Corrective Action Plans

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Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing co...
Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the School will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the School has received an executed copy of the form. Upon notification of construction commencement, the School will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.
Reference Number: 2024-002 Finding: Other Instance of Noncompliance and Deficiency Status: In-progress Corrective Action: The University did not complete a Return to Title IV refund calculation within 45 days after a student had withdrawn from UST. The Assistant Director of Financial Aid ru...
Reference Number: 2024-002 Finding: Other Instance of Noncompliance and Deficiency Status: In-progress Corrective Action: The University did not complete a Return to Title IV refund calculation within 45 days after a student had withdrawn from UST. The Assistant Director of Financial Aid runs a query once a month to find students who have received Title IV or state aid and have withdrawn. The student in question did not appear on the query when we believe they should have, but was on the subsequent report. We have changed our procedures to run the query and complete Return to Title IV calculations weekly, rather than monthly. We believe this will help us find any discrepancies more quickly. We also reviewed the query and made some edits to attempt to increase accuracy. Person(s) Responsible for Implementing: Lynda McKendree, Dean of Scholarships and Financial Aid and Thuylieu Aligo, Assistant Director of Scholarships and Financial Aid Implementation Date: 09/01/2024
Reference Number: 2024-001 Finding: Other Instance of Noncompliance and Significant Deficiency Status: In-progress Corrective Action: Following our analysis, we have concluded that adjusting our data transmission schedule to NSC will help prevent future last minute data anomalies, ensuring that...
Reference Number: 2024-001 Finding: Other Instance of Noncompliance and Significant Deficiency Status: In-progress Corrective Action: Following our analysis, we have concluded that adjusting our data transmission schedule to NSC will help prevent future last minute data anomalies, ensuring that a final transmission for the term always occurs after the end date of each term. Additionally, we have identified a potential issue where NSC may fail to send graduate records to NSLDS for students who immediately re-enroll in the subsequent semester. Due to timing between the submission from NSC to NSLDS, the newer enrollment appears to be overriding the previously sent graduation record, preventing the graduation record from being sent to NSLDS. To address this, we will create a dedicated report to identify students in this situation and manually update NSLDS with the missed graduation data. Finally, there were isolated cases where a historical date adjustment was made to generate an auxiliary outcome (e.g., a grade change of Withdrawal instead of Withdrawal Failing), which made it appear as though a record change wasn't submitted in a timely manner. For these, we will discontinue this practice and employ an alternative method to derive the desired outcome (e.g., additional grade change transactions input after the withdrawal with no date adjustment). Person(s) Responsible for Implementing: Mike Acosta, Institutional Analyst, Nathan Dugat, Registrar, Lynda McKendree, Dean of Scholarships and Financial Aid Implementation Date: 11/01/2024
Finding Number: 2024-002 – Approval of Payroll Expense Transactions Corrective Action Plan: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be ...
Finding Number: 2024-002 – Approval of Payroll Expense Transactions Corrective Action Plan: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted until proper approval is received. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2025
Finding 2024-003 – Child Nutrition Cluster - Reporting Context: During the testing of claim reimbursements, we noted two monthly reimbursements in a sample of four claims where the number of meals claimed for reimbursement did not agree to underlying meal system reports. For one claim reimbursemen...
Finding 2024-003 – Child Nutrition Cluster - Reporting Context: During the testing of claim reimbursements, we noted two monthly reimbursements in a sample of four claims where the number of meals claimed for reimbursement did not agree to underlying meal system reports. For one claim reimbursement, there was an overstatement of $9,976 and on another an understatement of $1,467. This resulted in a net over reimbursement $8,509 in the testing sample. Contact Person Responsible for Corrective Action: Leslie Beach, Director of Food Services Contact Phone Number: 812-542-2245 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A new person has been hired in this position. A manager will review claim reimbursements. Anticipated Completion Date: Immediate correction.
View Audit 336751 Questioned Costs: $1
Finding 2024-001 – Child Nutrition Cluster – Eligibility 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 ...
Finding 2024-001 – Child Nutrition Cluster – Eligibility 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. Contact Person Responsible for Corrective Action: Leslie Beach, Director of Food Services Contact Phone Number: 812-542-2245 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A manager will review eligibility determination and guidelines moving forward. Anticipated Completion Date: Immediate correction.
Recommendation: We recommend that the District implements a process that will ensure all Title IV funds are awarded at proper amounts. Action taken in response to finding: Student’s award was adjusted to appropriately match the EFC of a subsequent ISIR that had not been processed at the time of awa...
