Corrective Action Plans

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Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If ...
Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested.
Condition - The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended June 30, 2023. Planned Corrective Action - The audit for the year ended June 30, 2023 was not submitted to the Federal Audit Clearinghouse due to issues with the UEI number...
Condition - The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended June 30, 2023. Planned Corrective Action - The audit for the year ended June 30, 2023 was not submitted to the Federal Audit Clearinghouse due to issues with the UEI numbers not being renewed timely on the Academy's side. The Finance Director is now responsible for the renewals going forward, and this will not be an ongoing issue in the future. Anticipated Completion Date: November 15, 2024 Point of Contact: Mary Ann Johnson
Condition - During our testing for Activities Allowed or Unallowed, Allowable Costs/Cost Principles, it was noted that 6 out of 6 payroll transactions selected for testing did not have evidence of review and approval. Planned Corrective Action Although the Academy has internal controls in place for ...
Condition - During our testing for Activities Allowed or Unallowed, Allowable Costs/Cost Principles, it was noted that 6 out of 6 payroll transactions selected for testing did not have evidence of review and approval. Planned Corrective Action Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson
Condition - During our testing for Reporting, it was noted that 2 out of 2 reports selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbur...
Condition - During our testing for Reporting, it was noted that 2 out of 2 reports selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and_ date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson
Condition - During our testing for Cash Management, it was noted that 2 out of 2 drawdown requests selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, ...
Condition - During our testing for Cash Management, it was noted that 2 out of 2 drawdown requests selected for testing did not have evidence of review and approval. Planned Corrective Action: Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: 1. We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. 2. All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested. Anticipated Completion Date: December 1, 2024 Point of Contact: Mary Ann Johnson
Continuum of Care – Assistance Listing No. 14.267 Recommendation: The Organization has not met its matching requirement for the NC0045 grant or the NC0221 grant. The Organization has determined that these awards have become too costly to administer and is now in discussions with HUD regarding the o...
Continuum of Care – Assistance Listing No. 14.267 Recommendation: The Organization has not met its matching requirement for the NC0045 grant or the NC0221 grant. The Organization has determined that these awards have become too costly to administer and is now in discussions with HUD regarding the objective of transferring these award programs to another entity. We recommend that the Organization continue these discussions with HUD in order to end its responsibilities for award programs that it has determined it is unable to comply with. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will continue working with HUD to transfer these award programs to another entity that has more capacity of complying with all requirements. As of July 2024, grant NC0045 was transferred to Brick Capital. The Organization is continuing to work with HUD to transfer the NC0221 grant. Name(s) of the contact person(s) responsible for corrective action: Tameka Gunn, President and Chief Executive Officer Planned completion date for corrective action plan: March 2025
Views of Responsible Officials: MCCC and Affiliate have implemented a system through their payroll processor beginning the payroll cycle of 9/23/24 to 10/06/24. This includes notification to the manager’s that their staff’s timesheet has been submitted which requires their approval in iSolve. The un...
Views of Responsible Officials: MCCC and Affiliate have implemented a system through their payroll processor beginning the payroll cycle of 9/23/24 to 10/06/24. This includes notification to the manager’s that their staff’s timesheet has been submitted which requires their approval in iSolve. The unapproved payroll register issues resulted from a transition in staff. Starting November 2023, the issue has been resolved.
Finding 509644 (2024-002)
Significant Deficiency 2024
Recommendation: We recommend that management ensures policies and procedures are in place to verify college eligibility for matching fund requirements and to confirm that waivers are obtained in future years. Management Response: Management concurs with the finding. It was assumed the college would ...
Recommendation: We recommend that management ensures policies and procedures are in place to verify college eligibility for matching fund requirements and to confirm that waivers are obtained in future years. Management Response: Management concurs with the finding. It was assumed the college would be auto-designated as an eligible institution based on Integrated Postsecondary Education Data System (IPEDS) data. New procedures have been implemented. The college will submit the Title III/V application annually regardless of the IPEDS status.
Management agrees with the finding and the recommendations made by the auditor. Over the next thirty days Management will analyze the enrollment reporting control environment including (but not limited to) how enrollment status effective dates, for students who withdrawal after the completion of the...
