Corrective Action Plans

Finding 513738 (2024-002)

Significant Deficiency 2024

OK

Eligibility Procurement, Suspension & Debarment Student Financial Aid § 200.303

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University...

ederal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP. Explanation of disagreement with audit finding: There is no disagreement with the audit finding . Action taken in response to finding: The Registrar's Office procedure will be to convert clock hours to credit hours to avoid this situation moving forward. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: December 15, 2024

View Audit 331630

Finding 513700 (2024-002)

Significant Deficiency 2024

City Colleges of Chicago

IL

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Finding 2024-002 – Enrollment Reporting Condition • For one out of sixty students tested (2%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Also, th...

Finding 2024-002 – Enrollment Reporting Condition • For one out of sixty students tested (2%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Also, the student’s program level withdrawal was not reported to NSLDS within 60 days. • For one out of sixty students tested (2%) who withdrew from City Colleges, the student’s withdrawal date reported to the NSLDS for campus level was not reported to NSLDS within 60 days. • For two out of sixty students tested (3%) who withdrew from City Colleges were not reported to NSLDS within 60 days. Cause CCC sends enrollment files of all students to National Student Clearinghouse (NSC) monthly, who then reports CCC enrollment data to National Student Loan Data System (NSLDS). It was discovered that two of the errors occurred due to an update in NSLDS and CCC was not aware the update caused missing files. In the other instances files were sent in late February, but not corrected within NSC until March 5th thus, it missed the beginning of the March roster. Corrective Action Taken or Planned CCC will work with NSC to monitor future updates and ensure files are accurately shared with NSLDS. Records, Financial Aid, Decision Support and OIT continue to meet bi-weekly to review and update the enrollment reporting logic to ensure the dates for student enrollment actions align at the campus level and the program level. In addition, the compliance team will monitor updates and announcements from NSC regarding file errors to ensure timely updates are submitted. Contact Person: Laura Clark, Associate Vice Chancellor, Academic Systems and Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 20, 2024

View Audit 331604

Finding 513692 (2024-001)

Significant Deficiency 2024

Montello School District

WI

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Finding #2024-001 – Limited Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detec...

Finding #2024-001 – Limited Segregation of Duties (Prior Year Finding #2023-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the district’s operations. Response: We agree with this finding and continue to work to achieve segregation of duties whenever cost effective. The cash disbursements process includes approval of purchase orders and matching of approved purchase orders with invoices. Review of account coding is performed by the district accounting staff. The payroll disbursement process includes approval of timesheets and review of coding on an ongoing basis. The Board of Education reviews budget to actual information along with disbursement information monthly. Contact Person: Cheryl Troost Anticipated Completion: Not Applicable

View Audit 331602

Finding 513661 (2024-002)

Significant Deficiency 2024

Vanguard University of Southern California and Affiliates

CA

Student Financial Aid Subrecipient Monitoring Reporting

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonst...

FINDING 2024-002 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: An undergraduate student in a year-round program was reported to National Student Clearinghouse (NSC) as a student for whom summer term was nonstandard. Non-standard summer term students are not reported to NSC over summer if they are not enrolled. Since this student was in a year-round program, the student should have been reported with summer as a standard term. Based on Vanguard’s NSC transmission schedule, had this student’s NSC Branch been classified correctly, the student would have been in a NSC transmission standard term data file and reported within 30 days of the enrollment adjustment. Annually, the Registrar’s Office will review all programs to ensure that year-round program students are reported to NSC with summer as a standard term. The assistant registrar who is responsible for both NSC reporting and updating program degree audits will manage this process with the dean of academic records oversight. The Registrar’s Office will create a column in the annual degree audit log that indicates standard/non-standard classification has been properly determined and set up correctly in the student information system for accurate reporting to NSC. A sample set of students within each NSC transmission will be checked following transmission in NSC by the Registrar’s Office and NSLDS by the Financial Aid Office to ensure that enrollment status is accurate. Name of Contact Person: Julie Cowen, Dean of Academic Records, 714-662-5204 Projected Completion Date: Program review for standard/non-standard classification for 2024-25 was completed on October 28, 2024 and will be completed annually in March-April beginning in 2025.

View Audit 331568

Finding 513656 (2024-001)

Significant Deficiency 2024

Vanguard University of Southern California and Affiliates

CA

Special Tests & Provisions Student Financial Aid Significant Deficiency

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Controls Over Compliance Corrective Action Plan: A traditional undergraduate who withdrew did not have an R2T4 calculation completed within 30 days of withdrawal and federal funding was not...

