Corrective Action Plans

Finding 513148 (2024-001)

Significant Deficiency 2024

WY

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

The Student Financial Aid Office and The Office of Student Records will work closely to ensure students date of withdrawal from all courses are entered into Colleague correctly and that both offices dates match. The Office of Student Records will provide the National Clearinghouse enrollment reporti...

The Student Financial Aid Office and The Office of Student Records will work closely to ensure students date of withdrawal from all courses are entered into Colleague correctly and that both offices dates match. The Office of Student Records will provide the National Clearinghouse enrollment reporting dates for Central Wyoming College to the Financial Aid Office. This will ensure the Financial Aid Office provides the Office of Student Records the Return to Title IV student report in a timely manner for reporting to the Clearinghouse. The Registrar will make sure any student on the Return to Title IV list has a record on the National Clearinghouse for program - level and campus- level reporting. The Registrar will verify all students on the Return to Title IV list are showing correctly on the Clearinghouse upon submittal. The Director of Financial Aid and the Registrar will meet monthly to review the Return to Title IV lists provided to the Registrar match NSLDS to ensure status dates for all Return to Title IV students are accurately reflected. The Director of Financial Aid will also communicate any issues found with statuses on the NSLDS site with the Registrar. The Director of Financial Aid in collaboration with the Office of Student Records will work to obtain and review the SOC1 report from the third-party servicer (Clearing house) to ensure proper controls are implemented. Anticipated Completion Date – December 1, 2024 Contact Person(s) – DeeAnna Archuleta, SFA Director Connie Nyberg - Registrar

View Audit 331134

Finding 513130 (2024-002)

Significant Deficiency 2024

University of Western States

OR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Identifying Number: 2024-002 Finding: Special Tests: Enrollment Reporting – Improper Reporting of Withdrawal Date Applicable Regulation: Per the National Student Loan Data System (NSLDS) enrollment reporting guide (Section 4.4.3) when a student withdraws during a term, the effective date for the wi...

Identifying Number: 2024-002 Finding: Special Tests: Enrollment Reporting – Improper Reporting of Withdrawal Date Applicable Regulation: Per the National Student Loan Data System (NSLDS) enrollment reporting guide (Section 4.4.3) when a student withdraws during a term, the effective date for the withdrawn status is the withdrawal date used by the Institution in accordance with 34 CFR 668.22. Finding: 3 out of a total of 24 students tested for enrollment reporting in NSLDS had an incorrect date listed as the effective date of the student’s enrollment status. Summary: During our enrollment testing, we noted that the effective date of withdrawal in NSLDS for 3 students tested was incorrectly listed as the date of determination by UWS instead of the withdrawal date determined in accordance with 34 CFR 668.22. Internal controls in place did not identify the errors. Three students with incorrect enrollment reporting dates were due to the student’s out of school status treated by the relevant University department as an unofficial withdrawal instead of an official withdrawal for enrollment reporting purposes. The Dates of Determination were therefore used incorrectly. Corrective Action Planned or Taken: The University of Western States has updated its policy for all out of school and reporting for all out of school students. Additionally, an internal Decision Tree resource document has also been created for use when processing student withdrawals and reporting student statuses. All out of school students will have the appropriate out of school date selected and submitted for enrollment roster reporting based on the updated policy and the supplemental Decision Tree. UWS staff has also reviewed all students and confirms reporting statuses align with the updated policy. Contact Person: Michelle Miller, Senior Vice President of Enrollment Management mmiller10@tcsedsystem.edu Anticipated Completion Date: September 17, 2024

View Audit 331120

Finding 513129 (2024-001)

Significant Deficiency 2024

University of Western States

OR

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

Identifying Number: 2024-0001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 685.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may bo...