Management agrees with the finding and the recommendations made by the auditor. Over the next thirty days Management will analyze the enrollment reporting control environment including (but not limited to) how enrollment status effective dates, for students who withdrawal after the completion of the semester, are identified and accounted for by Management. Within forty-five days, Management will implement enhanced enrollment reporting processes to ensure accurate and timely enrollment statuses are reported to NSLDS in compliance with federal regulations.
The College agrees that Enrollment Reporting should be submitted in a timely manner. The College has been actively working with the new SIS to ensure the ability to produce the reports and has currently submitted reports through the Fall 2023 term. The College anticipates completion of reports throu...
The College agrees that Enrollment Reporting should be submitted in a timely manner. The College has been actively working with the new SIS to ensure the ability to produce the reports and has currently submitted reports through the Fall 2023 term. The College anticipates completion of reports through the Fall 2024 term by the end of December, resulting in compliance with this requirement.
Student Financial Assistance Cluster– 84.038 – Federal Perkins Loans Recommendation: We recommend that the University implement a procedure with the third-party servicer to ensure that its Title IV compliance report is completed in a timely manner so that the University can perform the necessary due...
Student Financial Assistance Cluster– 84.038 – Federal Perkins Loans Recommendation: We recommend that the University implement a procedure with the third-party servicer to ensure that its Title IV compliance report is completed in a timely manner so that the University can perform the necessary due diligence. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For 22-23, the third-party servicer provided the compliance report in March 2024. For 23-24, the third-party servicer states the report should be available by the end of December 2024. Name(s) of the contact person(s) responsible for corrective action: Michael Dorner Planned completion date for corrective action plan: Already in place
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded with...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An internal tracker has been created for the entire team to report why a credit balance is not released to the student; and to monitor what steps are still needed to take to clear and release the credit balance. This will allow staff and the Financial Aid Director to quickly assist when staff is unexpectedly out of the office and connect with the necessary departments. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: Put into place November 2024
View Audit 329180 Questioned Costs: $1
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded with...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its current policies and procedures around credit balances and ensure the processes in place are sufficient to ensure student credit balances due to federal funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An internal tracker has been created for the entire team to report why a credit balance is not released to the student; and to monitor what steps are still needed to take to clear and release the credit balance. This will allow staff and the Financial Aid Director to quickly assist when staff is unexpectedly out of the office and connect with the necessary departments. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: Put into place November 2024
View Audit 329180 Questioned Costs: $1
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A report was created in response to 2022-001 that pulls all students to verify no R2T4 are missed, it was put into place and pulled at the end of the semester. This did catch the 5 students, however, instead of running at the end of the semester, it now runs every 30 days to make sure students are processed within 45 days. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: The new process started in August 2024
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend that the University implement a review process as it relates to R2T4. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A report was created in response to 2022-001 that pulls all students to verify no R2T4 are missed, it was put into place and pulled at the end of the semester. This did catch the 5 students, however, instead of running at the end of the semester, it now runs every 30 days to make sure students are processed within 45 days. Name(s) of the contact person(s) responsible for corrective action: Amanda McCaughan Planned completion date for a corrective action plan: The new process started in August 2024
View Audit 329180 Questioned Costs: $1
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: Th...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the 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. Registrar's Office did note that while nine students were flagged within the audit review, the final report does include an additional 18 students who were not brought to the attention of the Registrar’s Office during the audit. Action taken in response to finding: The Registrar's Office worked with the National Student Clearinghouse to identify new errors with CIP code rejects. We have now updated the curriculum in our SIS to eliminate the error and review the reject report for this specific error. The Registrar's Office will modify the report schedule with the National Student Clearinghouse to every three weeks to assist NSLDS with more time to update their website to align with compliance timelines. The National Student Clearinghouse records show the submission timeline. Name(s) of the contact person(s) responsible for corrective action: Lynn Lundquist Planned completion date for a corrective action plan: The new process started in August 2024
Inaccurate Packaging of Federal Direct Loans (FDL) Planned Corrective Action: Shorter University will provide additional training to Financial Aid Staff regarding the importance of reviewing students financial aid offers after manual adjustments are made. The training will include practice scenarios...