FINDING 2024-001 – Special Tests and Provisions – Return of Title IV Funds: Significant Deficiency in Internal Controls Over Compliance Corrective Action Plan: A traditional undergraduate who withdrew did not have an R2T4 calculation completed within 30 days of withdrawal and federal funding was not returned within 45 days of withdrawal. The withdrawal process by the student and academic staff was not completed according to process or timeframe. The course deregistration and withdrawal process for a traditional undergraduate student did not occur following standard procedures or timeframe. The Registrar’s Office entered two different course deregistration dates, within the two-week add/drop period, into the student information system and the withdrawal was entered nearly 60 days after the first day of class. The withdrawal and leave of absence reports generated daily and enrollment adjustment report generated weekly had inadequate queries to catch this complicated course deregistration and withdrawal situation to trigger timely R2T4 calculation and return of federal funding. Following this finding, the Financial Aid Office identified the reporting deficiencies and started dialog with the Registrar’s Office and Information Technology regarding student information system screens and fields being used by the Registrar’s Office that need to be adjusted on the reports. The Registrar’s Office understands the interdependency between its office and the Financial Aid Office with regards to enrollment adjustments and completing an R2T4 calculation, returning federal funding, monitoring Common Origination and Disbursement transmission and any necessary communication with students. With daily and weekly monitoring of said reports, and the Registrar’s Office proactively notifying the Financial Aid Office of any enrollment adjustments that are nearing the R2T4 deadlines rather than solely relying on reports, the Financial Aid Office will be positioned to be compliant with the federal deadlines. The Financial Aid Office will begin a two-person review of calculation and funding return and a recorded acknowledgement of such. Name of Contact Person: Kim Johnson, Vice President for Enrollment Management, 714-966-5415 Projected Completion Date: Review of all fall 2024 enrollment adjustment/withdrawal/leave of absence students after the first day of class (August 26, 2024) will be done by the vice president for enrollment management (serving as director of financial aid) and assistant director during November 2024. Going forward, said two-person review will be done daily by the assistant director and at a minimum biweekly by a senior manager.

View Audit 331568

Finding 513630 (2024-001)

Material Weakness 2024

Clarke University of Dubuque, Iowa

IA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisio...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans ‐ 2023/2024 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program ‐ 2023/2024 P063P201430 Special Tests & Provisions:– Return of Title IV Funds Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: One instance was identified where there was no documented return of Title IV calculation, and fourteen instances were identified where there was no documented review of the return of Title IV calculation. Responsible Individuals: Robert Hoover, Director of Financial Aid and Sylma Fernandez, Assistant Director of Financial Aid Corrective Action Plan: The Financial Aid Director recently completed R2T4 process training with the Controller. This added expertise will enhance the secondary review process, providing an independent assessment by a reviewer not involved in daily operations. This additional oversight will strengthen quality control through sampled calculation reviews. Furthermore, expanded attendance and withdrawal reports will support comprehensive control processes for this cluster. Anticipated Completion Date: Commenced December 1, 2024

View Audit 331542

Finding 513617 (2024-002)

Material Weakness 2024

Calvary University

MO

Student Financial Aid Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment

Condition Found: The University has an adequate Satisfactory Academic Progress policy. Student GPAs and completion rates are reviewed at the end of each academic year. However, the University is not informing students when they are placed on financial aid suspension and how to appeal the decision. C...

Condition Found: The University has an adequate Satisfactory Academic Progress policy. Student GPAs and completion rates are reviewed at the end of each academic year. However, the University is not informing students when they are placed on financial aid suspension and how to appeal the decision. Corrective Action Plan: Management agrees with the auditors’ finding and their recommendation. The Business Office and the Director of Financial Aid is in the process of creating a Financial Aid Suspension Letter to notify students of the financial aid ramifications of being placed on financial aid suspension. Anticipated Completion Date: The corrective action will be completed by December 31, 2024. Contact Person: Tasha Young, CFO 816-425-6151

View Audit 331527

Finding 513616 (2024-001)

Material Weakness 2024

Calvary University

MO

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Condition Found: The bi-monthly National Student Loan Database System (“NSLDS”) Enrollment Reporting Summary Reports were not updated and returned to NSLDS during the year ended June 30, 2024. Therefore, student enrollment status changes were not reported timely to NSLDS. Corrective Action Plan: Man...

