Corrective Action Plans

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Office of Mental Health (OMH) acknowledges that there was an oversight in payments being passed through to a single subrecipient without an executed contract. This single event occurred during the Statewide transition from Grants Gateway to the Grants Management Module of the Statewide Financial Sys...
Office of Mental Health (OMH) acknowledges that there was an oversight in payments being passed through to a single subrecipient without an executed contract. This single event occurred during the Statewide transition from Grants Gateway to the Grants Management Module of the Statewide Financial System (SFS). The data transfer when the system switch occurred was not 100% accurate. The contract in question was incorrectly read and transmitted the contract to the new grants management module in SFS as executed. OMH is currently working on a contract amendment to support this payment which will be submitted for approval and signature by all required parties. The business owners of the SFS were informed of the error and it is OMH’s understanding that the issue has been addressed in SFS.
View Audit 334898 Questioned Costs: $1
The Office of Mental Health (OMH) agrees with this recommendation. While OMH ensures that the source data is maintained and has updated internal procedures accordingly, a formalized policy and procedure will be implemented in SFY 2024-25.
The Office of Mental Health (OMH) agrees with this recommendation. While OMH ensures that the source data is maintained and has updated internal procedures accordingly, a formalized policy and procedure will be implemented in SFY 2024-25.
The Office of Temporary and Disability Assistance (OTDA) and the State will review, develop, and enhance the subrecipient monitoring policies and procedure, which include monitoring procedures over local districts. These policies and procedures would include verification of the source of the local d...
The Office of Temporary and Disability Assistance (OTDA) and the State will review, develop, and enhance the subrecipient monitoring policies and procedure, which include monitoring procedures over local districts. These policies and procedures would include verification of the source of the local district’s cost sharing or match to determine that the source is appropriate and in accordance with 45 CFR 75.306(b).
View Audit 334898 Questioned Costs: $1
New York State Education Department’s Adult Career and Continuing Education Services-Vocational Rehabilitation (ACCES-VR) will update RSA 911 Reporting Data Validation policies and procedures. This updated policy and procedure will address the input of information provided through supporting documen...
New York State Education Department’s Adult Career and Continuing Education Services-Vocational Rehabilitation (ACCES-VR) will update RSA 911 Reporting Data Validation policies and procedures. This updated policy and procedure will address the input of information provided through supporting documentation, the storing of supporting documents and review protocols of the RSA 911 data elements.
New York State Education Department will update the payment processing procedures and provide training to staff involved in preparing or processing payment forms to understand the appropriate application of cost centers to align with the Period of Performance for Federal awards, including the VR gra...
New York State Education Department will update the payment processing procedures and provide training to staff involved in preparing or processing payment forms to understand the appropriate application of cost centers to align with the Period of Performance for Federal awards, including the VR grant. Additional controls will be explored to ensure that the accounting details on the payment form are accurate and entered correctly into the Statewide Financial System.
View Audit 334898 Questioned Costs: $1
Federal Awards Findings And Recommendations 2024-001 Special Tests and Provisions - Enrollment Reporting View of Responsible Officials and Corrective Action Plan The Financial Aid and Admissions and Records departments in collaboration with the district, contracted with an outside consultant to he...
Federal Awards Findings And Recommendations 2024-001 Special Tests and Provisions - Enrollment Reporting View of Responsible Officials and Corrective Action Plan The Financial Aid and Admissions and Records departments in collaboration with the district, contracted with an outside consultant to help identify why the enrollment reporting process was not accurately reporting students' enrollment levels. It was identified that a system setting was not set to capture chnage sof enrollment levels within the specific terms. Based on the consultant recommendation, the district agreed to update system settings to accurately report student enrollment level changes throughout the term. These adjustments to the system settings will allow for the accurate and timely reporting of information to the National Student Loan Database System (NSLDS). This ongoing change to system settings is in place beginning with the Fall 2024 term. Additionally, the district has implemented internal controls to include: Developed additional training and Information Technology support structures to maintain data integrity associated with the National Student Clearinghouse (NSC) data submission, Developed pre data submission audit report to check for accuracy prior to the upload of required data to the NSC, and Created an internal work group consisting of financial aid and admissions and records professionals to review information associated with NSC reports prior to the scheduled submission of requested information. Implementation Date September 2024
Action taken in response to finding: LCHC management has implemented a robust task-management software to assist with internal controls, especially when related to grant management. Furthermore, a cloud-hosted warehouse for internal procedures was implemented to properly manage the assignment and tr...