Inaccurate Packaging of Federal Direct Loans (FDL) Planned Corrective Action: Shorter University will provide additional training to Financial Aid Staff regarding the importance of reviewing students financial aid offers after manual adjustments are made. The training will include practice scenarios. In addition to training staff, Shorter University's Director of Information Technology is creating a quality control report that will identify students who may be eligible for a subsidized Stafford loan but have not received one. The report will be monitored by the Assistant Director of Financial Aid Systems who will review the students' financial aid. The quality control report will ensure the proper subsidized and unsubsidized Stafford loan allocation. A manual adjustment error was made to a student's financial aid offer, after financial aid was accepted resulting in an under awarding of a Stafford loan. A $3,500 unsubsidized loan to subsidized loan swap will be completed to hold the student harm less and correct the manual adjustment error. Person Responsible for Corrective Action Plan: Colleen Lassiter Anticipated Date of Completion: Training will be completed November 8, 2024 and Quality Control Report will be completed by December 15, 2024.
View Audit 329160 Questioned Costs: $1
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: An incorrect satisfactory academic progress tracking status was assigned to a single student, which resulted in the one student receiving federal aid for the spring semester when they sh...
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: An incorrect satisfactory academic progress tracking status was assigned to a single student, which resulted in the one student receiving federal aid for the spring semester when they should have been marked as ineligible. The spring disbursement was corrected promptly when uncovered and funds have been returned to ED. An enhanced system is now in place to more clearly track the satisfactory academic progress of students who take a leave of absence from the university and return without demonstrating satisfactory academic progress at a different school. Anticipated Completion Date: 11/1/2024
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, tra...
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: This finding cumulated into three different types of issues, summarized below, and corrective action has been taken for each of the three. In addition to addressing the three issues, training has been provided to the financial aid staff for the verification process as a whole and a report is being run several times a month to identify possible data entry errors of the verification process. 3 of the 8 students had a discrepancy in their documentation that does not result in a change to their federal aid eligibility. This has been addressed by implementing an electronic signature of the verification worksheet through DocuSign. 3 of the 8 students submitted documentation for a professional judgement that was approved, however the professional judgement flag was not properly selected. This has been addressed by reviewing the professional judgement steps taken by the financial aid team and providing training to those who submit professional judgement changes in the FAFSA Partner Portal. 2 of the 8 students had incomplete documentation saved to the student file. This has been addressed by implementing an additional step in the verification process to require a second review of verification documents by two separate staff members. Anticipated Completion Date: 11/1/2024
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing im...
Individual Responsible for Corrective Action: Sarah Christoffersen, Director of Financial Aid Corrective Action: All instances of this finding occurred during the fall 2023 semester while we were still in the implementation process for joining the National Student Clearinghouse. Since completing implementation, there have been no further instances. Anticipated Completion Date: Completed
Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation Status submission calendar will be updated to reflect the necessary reporting timeline and appropriate parties within the Office of the Registrar, Student Financial Services, and Offic...
Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation Status submission calendar will be updated to reflect the necessary reporting timeline and appropriate parties within the Office of the Registrar, Student Financial Services, and Office of Institutional Effectiveness will be held responsible for specific deadlines each month. The report will be completed after verification of graduation requirements and credentialing or other status changes are completed in Colleague by the Registrar's Office. Ellucian Colleague processes will be fully utilized for NSC file generation. The Registrar and Associate Registrar complete different steps in the credentialing process, but will review the student records together to ensure accuracy and timely completion. Submission of graduation status to NSC will occur after each academic term (fall and spring semester, January and summer sessions) and submission of other status changes will occur monthly and follow-ups will occur within four business days.
Need Analysis Planned Corrective Action: To ensure compliance with Needs Analysis regulations for the limitations of keeping aid within the Cost of Attendance (COA) both during R2T4 calculations and in overall packaging, Point Loma will use system-specific configuration our new Workday Student Finan...