Condition Found: The bi-monthly National Student Loan Database System (“NSLDS”) Enrollment Reporting Summary Reports were not updated and returned to NSLDS during the year ended June 30, 2024. Therefore, student enrollment status changes were not reported timely to NSLDS. Corrective Action Plan: Management agrees with the auditors’ finding and their recommendation. The Director of Financial Aid or business office staff will update the enrollment status for all students who obtained Federal Direct Student Loans from the University. The University will review its contract with their third-party financial aid administrator. The University will update their policies and procedures as needed. Anticipated Completion Date: The corrective action will be completed by December 31, 2024. Contact Person: Tasha Young, CFO 816-425-6151

View Audit 331527

Finding 513610 (2024-007)

Significant Deficiency 2024

Cleveland State University

OH

Internal Control / Segregation of Duties Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Name of the contact person responsible for corrective actions planned: Rachel Schmidt Financial Aid Director Cleveland State University 2121 Euclid Avenue, UN 402 Cleveland, OH 44115 Phone: 216.687.5594 E-mail: r.m.schmidt@csuohio.edu Corrective actions planned: During the audit of Perkins Loan fil...

Name of the contact person responsible for corrective actions planned: Rachel Schmidt Financial Aid Director Cleveland State University 2121 Euclid Avenue, UN 402 Cleveland, OH 44115 Phone: 216.687.5594 E-mail: r.m.schmidt@csuohio.edu Corrective actions planned: During the audit of Perkins Loan files, it was identified that 5 out of the 25 files tested did not contain a signed Perkins Loan form. Management understands the recommendation to review and strengthen its procedures for collecting and retaining Perkins Loan forms and the need to retain the records of former students. While we are certain that the required documentation exists or existed at one time, the passage of time and lack of digital backups impaired our ability to produce the documents. Since the loans related to the missing documents are currently in repayment status, we feel that provides assurance the former students did sign the loan agreement. However, we understand the need to retain all critical forms for our students. Completion date: November 2024

View Audit 331516

Finding 513583 (2024-002)

Significant Deficiency 2024

Cankdeska Cikana Community College

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking

2024-002 Contact Person Chelly Merkel-Veer Planned Corrective Action The College collects weekly payrolls from contractors. They will be checked by the Facilities Director and CFO to assure they are being reported on the required form WH-347. Planned Completion Date Immediately

View Audit 331509

Finding 513576 (2024-002)

Material Weakness 2024

Woodbury University

CA

Student Financial Aid Subrecipient Monitoring Material Weakness

Woodbury University Corrective Action Plan For the Year Ended June 30, 2024 Agency: U.S. Department of Education Name of Federal Program or Cluster: Student financial assistance cluster Award Year: 2023-2024 Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness ...

Woodbury University Corrective Action Plan For the Year Ended June 30, 2024 Agency: U.S. Department of Education Name of Federal Program or Cluster: Student financial assistance cluster Award Year: 2023-2024 Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting – Material Weakness in Internal Control Over Compliance Conditions: From a system generated population of 119 students who received federal aid and either graduated, withdrew, or changed their permanent address during the year ended June 30, 2024, auditors selected a sample of 17 students who received direct loans. The enrollment information and withdrawal or graduation date per the Woodbury University’s records were compared to the information reported to NSLDS in order to determine if status changes were reported accurately and within the required timeframes. Of the 17 students selected for testing, 17 were not reported to the NSLDS within the required timeframe and had an incorrect status reported to the NSLDS. Corrective Action Plan: If the student is planning to leave the University. Students must withdraw from all classes before the withdraw date. Also, the students must circulate their form to the listed departments for a signature. The issue is something this was completed by email with several forms for the same student. We will work with Redlands to create a Soft Doc/ electronic withdraw form which can be completed by the student on line. This form will be accessible to the offices listed on the form paper. Also, this will aid in the Registrar's Office and Financial Aid to have more accurate record of the students who have completed the withdraw process. Name of Contact Person: Verletta Jackson, Registrar, (818) 252-5277 Projected Completion Date: Spring 2025

View Audit 331458

Finding 513532 (2024-005)

Significant Deficiency 2024

North Kansas City School District No.74

MO

School Nutrition Programs Reporting Significant Deficiency § 200.303

Identifying Number: 2024-005 Reporting – Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582...