Action taken in response to finding: LCHC management has implemented a robust task-management software to assist with internal controls, especially when related to grant management. Furthermore, a cloud-hosted warehouse for internal procedures was implemented to properly manage the assignment and transfer of accounting roles/responsibilities like the review and approval of grant drawdown request. Name(s) of the contact person(s) responsible for corrective action: Jeff Nelson, Accounting and Financial Analysis Director Planned completion date for corrective action plan: 9/30/2024
Response to Finding 2024-002 Federal Award Agency: Department of the Treasury Name of Contact Person: Marat Saks, Chief Financial Officer Views of Responsible Officials: The housing authority’s property management company attempted to submit proposed 2023-2024 budgets and financial reports includi...
Response to Finding 2024-002 Federal Award Agency: Department of the Treasury Name of Contact Person: Marat Saks, Chief Financial Officer Views of Responsible Officials: The housing authority’s property management company attempted to submit proposed 2023-2024 budgets and financial reports including form RD 3560-7 within the proscribed timeframe but encountered technical issues relating utility allowances. After an initial attempt to remediate the technical issue with RD, the property management company failed to submit the proposed budget. Corrective Action: 1. The housing authority is in the process of transitioning to a new property management company which will have better technical resources to resolve similar issues. Furthermore, the housing authority will institute a checklist with the new property management company which will include submission of the annual proposed budget and financial reports which will be reviewed by the housing authority for compliance. Date of Planned Corrective Action: Immediately following being notified of this finding.
We will implement stricter adherence to deadlines and ensure that all required annual deposits to residual receipts are completed within 90 days of year end.
We will implement stricter adherence to deadlines and ensure that all required annual deposits to residual receipts are completed within 90 days of year end.
Auditor Description of Condition and Effect. During our testing we noted that there was not an independent review performed on journal entries related to their federal grant program. Without a review process, there is an increased risk of inaccurate financial reporting and potential noncompliance. A...
Auditor Description of Condition and Effect. During our testing we noted that there was not an independent review performed on journal entries related to their federal grant program. Without a review process, there is an increased risk of inaccurate financial reporting and potential noncompliance. Auditor Recommendation. We recommend that the Organization implement a formal review and approval process for all journal entries related to federal grant programs. Corrective Action. Management will implement an independent monthly review of all journal entries, including those related to the federal grant programs. The designated reviewer will be a senior accounting team member or equivalent who does not have the ability to create or approve journal entries in the general ledger system. The designated reviewer will compare the entries to ensure proper documentation, accurate amounts, correct coding, and compliance with the applicable federal grant regulations. Any discrepancies or issues identified during the review will be documented, and corrective actions will be taken immediately. The reviewer will sign off on the entries, confirming that all journal entries meet required standards. Responsible Person. Chris Sargent, President & Executive Officer Anticipated Completion Date. March 31, 2025
Auditor Description of Condition and Effect. During our single audit testing, it was determined that there was no process in place to verify that vendors with transactions in excess of $25,000 were not suspended or debarred. Certain vendors could be used that are considered suspended or debarred by ...
