance Cluster Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to prope...
Student Financial Assistance Cluster Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to properly capture return of Title IV funds on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned corrective action: Currently, the return of Title IV calculations are done manually and a second person within Financial Aid reviews the calculation. The University is working on a training engagement for the Financial Aid office which will explore the ability to perform the return of Title IV calculations within the ERP system. A second person would continue to review the calculation. Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid If the United States Department of Education has questions regarding this plan, please call Shari Keffer, Vice President for Administration & Finance at 618-537-6838.
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