Recommendation: We recommend that the District implements a process that will ensure all Title IV funds are awarded at proper amounts. Action taken in response to finding: Student’s award was adjusted to appropriately match the EFC of a subsequent ISIR that had not been processed at the time of awarding. Evidence of that change was provided to auditors in July 2024. Refresher training was provided to analysts to improve monitoring the output files of the ISIR import process (RCRTPxx) that identifies subsequent ISIRs received for students with locked records. Names of the contact persons responsible for corrective action: Patrick Scott and Anna Marie Troupe Planned completion date for corrective action plan: July 2024
View Audit 336749 Questioned Costs: $1
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: As this is a multi-year finding, the Financial Aid department and the Business Services department ha...
Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: As this is a multi-year finding, the Financial Aid department and the Business Services department have been working closely this term to develop a coordinated approach to avoid the issue going forward. Our procedures have been changed drastically. Once a student appears on a timeout / stale-dated check report from the vendor responsible for delivering aid to our students, we are reversing the funds and processing that reversal through COD first, then reaching out to the student to see if they need to make arrangements for correcting their address. This was done in the opposite fashion in prior years, and while it reduced delays for students who could rectify things, it carried too much risk of being forgotten and the 240 day mark being surpassed. The financial aid department has committed to placing the reversals and processing them through COD within seven business days of receiving the notification from the vendor and/or Business Services. This is far stricter than the federal regulations, but a seemingly necessary step to ensure compliance. Additionally, the Business Services team is aware of the impossibility of delivering aid beyond 240 days of the original check issuance and is helping the financial aid team to understand issuance dates in situations where Title IV aids may be commingled with other financial aid across multiple disbursement attempts. This coordination will ensure the District’s compliance going forward. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid, Shannon Beckham –Director of Business Services Planned completion date for corrective action plan: December 2024
View Audit 336749 Questioned Costs: $1
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria. Action taken i...
Recommendation: We recognize the District made corrective action after the June 30, 2023 audit and implemented those controls during the Fall 2023 semester. We recommend the District continue to follow those controls put in place to ensure compliance with the aforementioned criteria. Action taken in response to finding: The District reviewed its enrollment reporting procedures and ensured that information—especially the effective date of status changes—is accurately reported to NSLDS as required by regulations. Name of the contact persons responsible for corrective action: Alysa Borelli, Dean—Enrollment Services, and Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: These corrections were already put into place during Fall 2023 when the issue was discovered in the FY 2023 audit.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: As this finding has occurred in multiple years, it is one of the financial aid team’s top priorities. Return to Ti...
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: As this finding has occurred in multiple years, it is one of the financial aid team’s top priorities. Return to Title IV calculations are complex operations—especially in the California Community College system where multiple Pell awards per term and high withdrawal rates are common—that require time and focus. This year’s batch of calculations were problematic due for several reasons: • Human error • Insufficient number of staff capable of reliably performing calculations • Failure to retain students who have received financial aid beyond the 60% mark of the term • A typographical error in the college’s end date for Fall 2023 required us to re-calculate all Return to Title IV calculations, making each of those calculations a technical violation of Title IV regulations since they were done outside the limited time window We have taken the following actions: • Increased the number of people in the department who are capable of performing calculations • Provided support for two staff members to obtain their NASFAA certification in Return to Title IV funds calculations • Requested out-of-class status to remunerate one of our student services assistants who obtained that certification so that they can be involved in these calculations going forward • Emphasized the importance of timely calculations in staff meetings and evaluations • Altered our procedures to include deliberate consideration of dates involved to better control the timeliness of both calculations and returning funds to the Title IV programs. • Added a step to the new aid year setup that verifies that the term start, and end dates entered in the Banner® system are correct. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Anna Marie Troupe, Financial Aid Supervisor Planned completion date for corrective action plan: January 2025
Finding 518362 (2024-001)
Significant Deficiency 2024
2024‐001 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Name of Contact Perso...
2024‐001 Significant Deficiency: Return to Title IV Funds (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268; Federal Pell Grant Program, ALN #84.063; Federal Supplemental Opportunity Grant Program, ALN #84.007; and TEACH Grant Program, ALN #84.379) Name of Contact Person The Director of Financial Aid, Christin Mustard, is responsible for the corrective action plan for this finding. Corrective Action Plan We agree with this finding. After review of this student’s Return to Title IV calculation, it was determined that upon beginning the calculation in the PowerFAIDS system, the Refresh button was not used which would have recalculated the completed days to include the 9-day Spring Break. After reviewing this procedure with PowerFAIDS, it was recommended that we also enter the withdrawal date on the R2T4 tab of the POE screen which forces the system to recalculate the completed days prior to beginning the R2T4 calculation. We have added this step to our Return to Title IV procedures. Anticipated Completion Date The corrected Return to Title IV calculation was completed, which resulted in an Unsubsidized loan return of $1,029. The loan funds were returned via the Common Origination and Disbursement (COD) system.
View Audit 336746 Questioned Costs: $1
2024-005: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Upon investigation, we discovered that even though Casper College is reporting our enrollment to the National Student Clearinghouse (NSC) in a timely fashion, t...