Auditor Description of Condition and Effect. During our single audit testing, it was determined that there was no process in place to verify that vendors with transactions in excess of $25,000 were not suspended or debarred. Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Auditor Recommendation. We recommend that the Organization review its policies over suspension and debarment review to ensure that they are contracting with allowable vendors. Corrective Action. For Federal grants, management will implement a system for verifying that all vendors or subrecipients with transactions exceeding $25,000 are not suspended or debarred by the federal government, ensuring full compliance with federal regulations and minimizing the risk of using prohibited vendors. A mandatory check against the System for Award Management (SAM) database for suspension and debarment status will occur, with a printout or screenshot of the results maintained. Responsible Person. Chris Sargent, President & Executive Officer Anticipated Completion Date. January 31, 2025
Finding 516521 (2024-001)
Significant Deficiency 2024
Finding 2024-001 Return to Title IV Condition While testing R2T4, the University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. RESPONSE: Husson University agrees with this finding. The financial aid office had staff turn-over that lead to new s...
Finding 2024-001 Return to Title IV Condition While testing R2T4, the University was unable to provide proof of a documented review for 2 of the 25 calculations selected for testing. RESPONSE: Husson University agrees with this finding. The financial aid office had staff turn-over that lead to new staff taking over this function. As part of the training, the staff who performed these calculations were under the impression that no secondary review was required for students who earned 100% of the awarded financial aid based on withdrawal after the 60% point of the payment period. CORRECTIVE ACTION: Husson reviewed all calculations completed after 60% point of the term for 2023-2024 to ensure they were accurate. Moving forward all R2T4 calculations are reviewed by a second individual. A staff training was completed to ensure that the financial aid staff understand that a second review is required for all R2T4 calculations completed to ensure the calculation is accurate regardless of the % of term completed. RESPONSIBLE PARTY: Sherry Watson, Director of Financial Aid COMPLETION DATE: July 2024
Responsible Individual: Joan Romano, Registrar Contact Information: jromano2@berklee.edu, 617-747-2475 Corrective Actions: Management concurs with the recommendations provided. The Registrar’s Office will implement a reconciliation of the Ellucian Colleague Enrollment Information and data provided t...
Responsible Individual: Joan Romano, Registrar Contact Information: jromano2@berklee.edu, 617-747-2475 Corrective Actions: Management concurs with the recommendations provided. The Registrar’s Office will implement a reconciliation of the Ellucian Colleague Enrollment Information and data provided to NSC (the National Student Clearinghouse). The reconciliations will be reviewed by Ari Kaufman, Associate Registrar, and confirmed by Joan Romano, Registrar before submission to ensure that it’s performed timely and accurately. Notifications or any discrepancies will be sent to NSC immediately informing them of any necessary corrections. Estimated Date of Completion: March 31, 2025 Status of Completion: In Process
Responsible Individual: Kathy Anderson, Associate Vice President, Student Financial Services Contact Information: kanderson8@berklee.edu, 617-747-6595 Management concurs with the recommendations provided. To remediate this issue, there are new personnel assigned to complete the process and ensure th...
Responsible Individual: Kathy Anderson, Associate Vice President, Student Financial Services Contact Information: kanderson8@berklee.edu, 617-747-6595 Management concurs with the recommendations provided. To remediate this issue, there are new personnel assigned to complete the process and ensure there are no gaps. The Director of Financial Aid Operations will ensure that the process is run as scheduled by the Assistant Director of Financial Aid Operations. In addition, there is an overflow schedule with the Operations team, if the primary or secondary Assistant Director assigned to this task will be out of the office on the day the report is run. Berklee has changed the date the notifications are sent to students. Berklee has changed the date the notifications are sent to the students. This ensures that notices are sent on day zero and the following week on day seven. This provides Berklee with a second chance to remediate student records that are not resolved on disbursement date zero. Lastly, we have built in additional controls to this process to include a thorough review of error logs so that any errors are resolved and notification sent within the required timeframe Management concurs with the recommendations provided. . Estimated Date of Completion: March 31, 2025 Status of Completion: In Process
Management agrees with the current year’s finding and recommendations to ensure timeliness of the Return of Title IV funds. Management has determined this to be an isolated incident because the Registrar dropped the student on May 9, 2024, following an investigation into the disparity between the st...
