Corrective Action Plans

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Action Taken: Management agrees with the recommendations. The management team involved with grants will work to modify and improve the current procedures and will implement the controls surrounding grant compliance, from the application process through final reporting. The team will also continue to...
Action Taken: Management agrees with the recommendations. The management team involved with grants will work to modify and improve the current procedures and will implement the controls surrounding grant compliance, from the application process through final reporting. The team will also continue to work to enhance our grant monitoring, including resuming management team meetings to keep everyone abreast of the status of grants. In addition, we will begin to gradually involve the new business office employee in grant reporting to improve on compliance with grant reporting requirements.
Action Taken: Management agrees with the recommendations. The unique situation with the COVID-19 funding, coupled with shifts in the business manager’s duties over the last few years and the staff retirement has resulted in grant report filings becoming a lower priority. The management team will wor...
Action Taken: Management agrees with the recommendations. The unique situation with the COVID-19 funding, coupled with shifts in the business manager’s duties over the last few years and the staff retirement has resulted in grant report filings becoming a lower priority. The management team will work together and will resume management team meetings to determine and monitor the duties for which each is responsible. Strides have been made in this regard, as the principals have become involved in Federal program training, budgeting, and scheduling. Although the aforementioned report submissions are delinquent and funding was suspended, some filings have been completed, and certain payments are forthcoming. However, management will begin to gradually involve the new business office employee in grant reporting to improve on compliance with grant reporting requirements.
U.S. Department of Health and Human Services, Pass-through Programs from: Nebraska Department of Health and Human Services and the Iowa Department of Health and Human Services HIV Care Formula Grants, AL #93.917 Award No. 24X07HA00042, 24X07HA00041, 5884HC14 Award Periods: April 1, 2023 to March 31,...
U.S. Department of Health and Human Services, Pass-through Programs from: Nebraska Department of Health and Human Services and the Iowa Department of Health and Human Services HIV Care Formula Grants, AL #93.917 Award No. 24X07HA00042, 24X07HA00041, 5884HC14 Award Periods: April 1, 2023 to March 31, 2024 and April 1, 2024 to March 31, 2025 Eligibility: Significant Deficiency in Internal Control over Compliance Finding Summary: For 1 of 25 program participants selected for testing from the State of Nebraska, the participant file was missing documentation of HIV status. For 1 of 13 program participants selected for testing from the State of Iowa, the participant file was missing documentation for the annual recertification. Responsible Individuals: Brent Koster, Executive Director Corrective Action Plan: Procedures will be developed to ensure proper eligibility determinations are maintained in the file. Additionally, recertifications will be completed timely and documentation maintained in the file. Anticipated Completion Date: June 2025
The Board acknowledges its lack of compliance relative to contractor and subcontractor payroll monitoring and omitting this requirement within the contract. The Board did provide the prevailing wage requirements within the contracts. Going forward when federal funds are utilitized for construction...
The Board acknowledges its lack of compliance relative to contractor and subcontractor payroll monitoring and omitting this requirement within the contract. The Board did provide the prevailing wage requirements within the contracts. Going forward when federal funds are utilitized for construction projects, management will reference the Code of Federal Regulations and relevant compliance supplements and cross-cutting supplements for expenditures of federal awards.
Case Managers will ensure all documents are scanned and retained for the Authority’s files prior to destroying them.
Case Managers will ensure all documents are scanned and retained for the Authority’s files prior to destroying them.
Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department...
Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. The School Corporation did not include Davis Bacon wage rate requirements in its contract with vendor which includes labor installation. The School Corporation did not obtain the weekly payroll reports certifications from vendor installing equipment. Context: The School Corporation had three projects during the audit period which included construction or labor installation which were charged to the ESSER III (84.425U) grant award. For one of two vendors selected for testing, the School Corporation did not include federal wage rate requirement clauses in the contract with the vendor and did not have an internal control designed to collect the weekly payroll reports certifications from vendors and its subcontractors, as applicable, to comply with Davis Bacon wage rate requirements. The amount disbursed for the project totaled $50,000. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will ensure all construction projects anticipated to incur labor costs greater than $2,000 include a signed contract containing a Davis-Bacon wage rate provision and will monitor the vendor to ensure compliance with certified payroll reporting requirements. Responsible Party and Timeline for Completion: David Wolford and Wyatt Schmicker will review wage rate provisions with vendors before initiating contracts when using federal funds.