2024-005: Student Financial Audit Cluster - Special Tests and Provisions: Enrollment Reporting (Significant Deficiency) Corrective Action: Upon investigation, we discovered that even though Casper College is reporting our enrollment to the National Student Clearinghouse (NSC) in a timely fashion, those reports are not always being sent to the National Student Loan Data System (NSLDS) swiftly. We understand that NSC is a third-party servicer and ultimately, the institution is responsible for ensuring NSLDS is being updated properly. As a failsafe, Casper College has developed an internal audit procedure to manually update students in NSLDS to be in compliance with CFR 690.83. Anticipated Completion Date: 9/18/2024 Contact Person: Laurie Johnstone
2024-004: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to or on Behalf of Students (Significant Deficiency) Corrective Action: Casper College’s award notifications have been updated to include when funds will be disbursed. In addition, the award notifications refere...
2024-004: Student Financial Audit Cluster - Special Tests and Provisions: Disbursements to or on Behalf of Students (Significant Deficiency) Corrective Action: Casper College’s award notifications have been updated to include when funds will be disbursed. In addition, the award notifications reference the Important Dates URL on the Casper College website for parents and students to refer to that include award disbursement dates. Anticipated Completion Date: 9/6/2024 Contact Person: Laurie Johnstone
Finding 518106 (2024-007)
Material Weakness 2024
Internal controls will be created to ensure that the Quarterly Compliance Reports agree to internal supporting documents and that reports will be submitted timely.
Internal controls will be created to ensure that the Quarterly Compliance Reports agree to internal supporting documents and that reports will be submitted timely.
Finding 518087 (2024-006)
Significant Deficiency 2024
Internal controls will be created for reviewing the determination of eligibility for participation in the Emergency Rental Assistance Program.
Internal controls will be created for reviewing the determination of eligibility for participation in the Emergency Rental Assistance Program.
Finding 2024-002 - Significant Deficiency: Enrollment Reporting Condition For 1 of 17 students tested, the student’s status was reported incorrectly to the National Student Loan Data System (NSLDS). The student graduated however was reported to NSLDS as withdrawn. The student’s status was also repor...
Finding 2024-002 - Significant Deficiency: Enrollment Reporting Condition For 1 of 17 students tested, the student’s status was reported incorrectly to the National Student Loan Data System (NSLDS). The student graduated however was reported to NSLDS as withdrawn. The student’s status was also reported late, after 60 days. In addition, another student’s status was also reported late. The sample was not a statistically valid sample. Corrective Action Plan The school agrees with the finding. While the withdrawn status was reported for this specific student, the follow-up graduated status was not. This student completed the graduation requirements much later. The school has implemented improved communication between registrar and financial aid to be sure these later graduations are reported. In addition, the timeframe for sending monthly enrollment reports through the National Student Clearinghouse will be altered to improve timely reporting of all statuses. The late statuses were by only a few days and should be resolved by adjusting this timeline. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeff Aalbers Anticipated Completion Date: January 31, 2025
Finding 2024-001 - Eligibility Condition For 1 out of 7 students tested, the school disbursed a loan to a student that had a Perkins student loan in default and there was no support documenting that the student was not in default at the time of the disbursement. The sample was not a statistically va...
Finding 2024-001 - Eligibility Condition For 1 out of 7 students tested, the school disbursed a loan to a student that had a Perkins student loan in default and there was no support documenting that the student was not in default at the time of the disbursement. The sample was not a statistically valid sample. Corrective Action Plan The school agrees with the finding. Procedures have been updated to ensure all verification and c-code reviews are conducted prior to disbursing of any Title IV aid. This would include maintaining documentation of clearance that is recent and up-to-date in the student’s permanent online folder. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeff Aalbers Anticipated Completion Date: January 31, 2025
View Audit 336383 Questioned Costs: $1
Finding 2024-001: Time and Effort Requirements (50000) Assistance Listing No. 84.010 - Title I, Part A Assistance Listing No. 84.425 - Education Stabilization Funds (ESSER) U.S. Department of Education Passed through California Department of Education Response to finding 2024-001: Time and effort r...
Finding 2024-001: Time and Effort Requirements (50000) Assistance Listing No. 84.010 - Title I, Part A Assistance Listing No. 84.425 - Education Stabilization Funds (ESSER) U.S. Department of Education Passed through California Department of Education Response to finding 2024-001: Time and effort requirements Controller Marisol Esparza has developed a process that includes completing corrections by January 31, 2025, and receiving all future forms promptly. Managers of each employee group have been notified of the importance of completing the time and effort requirements. Managers, with the support of the administrative/department secretaries, are now tasked with monitoring, reconciling, and ensu ing that these documents are completed and submitted monthly.