Management agrees with the current year’s finding and recommendations to ensure timeliness of the Return of Title IV funds. Management has determined this to be an isolated incident because the Registrar dropped the student on May 9, 2024, following an investigation into the disparity between the student’s self-reported last date of attendance, March 14, 2024, and the receipt of the form on April 15, 2024. Accordingly, May 9, 2024, became the institution’s determination date due to unknown last date of attendance from the faculty. Furthermore, the University offices were closed at 1pm on April 22, 2024, and closed entirely on April 23, 24, 29, 30. The investigation and University closures took the office outside the 45-day compliance requirement. The University plans to enhance the policy for LOA and Withdrawal forms to have the Last Date of Attendance removed as a student self-reported option. In the future, the determination date will be based on date of receipt of the form and not a student-reported, last date of attendance. We believe this finding will be remediated in fiscal 2025.
Finding 2024-001 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance Federal Grantor: United States Department of Homeland Security Assistance Listing No.: Assistance Listing 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disas...
Finding 2024-001 – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance Federal Grantor: United States Department of Homeland Security Assistance Listing No.: Assistance Listing 97.036, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Indiana Department of Homeland Security Federal Award Period of Performance: March 1, 2020 – May 11, 2023 A material weakness was identified related to internal controls over payroll expenses charged to FEMA funds, subject to the Uniform Guidance (UG) audit. This guidance requires internal controls to comply with the terms of the federal award as well as with the "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control—Integrated Framework" issued by COSO. The finding was a compliance matter and did not result in any questioned costs. Community Foundation of Northwest Indiana, Inc. and Subsidiaries (CFNI) acknowledges the finding related to the lack of documented review and approval of all timecards for payroll expenses charged to federally funded programs. In line with industry standards, CFNI prioritizes timely payroll processing and does not delay payroll for outstanding timecard approvals. While this is not a recurring issue and did not result in any questioned costs, CFNI recognizes the importance of ensuring compliance with all federal requirements. To address this finding and prevent recurrence, CFNI is implementing a comprehensive policy that mandates timely review and approval of all timecards associated with payroll expenses charged to federal grants. Additionally, CFNI is establishing a formal process to monitor adherence to this policy, including regular audits and detailed documentation of the review process. CFNI is committed to strengthening internal controls, improving oversight, and ensuring full compliance with federal grant requirements. Responsible Official: Pamela Pokropinski, VP Finance Status of finding: Completion expected June 2025
Finding 2024-003: Time and Effort Requirements (50000) Assistance Listing No. 84.425 – Education Stabilization Funds (ESSER) U.S. Department of Treasury Passed through California Department of Education Corrective Action Plan To resolve the issue, the Internal Auditor met with the Senior Secretary...
Finding 2024-003: Time and Effort Requirements (50000) Assistance Listing No. 84.425 – Education Stabilization Funds (ESSER) U.S. Department of Treasury Passed through California Department of Education Corrective Action Plan To resolve the issue, the Internal Auditor met with the Senior Secretary, Educational Services to go over the processes in place. Going forward, a list of employees that work on federal programs will be extracted from the accounting system. The Senior Secretary will use this list to see who has or not turned in their time accounting documents. The Secretary will then follow up with the respective employees and/or managers at the sites with missing documents. Responsible Person for Corrective Action Plan Cindy Barnett, Senior Secretary, Educational Services, Christina Filios, Assistant Director: Educational Services Implementation Date of Corrective Action Plan December 19, 2024 – Internal Auditor met with the Secretary to review process and find ways to improve upon it. The District will monitor this process during Fiscal Year 2024-25.
View Audit 334377 Questioned Costs: $1
Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are no...
Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are no longer using a Tier One processor for our financial aid refunds. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Implemented July 2024 when we changed from Bank Mobile to TouchNet.
Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are wo...
Recommendation: We recommend the College implement IT policies and create an updated WISP to ensure the College is compliant with the GLBA Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are working on an updated WISP and plan to have it approved by college administration prior to the end of the academic year. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: 6/30/2025
Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and a...