The Financial Aid department will continue to review and update the reporting procedures. The Director of Financial Aid will review the origination and posting of loans with staff and train them to ensure that dates are consistent and in compliance with Title IV regulations.
The Financial Aid department will continue to review and update the reporting procedures. The Director of Financial Aid will review the origination and posting of loans with staff and train them to ensure that dates are consistent and in compliance with Title IV regulations.
The departments involved in the enrollment reporting process are continuing to review and enhance the workflow in order to report accurately. Monthly submissions by Information Technology Systems (ITS) will be completed in a timely manner to allow for prompt communication of corrections that are req...
The departments involved in the enrollment reporting process are continuing to review and enhance the workflow in order to report accurately. Monthly submissions by Information Technology Systems (ITS) will be completed in a timely manner to allow for prompt communication of corrections that are required, which are communicated to Admissions and Records by the National Student Clearinghouse (NSCH). Admissions and Records will ensure that error reports provided by NSCH are returned to NSCH within 10 business days to allow for a timely submission to the National Student Loan Database (NSLDS). Staff in Admissions and Records has been specifically assigned to complete error reports to contribute to a prompt submission. The Admissions and Records department will collaborate and communicate with the Financial Aid department to identify students with error codes in NSLDS in an effort to correct them. The Admissions and Records and Financial Aid departments will work with the Internal Auditor to perform semiannual reviews of NSLDS data to ensure accuracy of student records.
Management's Response: The College will strengthen its policies and procedures surrounding payroll grant disbursements to ensure expenses are properly approved and allowable under the specific grant budget. Management will ensure that budgets are amended when changes in pay rates occur during the ...
Management's Response: The College will strengthen its policies and procedures surrounding payroll grant disbursements to ensure expenses are properly approved and allowable under the specific grant budget. Management will ensure that budgets are amended when changes in pay rates occur during the grant award periods. Anticipated Completion Date: February 28, 2025
View Audit 340025 Questioned Costs: $1
Management's Response: The College will strengthen its policies and procedures surrounding non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations supported. Management will review budgets on a monthly basis to ensure expenses do not exceed the budget. M...
Management's Response: The College will strengthen its policies and procedures surrounding non-payroll grant disbursements to ensure disbursements are approved, allowable, and calculations supported. Management will review budgets on a monthly basis to ensure expenses do not exceed the budget. Management will review indirect cost calculations to ensure they are calculated at the correct percentages. Management will review invoices three months past year end to ensure the proper accrual of expenses. Anticipated Completion Date: February 28, 2025
View Audit 340025 Questioned Costs: $1
Finding 520287 (2024-001)
Significant Deficiency 2024
Condition: The University does not have controls in place for review of Return of Title IV calculation. Planned Corrective Action: All R2T4 calculations will be reviewed by a second individual within the Calvin Financial Aid Office. Calculations will not become final until both individuals agree wit...
Condition: The University does not have controls in place for review of Return of Title IV calculation. Planned Corrective Action: All R2T4 calculations will be reviewed by a second individual within the Calvin Financial Aid Office. Calculations will not become final until both individuals agree with the specifics of each calculation. Contact person responsible for corrective action: James Koeman, Director of Financial Aid Anticipated Completion Date: Already completed as of the 24FA term.
Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($347,59...
Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($347,591 and $337,851 respectively) did not agree to the underlying expenditure records ($135,355 and $159,811 respectively). Additionally, we noted that the ESSER II amount reported on the Year 4 report ($233,093) did not agree to the underlying expenditure records ($267,310) of the School Corporation. Contact Person Responsible for Corrective Action: Vicki Jones Contact Phone Number: 765-793-4877 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Annual report data will be submitted with the requested information and will be verified with a sign-off by the Superintendent. Anticipated Completion Date: July 2025
Finding 2024-001 – Child Nutrition Cluster – Eligibility Context: During sample testing of 60 students for eligibility, we noted 7 instances where there was no documented review by someone other than the individual making the eligibility determination. The lack of review was isolated to paper appl...