Need Analysis Planned Corrective Action: To ensure compliance with Needs Analysis regulations for the limitations of keeping aid within the Cost of Attendance (COA) both during R2T4 calculations and in overall packaging, Point Loma will use system-specific configuration our new Workday Student Financial Aid software: • Disbursement Eligibility criteria that flags “Exceeds COA”, preventing disbursement • Automatic calculations of the COA based on the number of weeks in which the student is enrolled. (Our previous software required all manual review and adjustments to COA when a student was only enrolled in a single module.) Any changes to the number of weeks or to enrollment as a whole, will result in a Need Packaging Reaction, prompting staff to re-run Cost of Attendance calculations and Need Packaging as needed. Furthermore, Point Loma will review and revise procedures for mandatory recalculations of COA, and train staff on these procedures. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid Jamie Asche, Director of SFS Business Analysis and Compliance Joanna Castro, Associate Director of Financial Aid, GPS Anticipated Date of Completion: December 31,2024
Return of Title IV (R2T4) Calculations Planned Corrective Action: To ensure compliance with R2T4 regulations for modules and the consideration of days, Point Loma will review and revise procedures for completion and clarity, and train staff on these procedures. Person Responsible for Corrective Acti...
Return of Title IV (R2T4) Calculations Planned Corrective Action: To ensure compliance with R2T4 regulations for modules and the consideration of days, Point Loma will review and revise procedures for completion and clarity, and train staff on these procedures. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid Jamie Asche, Director of SFS Business Analysis and Compliance Joanna Castro, Associate Director of Financial Aid, GPS Anticipated Date of Completion: December 31,2024
October 22, 2024 RE: Finding 2024-001 Student Financial Aid Cluster Enrollment Reporting - Clearinghouse for National Student Loan Data (NSLDS) enrollment reporting for the Fall 2023 and Spring 2024 semesters. Student Affair’s response and corrective action plan. Purpose of Student Reporting Student...
October 22, 2024 RE: Finding 2024-001 Student Financial Aid Cluster Enrollment Reporting - Clearinghouse for National Student Loan Data (NSLDS) enrollment reporting for the Fall 2023 and Spring 2024 semesters. Student Affair’s response and corrective action plan. Purpose of Student Reporting Student enrollment reporting is critical, as it is sent to the National Student Clearinghouse, which then provides this data to the National Student Loan Data System (NSLDS). This information is used to determine students' enrollment status, which is essential for the administration of financial aid, particularly for calculating grace periods and repayment timelines for student loans. Corrective Actions and Process Changes Once we identified the reporting issue, we re-ran the reports using the previous method, prior to the saved list implementation, to compare the results. We thoroughly reviewed the enrollment numbers for both semesters to ensure all students were correctly reported. In addition, we contacted the National Student Clearinghouse to make the necessary corrections. To ensure this issue is fully resolved moving forward, we have implemented a more rigorous internal process, including thorough testing and random sampling. We now compare reported enrollment data against actual student enrollment for each semester, allowing us to verify that all students are accurately reported. These enhanced measures will safeguard against similar oversights in the future. Challenges with Clearinghouse Resolution While we completed our internal corrections, we experienced significant delays in finalizing the data updates due to customer service challenges on the National Student Clearinghouse’s side. After escalating the issue, we were able to receive assistance from a representative on October 23rd, which we believe will resolve the discrepancies. Expected completion date: 10/31/24 Partys Responsible: Dr. Jason Johnson, Vice President for Student Affairs - Amanda Williams- Mize, Assistant Vice President for Enrollment Services, Registrar Contact Information: jason.k.johnson@occc.edu 405-682-1611 ext. 7784 amanda.williams-mize@occc.edu, 405-682-7537
Significant Deficiencies: Finding: 2024-002 Segregation of Duties Name of Contact Person: Wendy Duckett, Housing Director Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue ...
Significant Deficiencies: Finding: 2024-002 Segregation of Duties Name of Contact Person: Wendy Duckett, Housing Director Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to approve and sign checks and periodically review the financial statements. Proposed Completion Date: The Board will implement the above procedure immediately. Findings and Questioned Costs - Major Federal Awards Programs Audit Finding: 2024-002 Segregation of Duties Same as above.
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