Identifying Number: 2024-005 Reporting – Significant Deficiency U.S. Department of Agriculture Passed through Missouri Department of Elementary and Secondary Education Child Nutrition Cluster, Assistance Listing No. 10.555 (National School Lunch Program), 10.553 (School Breakfast Program), 10.582 (Fresh Fruit and Vegetable Program) Federal award year 2023-2024 U.S. Department of Education Passed through Missouri Department of Elementary and Secondary Education Education Stabilization Fund, Assistance Listing No. 84.425C (Governor’s Emergency Education Relief Fund), 84.425D (Elementary and Secondary School Emergency Relief Fund), 84.425U (American Rescue Plan-Elementary and Secondary School Emergency Relief), 84.425W (American Rescue Plan-Elementary and Secondary School Emergency Relief-Homeless Children and Youth) Federal award year 2023-2024 Summary of Finding: Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance retirements. This includes controls to ensure that reports submitted are timely, complete, and accurate. Condition: The District did not have internal controls in place for federal reports to be reviewed for completeness and accuracy prior to submission. Cause: A lack of controls that could reasonably ensure this review had been performed by someone other than the preparer of the information. Effect or potential effect: The potential effect is submitting incomplete or inaccurate reports. Questioned costs: None Context: For all sample selections tested in the major programs, all reports were submitted timely and appeared to be accurate, however, there was no evidence that these reports were reviewed for completeness and accuracy prior to submission. Identification as a repeat finding, if applicable: Not applicable. Corrective Action: To ensure the accuracy of Federal reports/claims, Food service will implement the following procedures: Federal reporting and claims will be reviewed for accuracy and completeness by the Food service director or designee before they are submitted. The food service director or designee will initial report to document this review. Finance department personnel will implement the following procedures for other federal programs: One employee will start the ePeGS process. This employee will forward the documentation that they used to prepare the ePeGS filing to their supervisor. The supervisor will review the documentation and the items entered into ePeGS for accuracy. Once the supervisor is satisfied that the ePeGS filing is correct, he or she will submit the ePeGS filing. This process will be documented in the ePeGS history. Anticipated Completion Date: June 2025 (for the year ending June 30, 2025). Contact Person: Steve Marriott, Controller 816-321-5000 Steve.marriott@nkcschools.org

View Audit 331386

Finding 513490 (2024-001)

Significant Deficiency 2024

Job Training & Employment Corporation

MA

Matching / Level of Effort / Earmarking

JTEC is aware of the requirement and did all it could to be compliant. The lack of enrollment is something that was out of JTEC’s control. JTEC runs one of the many MassHire career centers in the state that struggled meeting this Federal requirement. In addition, JTEC communicated the issue to MDCS....

JTEC is aware of the requirement and did all it could to be compliant. The lack of enrollment is something that was out of JTEC’s control. JTEC runs one of the many MassHire career centers in the state that struggled meeting this Federal requirement. In addition, JTEC communicated the issue to MDCS. JTEC has established a separate youth and testing center, designed to cater to the specific needs and preferences of youth participants. In addition to keeping in regular contact with school guidance departments and student support staff, JTEC’s youth counselor continues to connect with juvenile court and probation officers, and works with the department of transitional assistance young parent program staff to encourage referrals to JTEC’s youth programs. JTEC is running an aggressive schedule of digital marketing campaigns that target youth in our service delivery area. JTEC has contracted with various vendors for content and distribution of these campaigns. JTEC has also increased its youth work experience wage, and has revised its support services and incentives policy to make incentives for youth participation more appealing. Increasing awareness of the out of school youth services available, ensuring that the youth program design and implementation match the needs of youth in our area, and maintaining strong relationships in our referral networks is JTEC’s strategy to increase out of school youth enrollments and youth work experience participation.

View Audit 331372

Finding 513474 (2024-001)

None 2024

Fox Valley Technical College District

WI

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

It is our understanding that issues are occurring for many institutions and appear to be due to changes in processes at the National Student Clearinghouse (NSC). We will monitor steps taken, updates and/or guidance made by NSC and professional organizations such as NASFAA to maintain awareness of an...

It is our understanding that issues are occurring for many institutions and appear to be due to changes in processes at the National Student Clearinghouse (NSC). We will monitor steps taken, updates and/or guidance made by NSC and professional organizations such as NASFAA to maintain awareness of any resolution to the issue identified. We will leverage the capabilities of our new student information system to use last dates of attendance for reporting enrollment statuses to NSC, as well as provide additional communication to faculty regarding the requirement to enter grades and last dates of attendance accurately and timely. Additionally, we will establish an internal process to review and update student status effective dates reported to NSC, ensuring they align with the last dates of attendance used in Return of Title IV calculations.