Finding 2024-001 – Child Nutrition Cluster – Eligibility Context: During sample testing of 60 students for eligibility, we noted 7 instances where there was no documented review by someone other than the individual making the eligibility determination. The lack of review was isolated to paper applications. Contact Person Responsible for Corrective Action: Mr. Patrick Culp Contact Phone Number: 219-279-2418 Views of Responsible Official: We concur with the finding. Of note, this is a new finding as we have never experienced this problem before. For this audit period, the Tri-County Food Service Director suffered a serious foot injury, requiring her to miss an extended period of time. When the accident with the Food Service Director occurred, one of the first actions the corporation took was to contact IDOE about our situation. The IDOE was aware how the review the process would look during that time. While the Food Service Director was recovering, student eligibility was not reviewed properly. Description of Corrective Action Plan: The Tri-County School Corporation food service director will complete all initial reviews of student eligibility. The initial review will be for both electronic and paper applications. Once the initial review is complete, the Tri-County central office secretary will complete a second review. The secretary works in a different building and does not have a role in eligibility determinations. Anticipated Completion Date: Our corrective action plan began in August 2024, upon the return of our food service director, and this is the plan moving forward.
Finding 2024-002: Reporting – Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Corrective Action Planned: The District agrees with the findings and management has implemented a corrective action plan to ensure the required reports are filed timely. Starting Ja...
Finding 2024-002: Reporting – Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Corrective Action Planned: The District agrees with the findings and management has implemented a corrective action plan to ensure the required reports are filed timely. Starting January 2024, all financial reports were filed on time. Person Responsible for Corrective Action: Anh Nguyen, Controller Anticipated Completion Date: June 30, 2025
We have reviewed the control procedures around preparation and review of the schedule of expenditures of federal awards (SEFA) and implemented an independent review of the assistance listing numbers (ALN} per the grant agreements in the initial review of the SEFA. The improved procedures will provid...
We have reviewed the control procedures around preparation and review of the schedule of expenditures of federal awards (SEFA) and implemented an independent review of the assistance listing numbers (ALN} per the grant agreements in the initial review of the SEFA. The improved procedures will provide the needed structure to fulfill management's responsibility to accurately report the grantor agency/ pass-through grantor, assistance listing number, federal program name and number, and expenditures. Identification of major programs, utilizing the guidelines in the Office of Management and Budget's (0MB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance} are the responsibility of the auditor.
Management acknowledges that there was an error with one over award of subsidized loan on a student. Student was given $448 (gross) over the aggregate subsidized limit. The overage was sent back to the Direct lender. Since the student graduated, the $448 was covered by a grant. A survey of all stude...
Management acknowledges that there was an error with one over award of subsidized loan on a student. Student was given $448 (gross) over the aggregate subsidized limit. The overage was sent back to the Direct lender. Since the student graduated, the $448 was covered by a grant. A survey of all students was completed and no other students were discovered to have been over their aggregate subsidized limit. • A student’s aggregate subsidized amount on NSLDS from his FAFSA record was listed at $17,948, allowing only $5,052 in remaining to reach the $23,000 aggregate limit on subsidized loan. Student was given $5,500 when it should have been $5,052. The $448 should have been given as unsubsidized loan. Student had previous loans from another school. (Powerfaids will catch this error if all of the historic loans were processed within our database.) • The student ISIR record did have Comment code 258: “Based upon data provided by the National Student Loan Data System (NSLDS) and your grade level, we have determined that you may have received a total amount of undergraduate student loans that is close to or equal to the loan limits established for the federal loan programs. Therefore, your eligibility for additional student loans may be limited.“ • The Federal processor usually sends a post-screening after federal aid is disbursed with warnings of limits: 255, 256, 258. 260 ad 261. This would cause a C-code on the student record. We did not receive a subsequent ISIR record on said student. Corrective Action Plan: Include in the Quality Assurance rules one for the ISIR codes associated with NSLDS overawarding of loans whether it be annual limits or aggregate limits. We will monitor these codes regularly during packaging season and subsequent to loan disbursing.
January 16, 2025 U.S. Department of Education 400 Maryland Ave SW Washington, DC 20212 Transylvania University respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Blue & Company, LLC 250 West Main Str...