Recommendation: We recommend the College implement an internal control that ensures timely and accurate reporting. We also recommend the College implement changes in processes and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have documented and tested enrollment reporting to National Student Clearinghouse from our new SIS, Colleague. NSC is working with us to get our enrollment current. Once hired, our Dean of Students / Registrar will partner with the Enrollment Systems Analyst to ensure enrollment reporting is timely and accurate. Name(s) of the contact person(s) responsible for corrective action: Dean of Students (Interim Sarah Geleynse, position to be hired Winter 2025) Planned completion date for corrective action plan: 6/30/2025
Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action t...
Recommendation: We recommend the College review the requirement and implement an internal process and control to specifically monitor the outstanding Title IV funded checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented a plan to review monthly each outstanding check to ensure that all funds are returned to the Federal programs if appropriate. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Implemented in September 2024
Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Explanation...
Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. In addition, the College should revise their procedures to include documentation of the key control. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have updated our procedure to reconcile Pell and Loans twice monthly to be able to catch any reporting errors within the 15-day reporting window. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024
Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal...
Student Financial Aid Cluster – Assistance Listing No. 84.063 Recommendation: The College changed systems since the end of this fiscal year, and we recommend the College review the auto-packaging rounding rules of its new system to ensure that the Pell award is calculated in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have implemented the auditor’s recommendation and thoroughly tested award rounding in the new SIS. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Implemented September 2024
2024-002 INTERNAL CONTROL OVER COMPLIANCE WITH ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL ACTIVITIES Procedures have been established requiring supervisors to review and approve time charged to Federal projects as a part of the internal control process and ongoing...
2024-002 INTERNAL CONTROL OVER COMPLIANCE WITH ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES – PAYROLL ACTIVITIES Procedures have been established requiring supervisors to review and approve time charged to Federal projects as a part of the internal control process and ongoing monitoring of federal awards. The current internal control policies and procedures will be strengthened and enforced to ensure employees are preparing and certifying, and supervisors and/or program managers are approving hours charged to all federal projects monthly. Individual(s) Responsible for Corrective Action Plan: John Chomiak Chief Financial & Administration Officer, NMSC 312-610-5615 Anticipated Completion Date: June 30, 2025
Recommendation: The auditors recommend the University continue to focus on improving internal controls surrounding the calculation and posting of, as well as review of, budget adjustments. The auditors recommend further that the University ensure this process is well documented in a formal policy. A...
Recommendation: The auditors recommend the University continue to focus on improving internal controls surrounding the calculation and posting of, as well as review of, budget adjustments. The auditors recommend further that the University ensure this process is well documented in a formal policy. Action taken: Identified common causation factors that contributed to the finding. In this particular case, the student’s budget was adjusted more than once due to changes in both her graduation date and her tuition rate during her final year. Her budget was not adjusted correctly. The issues identified are: o Identifying when tuition charge has been adjusted. o Having another financial aid staff member review changes to the budget adjustment(s). The following actions were taken: o Reached out for assistance identifying students whose tuition has been reduced. Was provided with a report we can run before financial aid disburses, “FA Registration”, which will capture all changes to each student’s tuition. o Have included running this report in the steps completed prior to aid disbursement. o Reviewed and refined steps already in place, specifically addressing the processing of budgets for students who are off cycle during a semester. Steps are outlined in document “23-24 Budget Adjustment Quality Control Process” and include:  Templates to be used for correct budgets.  Assigned two-letter comment codes that will identify students with budget adjustment for off-cycle attendance.  Created a selection set in PowerFAIDS to capture students with these comment codes in a report.  Created a task in PowerFAIDS that will assign review of completed budget adjustments to a specific FA staff member. She will review the calculations and sign off on them. These actions have been implemented effective immediately. Name of Responsible Party: Laura Pendleton, Director of Financial Aid Anticipated completion date: October 30, 2024
View Audit 334218 Questioned Costs: $1
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