View Audit 331355

Finding 513461 (2024-001)

Significant Deficiency 2024

Moraine Valley Community College District Number 524

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Corrective Action Planned: The Director of Financial Aid will identify unofficial withdrawals through the R2T4 process. Financial Aid staff will use the NSLDS Enrollment History Update feature to adjust historical changes directly. This ensures that the Clearinghouse sends an updated certification o...

Corrective Action Planned: The Director of Financial Aid will identify unofficial withdrawals through the R2T4 process. Financial Aid staff will use the NSLDS Enrollment History Update feature to adjust historical changes directly. This ensures that the Clearinghouse sends an updated certification of current enrollment status to NSLDS, avoiding any disruption in the NSLDS SSCR Roster process and preventing data from being unintentionally overwritten. For these historical changes, once the NSLDS is updated, the Director of Financial Aid will notify the Assistant Dean of Enrollment Services. The Assistant Dean will then update the Clearinghouse records accordingly, ensuring the enrollment is rebuilt to prevent backdated data from being overwritten. Anticipated Completion Date: June 30, 2025 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu

View Audit 331335

Finding 513458 (2024-001)

Significant Deficiency 2024

Gateway Techincal College District

WI

Student Financial Aid Reporting Significant Deficiency

U.S. Department of Education Gateway Technical College District respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings ...

U.S. Department of Education Gateway Technical College District respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2024-001 Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend that the District review its processes and internal controls designed to mitigate the risk of noncompliance with the stated criteria to ensure the information reported to NSLDS is consistent with District records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will take corrective action to correct the information for the one (1) exception noted in the audit. In addition, the District will review its procedures for the transmission of the required data to the National Student Clearinghouse, which assists the District in transmitting the data to the National Student Loan Data System. This review will include consideration of process enhancement to mitigate the risk of the error occurring again in future submissions. Name of the contact person responsible for corrective action: Travis Jansen, Registrar Planned completion date for corrective action plan: June 30, 2025 *** If the U.S. Department of Education has questions regarding this plan, please call Travis Jansen, Registrar at 262-564-2450.

View Audit 331307

Finding 513409 (2024-003)

None 2024

The Open Door Network

CA

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring

Managements Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their ESG programs matching requirements to familiarize themselves with the amount of required match, and work with the Organization's Controller to identify program needs for whi...

Managements Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their ESG programs matching requirements to familiarize themselves with the amount of required match, and work with the Organization's Controller to identify program needs for which matching funds can be used. The Organizations Controller will ensure that these expenditures are tracked in the Accounting software. Led by the Compliance Manager and Controller, a review process will be implemented with the grants, accounting and compliance team before any grant is submitted to ensure the Organization can obtain the match. This will be completed by February 2025.

View Audit 331259 Questioned Costs: $1

Finding 513404 (2024-002)

None 2024

The Open Door Network

CA

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Management's Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their Continuum of Care Programs matching requirements to familiarize themselves with the amount of required match, and work with the Organizations Controller to identify program...

Management's Response/Planned Corrective Action: Beginning immediately, the Organization's Program Directors will review their Continuum of Care Programs matching requirements to familiarize themselves with the amount of required match, and work with the Organizations Controller to identify program needs for which matching funds can be used. The Organization's Controller will ensure that these expenditures are tracked in the Accounting software. Led by the Compliance Manager and Controller, a review process will be implemented with the grants, accounting, and compliance team before any grant is submitted to ensure the Organization can obtain the match. This will be completed by February 2025.

View Audit 331259

Finding 513383 (2024-003)

Significant Deficiency 2024

Platte Health Center

SD

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Finding Summary: The Health Center does not have a formally documented review and approval process in place to ensure compliance with the debt service co...

Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Finding Summary: The Health Center does not have a formally documented review and approval process in place to ensure compliance with the debt service coverage ratio and working capital calculations. Responsible Individuals: Vicki Jensen, Chief Financial Officer Corrective Action Plan: Platte Health Center will perform debt service ratio and working capital calculations as part of their year-end close process. The calculations will be reported to the Board of Directors and be recorded in the meeting minutes. Anticipated Completion Date: June 30, 2025

View Audit 331222

Finding 513260 (2024-002)

None 2024

Dallas Christian College

TX

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

Need Analysis and Estimated Financial Assistance Planned Corrective Action: The new student information system adopted this fall will help avoid this issue. In addition, students with high SAIs will be monitored more closely to ensure scholarships and need based aid are being applied appropriately....