January 16, 2025 U.S. Department of Education 400 Maryland Ave SW Washington, DC 20212 Transylvania University respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Blue & Company, LLC 250 West Main Street, Suite 2900 Lexington, Kentucky 40507 The findings from the schedule of findings and questioned costs (the Schedule) for the year ended June 30, 2024 are discussed below and are numbered consistently with the numbers assigned in the Schedule. Identifying Number: 2024-001 Finding: Enrollment Reporting. The enrollment status for students who completed their graduation requirements in May 2024 was incorrect for more than 30 days. Corrective Actions Taken or Planned: This issue occurred because enrollment and degree verify files sent to the National Student Clearinghouse (NSC) at the end of a term were processed in a particular order and student enrollment data overwrote student graduated status data. To correct the impacted students, the university registrar requested that NSC reprocess the May 2024 degree verify file, which should have been processed last. To prevent a future recurrence, the registrar has modified the file upload schedule to reflect the correct order of processing and has updated office procedures to clarify that the degree verify file should be uploaded last, following the submission of all term enrollment data. In addition to altering the file submission schedule, the registrar will ensure the end-of-term enrollment file has been processed by the NSC before the Degree Verify file is submitted each term. January 16, 2025 U.S. Department of Education 400 Maryland Ave SW Washington, DC 20212 Estimated Completion Date: November 11, 2024 Responsible Personnel: Michelle Robinson, Registrar If you have any questions or would like any additional information regarding these matters, please let us know and we will be happy to provide. Sincerely, Lisa Custardo, CPA Chief Financial Officer
The Housing Choice Voucher Program administrator will review the HQS Inspection report upon receiving to ensure all units are following Federal requirements.
The Housing Choice Voucher Program administrator will review the HQS Inspection report upon receiving to ensure all units are following Federal requirements.
Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2024 Corrective Action Plan: The R2T4 calculations were done in a timely manner. These errors were due to human error and is considered isolated in...
Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2024 Corrective Action Plan: The R2T4 calculations were done in a timely manner. These errors were due to human error and is considered isolated incidents. The Financial Aid office has taken great steps over the years and improved the processes for identifying and processing R2T4 calculations in a timely manner. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2024. Contact Person Scott Jewell, Director of Financial Aid
View Audit 339156 Questioned Costs: $1
The University recognizes the importance of complying with all federal requirements. In this case out of the sample of students one student was reported late to NSLDS. During the processing of a student's academic status, there was a unique situation where the student's record remained active in our...
The University recognizes the importance of complying with all federal requirements. In this case out of the sample of students one student was reported late to NSLDS. During the processing of a student's academic status, there was a unique situation where the student's record remained active in our system due to the presence of an incomplete grade. In this case, because the incomplete grade delayed the finalization of the student’s academic status, the dismissal was not reported to NSLDS within the typical timeframe. Once the incomplete was resolved and the final status was updated, the necessary information was reported to NSLDS. Measures will be put in place to ensure all changes are processed timely, additional measures are as follows.  Adding the following language to the Graduate catalog, consistent with the Undergraduate catalog: Students with one or more Incomplete grades at the end of the term have an academic standing of On Hold until the Incomplete grade(s) is resolved. When all Incomplete grades are converted to letter grades, the term and cumulative GPA are recalculated and academic standing is set according to the Standards of Academic Progress.  Before any dismissal decision is finalized, the Registrar’s Office verifies that all incomplete grades for the student have been resolved and that final grades are recorded in the system. This verification ensures that no student is dismissed prematurely or inaccurately in the academic records. Implement a workflow process as a double check in the student information system that monitors the status of incomplete grades for students who are dismissed, the system will generate alerts to the Registrar’s office when an incomplete grade is pending resolution in conjunction with dismissal.  Implementing controls to ensure accurate grading in conjunction with dismissals in the Student Information System will enable precise reporting to NSC/NSLDS
Condition: The Organization lacked sufficient controls to ensure consistent reviews/approvals of monthly reimbursement requests and tenant rent calculations throughout the year. Planned Corrective Action: - The Rent Analyst will complete the rent calculations and sign off. - The Director of Account...