Identifying Number: 2024-0001 Finding: Eligibility – Determining Federal Direct Student Loan Awards Applicable Regulation: Per 34 CFR 685.203(b)(iii), in the case of a graduate or professional student for a period of enrollment beginning on or after July 1, 2012, the total amount the student may borrow for any academic year of study under the Unsubsidized Loan program may not exceed $8,500. Per 34 CFR 685.203(c)(2)(v), the additional amount that a student described in paragraph (c)(1)(i) of this section may borrow under the Direct Unsubsidized Loan Program for any academic year of student may not exceed the following: in the case of a graduate or professional student, $12,000. Finding: UWS improperly awarded 6 out of 6 students Unsubsidized Federal Direct Loans in excess of the maximum amount for one academic year of $20,500. Summary: During testing of eligibility, six out six students selected for testing within the Doctor of Naturopathic Program were overawarded Unsubsidized Federal Direct Loans. Eligibility testing was performed over 40 other students with no exceptions. We determined that UWS improperly awarded 6 out of 6 students Unsubsidized Federal Direct Loans in excess of the maximum amount for one academic year of $20,500. The total overawards accumulated to $119,443 in total loan funds. The students were awarded the higher annual Direct Unsubsidized Loan limits for certain graduate and professional health professions students. Schools may award the increased unsubsidized amounts to students who are enrolled at least half time in certain health professions programs. The programs must be accredited by specific accrediting agencies for students to qualify for additional unsubsidized loan amounts. The UWS Naturopathic Medicine Doctoral program has not yet achieved the required accreditation from The Council on Naturopathic Medical Education Corrective Action Planned or Taken: During the course of an internal audit of student awards in the Naturopathic Medicine Doctoral program it was determined that the required programmatic accreditation had not been achieved from the Council on Naturopathic Medical Education to qualify for the additional Health Professions unsubsidized loan eligibility. As a result of this finding a thorough audit was completed for all students that were enrolled in the program since the first class began in October of 2023. In total six students were identified, and awards were adjusted to the proper annual loan limit of $20,500. The Institution made students whole by forgiving any student balances that would have been paid by theover award amount. In addition, the software configuration was changed to ensure moving forward that students receive up to the proper maximum of $20,500 until proper accreditation is achieved. Contact Person: Michelle Miller, Senior Vice President of Enrollment Management mmiller10@tcsedsystem.edu Anticipated Completion Date: September 13, 2024

View Audit 331120 Questioned Costs: $1

Finding 513124 (2024-004)

Material Weakness 2024

Independent School District No 113

MN

Internal Control / Segregation of Duties Material Weakness Matching / Level of Effort / Earmarking

Finding 2024-004 Department of Education Federal Financial Assistance Listing 84.425 COVID-19 Education Stabilization Fund Special Tests – Wage Rate Requirement Material Weakness in Internal Control over Compliance Finding Summary: Eide Bailly LLP noted that the District did not satisfy the requirem...

Finding 2024-004 Department of Education Federal Financial Assistance Listing 84.425 COVID-19 Education Stabilization Fund Special Tests – Wage Rate Requirement Material Weakness in Internal Control over Compliance Finding Summary: Eide Bailly LLP noted that the District did not satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The District did not did not obtain proper support to ensure required certified payrolls were submitted. Responsible Individuals: Kevin Wellen, Superintendent Corrective Action Plan: The District will establish controls to follow all applicable requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: June 30, 2025

View Audit 331097

Finding 513120 (2024-002)

Significant Deficiency 2024

Hodges University, Inc.

FL

Student Financial Aid Reporting Significant Deficiency

Common Origination and Disbursement (COD) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for ...

Common Origination and Disbursement (COD) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: The previous corrective action plan failed to fully address this finding. Action taken in response to finding: Not Applicable- No corrective action will be made, Hodges University closed on August 25th, 2024. Name(s) of the contact person(s) responsible for corrective action: Not Applicable Planned completion date for corrective action plan: Not Applicable

View Audit 331081

Finding 513119 (2024-001)

Significant Deficiency 2024

Hodges University, Inc.

FL

Student Financial Aid Reporting Significant Deficiency

National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagreement ...

National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: The previous corrective action plan failed to fully address this finding. Action taken in response to finding: Not Applicable- No corrective action will be made, Hodges University closed on August 25th, 2024. Name(s) of the contact person(s) responsible for corrective action: Not Applicable Planned completion date for corrective action plan: Not Applicable

View Audit 331081

Finding 513115 (2024-002)

Significant Deficiency 2024

Community College of Beaver County

PA

Questioned Costs Special Tests & Provisions Student Financial Aid

Finding 2024-002: Student Financial Assistance Cluster - Refunds of Title IV Funds - Special Tests & Provisions Criteria: In accordance with 34 CFR 668.221, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which th...