Need Analysis and Estimated Financial Assistance Planned Corrective Action: The new student information system adopted this fall will help avoid this issue. In addition, students with high SAIs will be monitored more closely to ensure scholarships and need based aid are being applied appropriately. Person Responsible for Corrective Action Plan: Jean-Claude St Juste, Financial Aid Director Anticipated Date of Completion: December 31, 2024

View Audit 331201 Questioned Costs: $1

Finding 513244 (2024-001)

Significant Deficiency 2024

Mississippi College

MS

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

2024 –001 Special Tests and Provisions – Return to Title IV Program: Student Financial Assistance Cluster Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268, 84.379 Name of Contact Person: Tawesia Colyer, Director of Financial Aid Corrective Action: Due to turnover in the Financial Aid Depart...

2024 –001 Special Tests and Provisions – Return to Title IV Program: Student Financial Assistance Cluster Assistance Listing Numbers 84.007, 84.033, 84.063, 84.268, 84.379 Name of Contact Person: Tawesia Colyer, Director of Financial Aid Corrective Action: Due to turnover in the Financial Aid Department, the number of break days related to whole week breaks was entered into the academic calendar as 7 days instead of the correct 9 days. The process surrounding the entering of days into the academic calendar for breaks and the process for the calculation of any return of Title IV funds has been corrected for this matter. A new process went into effect as of August 1, 2024, and includes updating Policy and Procedures on R2T4 as well as more in-depth training for the Financial Aid staff. A back-up financial aid counselor to assist in R2T4 has been added and is involved in all training. All R2T4 withdrawals requiring a calculation are being added to a spreadsheet for review with the Director of Financial Aid which will be completed each semester. Additionally, the Office of Business Affairs has begun implementing internal control procedures to serve as a detective control. Of note, the calculations used in the 2023-2024 academic year resulted in no questioned costs and an over-return of funds to the U.S. Department of Education. Anticipated Completion Date: December 31, 2024

View Audit 331197

Finding 513227 (2024-005)

Material Weakness 2024

Southwestern Oregon Community College

OR

Matching / Level of Effort / Earmarking Student Financial Aid Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.063,84.268 Recommendation: We recommend the college evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Ex...

Student Financial Assistance Cluster – Assistance Listing No. 84.063,84.268 Recommendation: We recommend the college evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Additional staff member will review COD reports before they are submitted via EdConnect. Name(s) of the contact person(s) responsible for corrective action: Avena Singh Planned completion date for corrective action plan: November 2024

View Audit 331167

Finding 513223 (2024-004)

Material Weakness 2024

Southwestern Oregon Community College

OR

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend the College implement a formal documented review process for the R2T4 process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actio...

Student Financial Assistance Cluster – Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend the College implement a formal documented review process for the R2T4 process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff in Business Office to now double-check and sign off on R2T4s after Financial Aid processes. Name(s) of the contact person(s) responsible for corrective action: Avena Singh Planned completion date for corrective action plan: November 2024.

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Finding 513219 (2024-003)

Material Weakness 2024

Southwestern Oregon Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend the college implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanat...

Student Financial Assistance Cluster – Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend the college implement changes in process 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: Continue to review policies and procedures for accurate reporting. Investigate and identify discrepancies being exported by the Student Information System (Jenzabar). Have additional staff member review file and sign off before the data is submitted. Name(s) of the contact person(s) responsible for corrective action: Avena Singh Planned completion date for corrective action plan: March 2025

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Finding 513215 (2024-002)

Significant Deficiency 2024

Southwestern Oregon Community College

OR

Matching / Level of Effort / Earmarking Student Financial Aid Eligibility § 200.303

Student Financial Assistance Cluster– Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend that the college review the process packaging awards and adjusting awards after they are packaged to ensure that the student’s subsidized loan award is calculated correctly, and stud...

Student Financial Assistance Cluster– Assistance Listing No. 84.007,84.033,84.063,84.268 Recommendation: We recommend that the college review the process packaging awards and adjusting awards after they are packaged to ensure that the student’s subsidized loan award is calculated correctly, and student is not under awarded. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student’s record has been updated to reflect proper Direct Subsidized Stafford Loan. School will create validation reports run regularly to find any records that may need further review. Name(s) of the contact person(s) responsible for corrective action: Avena Singh Planned completion date for corrective action plan: Incorrect student record fixed November 2024. Validation report shall be completed before February 2025.

View Audit 331167

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