Condition: The Organization lacked sufficient controls to ensure consistent reviews/approvals of monthly reimbursement requests and tenant rent calculations throughout the year. Planned Corrective Action: - The Rent Analyst will complete the rent calculations and sign off. - The Director of Accounting will review and approve the checklist in writing. Contact person responsible for corrective action: The Director of Accounting will oversee all rent calculations. Anticipated Completion Date: Effective 01-13-2025.
FINDING 2024-001 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23,...
FINDING 2024-001 Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY 22-23, FY 23-24 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will formally sign off on the Mosaic income guidelines annually prior to each school year. Responsible Party and Timeline for Completion: Shane Hacker, Assistant Superintendent of Operations; Corey Ebert, Director of Finance; Jordan Ryan, Director of Nutrition Services Anticipated Completion Date: February 1, 2025
Information on the Federal Program: U.S. Department of Education, Trio Cluster and Appalachian Regional Commission (ARC), Appalachian Area Development Assistance Listing No. 23.002 Criteria: 2 CFR 200 Subpart E establishes cost principles to apply in determining costs under federal awards. Nonfeder...
Information on the Federal Program: U.S. Department of Education, Trio Cluster and Appalachian Regional Commission (ARC), Appalachian Area Development Assistance Listing No. 23.002 Criteria: 2 CFR 200 Subpart E establishes cost principles to apply in determining costs under federal awards. Nonfederal entities are also required to establish controls over the disbursement process to ensure compliance with allowable cost requirements. Condition: We selected a Trio sample of 25 payroll charges, containing 56 employee paychecks. Of those 56, five employee's approved pay was not properly documented. The employee had additional pay not on the approved Letter of Appointment (LOA) or the LOA reflected the use of restricted dollars, but the pay was charged to the grant. In addition, of those 56, five employees were charged to a grant that they were not budgeted for. We selected an ARC sample of 10 nonpayroll disbursements to test for controls. Of those 10, one disbursement of four scholarships was not properly documented as approved for payment. Management’s Response: The College will strengthen its policies and procedures surrounding the disbursement process. The College will document approvals on all payroll changes at the college and on the grant budgets. All scholarships will have prior written approval before scholarships will be applied. The College will also amend all grants when needed to properly reflect all job titles and expenditure items. Anticipated Completion Date: February 28, 2025
View Audit 339006 Questioned Costs: $1
Corrective Action Plan (CAP) Name of auditee: A.C. Ware Housing Development Fund Company, Inc. TIN: 014-EE181 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2024 CAP prepared by: Andrea D. Mays President ADM Management Group, Inc. (716) 892-1799 Current Findings on...
Corrective Action Plan (CAP) Name of auditee: A.C. Ware Housing Development Fund Company, Inc. TIN: 014-EE181 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: September 30, 2024 CAP prepared by: Andrea D. Mays President ADM Management Group, Inc. (716) 892-1799 Current Findings on the Schedule of Findings and Questioned Costs and Recommendations (1) Finding 2024-001 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation. Please see below for action taken. (b) Action taken: Management is in the process of depositing funds, however, it currently does not have enough operating funds to deposit the underfunded amount of $16,785 into the reserve for replacements account. Management is in process of requesting a rent increase from HUD and will deposit funds as they become available.
There is no disagreement with the finding. The program length will be corrected for all students. In response to the findings from 2023, North Central corrected all program lengths within our Enterprise Resource Planning (ERP) system, Ellucian’s Colleague. Throughout the academic year, the Registrar...
There is no disagreement with the finding. The program length will be corrected for all students. In response to the findings from 2023, North Central corrected all program lengths within our Enterprise Resource Planning (ERP) system, Ellucian’s Colleague. Throughout the academic year, the Registrar’s Office and Financial Aid Department conducted thorough quality checks of the source data to ensure accuracy. Despite these efforts, unforeseen errors in enrollment data arose due to a data conversion issue between Colleague and the National Student Clearinghouse, which transmits information to the National Student Loan Data System (NSLDS). To address this, we will maintain our semesterly data confirmation process but will shift the primary focus of our reviews to the output data transmitted to NSLDS, ensuring data integrity at every stage of reporting.
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