Corrective Action Plans

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Finding 517180 (2024-002)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the cam...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus and program level is aligning with the University. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The process Union Adventist University follows to ensure that enrollment effective dates as reported to NSLDS are submitted and coordinated through the Records Office. Records submits the list of enrollment effective dates to the National Student Clearinghouse. The Records office will be monitoring for error reports from National Student Clearinghouse that might affect the change of enrollment effective dates. The Records submits monthly reports to the National Student Clearinghouse for any changes that occur during the month. Name(s) of the contact person(s) responsible for corrective action: Tricia Harris, Director of Student Financial Services Planned completion date for corrective action plan: The goal date for this project to be completed is prior to the FY25 audit.
A. Revise and Strengthen Processes 1. New Software Implementation: o Replace the previous software program with a more reliable system. 2. Process Realignment: o Redefine staff roles to ensure clear responsibilities for eligibility determinations and reviews. B. Establish and Strengthen Internal Con...
A. Revise and Strengthen Processes 1. New Software Implementation: o Replace the previous software program with a more reliable system. 2. Process Realignment: o Redefine staff roles to ensure clear responsibilities for eligibility determinations and reviews. B. Establish and Strengthen Internal Controls 1. Eligibility Review: o DeAnn Gould, Federal Programs & Grants Coordinator, and Howard Carpenter, Director of Operations, will oversee eligibility determinations using the updated software and Attachment A for reference. o Conduct a second review of all applications to verify accuracy and compliance with eligibility criteria. 2. Regular Edit Checks: o Implement weekly edit checks in the Point of Service (POS) system to confirm correct benefits distribution. C. Staff Training 1. Regular Food and Nutrition Services (FNS) Training: o Conduct quarterly training sessions on eligibility criteria, compliance requirements, and internal control processes. o Include hands-on training for using the new software and reviewing Attachment A criteria. 2. Compliance Assessments: o Assess staff understanding post-training to identify additional support needs. D. Monitoring and Evaluation 1. Audit Schedule: o Conduct monthly internal audits to evaluate compliance and report findings to leadership. 2. Performance Metrics: o Track error rates in eligibility determinations and aim for a significant reduction by June 30, 2025. E. Addressing Questioned Costs 1. Reconciliation Plan: The Missouri Department of Elementary and Secondary Education (DESE) has informed the School that the questioned costs of $20,578.74 will be withheld from future Food Service payment requests. The School will work with DESE to ensure proper adjustments and compliance with this reconciliation plan. 2. Process Transparency: Documentation of the withholdings and their impact on future payments will be maintained and reviewed to confirm accurate reconciliation of the overclaimed amount.
View Audit 335092 Questioned Costs: $1
Contact Person Responsible: Kelli Engelhardt – Lead Mackenzie Stick - Support Corrective Actions Planned: 1. Enhanced Monitoring of Subsidized Loan Eligibility o Accelerated Nursing Students’ loan eligibility will be closely monitored, particularly during the first two semesters, to identify and pre...
Contact Person Responsible: Kelli Engelhardt – Lead Mackenzie Stick - Support Corrective Actions Planned: 1. Enhanced Monitoring of Subsidized Loan Eligibility o Accelerated Nursing Students’ loan eligibility will be closely monitored, particularly during the first two semesters, to identify and prevent over-awards. o Financial Aid staff will utilize Jenzabar Student Information System reporting tools to track Subsidized Loan usage and eligibility. o Anticipated Completion Date: Ongoing; Semester-based Review, effective Spring 2025 2. Preventive Measures for Timing Issues o Financial Aid staff will actively monitor updates to ISIR records and NSLDS reporting to mitigate timing-related errors. o Steps will be taken to identify students at risk for loan overpayment earlier in the process. o Anticipated Completion Date: February 1, 2025, and then ongoing with emphasis on the first two weeks of every semester. Commitment to Compliance: The University will leverage all available tools to prevent timing-related errors and ensure accurate Subsidized Loan awarding in future years.
Contact Person(s) Responsible: Kelli Engelhardt – Lead Mackenzie Stick - Support Corrective Actions Planned: 1. Evaluate Opportunity for Staffing Enhancements o A working group will be assembled to evaluate the feasibility of adding additional staff to the Financial Aid Department to ensure proper s...
Contact Person(s) Responsible: Kelli Engelhardt – Lead Mackenzie Stick - Support Corrective Actions Planned: 1. Evaluate Opportunity for Staffing Enhancements o A working group will be assembled to evaluate the feasibility of adding additional staff to the Financial Aid Department to ensure proper segregation of duties and adherence to federal guidelines. o If additional staffing is not possible due to budget constraints, existing resources within the University will be explored to meet compliance goals. o Anticipated Completion Date: March 30th, 2025 2. Implementation of Internal Control Procedures o Eligibility Determinations: Manual and automated eligibility processes will be reviewed by designated staff and supervised by the Vice President for Enrollment Management on a semester basis to ensure compliance. o Return of Funds Calculations: Dual-review processes for return of funds calculations will be implemented each semester to mitigate errors. o Anticipated Completion Date: February 28, 2025 3. Training and Documentation o Annual training will continue for the Financial Aid team to ensure compliance with the Federal Student Aid Handbook. o Comprehensive documentation and supervisory review checklists will be developed to maintain transparency. o Anticipated Completion Date: Ongoing; Annual Review in July 2025 Commitment to Compliance: The University is committed to rectifying this finding and will ensure future compliance with federal regulations.
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
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