Non-Compliance with Monthly Direct Loan Reconciliations Management agrees with the finding and the auditor's recommendation. Mass General Brigham (MGB) will update existing procedures to include a formal monthly Direct Loan reconciliation with applicable supporting documentation. This will be implem...
Non-Compliance with Monthly Direct Loan Reconciliations Management agrees with the finding and the auditor's recommendation. Mass General Brigham (MGB) will update existing procedures to include a formal monthly Direct Loan reconciliation with applicable supporting documentation. This will be implemented February 2025 for the period beginning January 2025. Updates will be prepared by the Director of Student Financial Aid and the Director of Finance for review and approval by the Controller's Office prior to implementation.
Auditee Response and Corrective Action Plan: a) Implementing a new process for adding the sliding fee discount to patient accounts. Each patient that applies for the slide will be scheduled under “eligibility” with an appointment. After the patient has completed the application, the information will...
Auditee Response and Corrective Action Plan: a) Implementing a new process for adding the sliding fee discount to patient accounts. Each patient that applies for the slide will be scheduled under “eligibility” with an appointment. After the patient has completed the application, the information will be entered into Athena, and then the plan will be calculated. The paperwork will then be uploaded as an attachment to the Sliding Fee Discount Policy. Each week, a report will be generated in Athena and sent to the Clinical Services Manager. This report will list all patients that had an appointment with eligibility for the prior week. The Clinical Services Manager will then use that report and verify that all information is uploaded and entered correctly. b) Training on the new process will occur. All support staff responsible for entering and uploading the Sliding Fee Discount will go through thorough training of the new process. Additionally, the Clinical Services Manager will complete peer‐to‐peer training on the verification process.
Recommendations: The District should put controls into place that will require contractors, performing contract work greater than $2,000 and paid with federal monies, to submit the required payroll reports, per the Wage Rate Requirements, throughout the contract work. Action Taken: We agree with th...
Recommendations: The District should put controls into place that will require contractors, performing contract work greater than $2,000 and paid with federal monies, to submit the required payroll reports, per the Wage Rate Requirements, throughout the contract work. Action Taken: We agree with the recommendation. Our targeted implementation date is December 2024.
2024-001 – Student Financial Assistance Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education ...
2024-001 – Student Financial Assistance Cluster – (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education Grants, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 – Year Ended June 30, 2024 Criteria: Institutions shall develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts and contains administrative, technical, and physical safeguards that are appropriate to your size and complexity, the nature and scope of your activities, and the sensitivity of any customer information at issue. The information security program shall include the elements set forth in § 314.4 and shall be reasonably designed to achieve the objectives of this part, as set forth in the objectives of section 501(b) of the Act (16 CFR 314.3(a)). Base your information security program on a risk assessment that identifies reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of such information, and assesses the sufficiency of any safeguards in place to control these risks (16 CFR 314.4(b)). Condition: The College did not implement a written information security program and a risk assessment as part of the Gramm-Leach-Bliley Act’s (GLBA) standards for safeguarding customer information. We consider this finding to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Corrective Action Plan: We are currently working with our IT vendors (CampusWorks and Lockstep) on policies and increasing GLBA compliance. Responsible Person for Corrective Action Plan: Holly Tharp, Vice President for Finance and Business Implementation Date for Corrective Action Plan: June 30, 2025
FINDING No. 2024-003: Section 202 Supportive Housing for Elderly, ALN 14.157 Recommendation: The Project should comply with HUD regulations for timely renewal of the PRAC contract to ensu...
FINDING No. 2024-003: Section 202 Supportive Housing for Elderly, ALN 14.157 Recommendation: The Project should comply with HUD regulations for timely renewal of the PRAC contract to ensure no interruption in funding. Action Taken: New staff have been put in place to monitor and submit all renewals in a timely manner. If the Oversight Agency for Audit has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips CFO
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPN’s are retained for at least three years after payment in accordance with the federal regulation. Explanation of disa...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University implement a procedure moving forward to ensure that all necessary MPN’s are retained for at least three years after payment in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Item was in reference to Perkins Loans that were assigned to ED. While the University does not disagree with the fact that three MPN’s were unavailable, each were old Perkins Loans, and each were successfully assigned to ED utilizing alternative documentation, as suggested by ED. The University has a current process in place to retain all information in student files for a minimum of three years. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: 06/30/2025
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: T...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This process is being reviewed with the Registrar’s Office, as they complete enrollment reporting through the Clearinghouse. The University has found that some delays are happening due to the lack of federal aid at the initial time. For example, one student started in Fall 2023 and the University has documentation to reflect the student was reported to Clearinghouse within the required timeframe. However, the student had not completed Entrance Counseling or a Master Promissory Note, thus they had not received Title IV aid and were not included in the request file from NSLDS to the Clearinghouse. The University will continue to review and make appropriate changes to the current process. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: 06/30/2025
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