Finding 2024-002: Student Financial Assistance Cluster - Refunds of Title IV Funds - Special Tests & Provisions Criteria: In accordance with 34 CFR 668.221, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student's withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution's determination that the student withdrew, the difference must be returned to the Title IV program within 45 days of the date of withdrawal. Condition: We examined 12 students who had withdrawn from the institution during a payment period or period of enrollment in which the recipient began attendance to ensure that the calculation and return of Title IV funds was done in accordance with 34 CFR 668.221. We noted that for one student who officially withdrew as of July 1, 2024, the calculation related to the return of Title IV funds was not done until October 7, 2024 and the return of funds did not occur until October 16, 2024. Controls in place were not operating effectively to ensure calculations and return of Title IV funds were done in the required time frame as outlined in 34 CFR 668.221. Cause: The College's process to identify students whose withdrawal requires a calculation of the return of Title IV funds is a manual process. The College does not have a process in place to verify that all students are identified and that all calculations and return of funds were done timely. Effect: The College had 1 student whose calculation and return of Title IV funds was not completed within the required timeframe and potentially could have additional students whose calculation and return of Title IV funds was also not completed in a timely manner. Repeat Finding: This is not a repeat finding. Questioned costs: Unknown Recommendation: We recommend that the College follow procedures in place to ensure all students who have withdrawn and require a calculation and potential return of Title IV funds are identified timely so that return of Title IV funds may be completed as required. View of Responsible Officials and Planned Corrective Action: Management agrees, see separate Corrective Action Plan Responsible Official: Executive Director of Finance and Financial Aid Corrective Action Plan: To ensure compliance with federal regulations regarding the Return to Title IV (R2T4) process, the College will implement the following steps to review students who begin attendance during a payment period or enrollment period, withdraw from the institution, and determine if the amount of Title IV aid earned by the student is less than the amount disbursed to the student or on their behalf as of the withdrawal date. Any excess Title IV aid will be returned to the appropriate program within 45 days of the withdrawal. The following procedures will be enacted: 1. Review of Withdrawal Reports: The Assistant Director of Financial Aid will regularly review the daily registration changes report to identify students who have withdrawn from the term. 2. Assessment of Title IV Aid: For each student identified as withdrawn, the Assistant Director of Financial Aid will verify whether Title IV aid was disbursed. If Title IV aid was received, the R2T4 calculation will be completed to determine the amount of aid earned. 3. Return of Unearned Title IV Funds: If the calculation indicates that the amount of Title IV aid disbursed exceeds the amount earned, the Assistant Director of Financial Aid will ensure that the appropriate funds are returned to the Title IV program through the Common Origination and Disbursement (COD) system, PowerFAIDS, and Jenzabar within 30 days of the student's withdrawal. 4. Notification and Coordination of Fund Return: If the College is required to return Title IV funds, the Assistant Director of Financial Aid will notify the Executive Director of Finance and Financial Aid, as well as the Chief Financial Officer, to ensure that funds are returned to the G5 system in a timely manner. 5. Daily Report Verification: The Assistant Director of Financial Aid will sign and date the daily registration changes report to confirm that it has been reviewed, the appropriate R2T4 calculation has been completed, and any necessary funds have been returned to the Title IV program. By implementing these steps, the College will ensure that it remains in full compliance with Title IV regulations, effectively manages financial aid disbursements, and returns unearned funds in a timely manner.

View Audit 331080 Questioned Costs: $1

Finding 513111 (2024-001)

Significant Deficiency 2024

Community College of Beaver County

PA

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Finding 2024-001: Student Financial Assistance Cluster-Student Eligibility Criteria: In accordance with 34 CFR 668.165 (a), before an institution disburses title IV program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent c...

Finding 2024-001: Student Financial Assistance Cluster-Student Eligibility Criteria: In accordance with 34 CFR 668.165 (a), before an institution disburses title IV program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV program and how and when those funds will be disbursed. Additionally, when Direct Loans are being credit to a student's account, the institution must notify the student, or parent in writing of the date and amount of disbursement as well as the timing and process by which a parent may cancel the loan. The notification process is often completed by either an award letter or college financing plan. Controls were not in place to ensure that college financing plans were emailed to all required students and/or parents. Condition: The college notifies students of Title IV funding by emailing a college financing plan to the student and/or parent. The college's manual process to identify students who should be notified of the Title IV funding did not identify three students out of forty tested that should have received a college financing plan. Cause: The college process to notify students and/or parents, involves a manual process to idently those who should receive a college financing plan. College financing plans are distributed by email to the student/ and or parent. The college does not have a system in place to verify that everyone who received Title IV funding received a College Financing Plan. Effect: The college did not provide notification via a College Financing Plan of Title IV funding to three of its students as required and potentially could have additional student that did not receive proper notification. Repeat Finding: This is not a repeat finding Recommendation: We recommend that the college implement procedures to ensure all students receive notification of Title IV funding as required under 34 CFR 668.165 (a). Questioned Cost: None View of Responsible Officials and Planned Corrective Action Plan: Responsible Party: Executive Director of Finance and Financial Aid Corrective Action Plan: To ensure that alt students and their parents are adequately informed of the funds they can expect to receive under each Title IV program, as well as the timing and process for disbursement, the college will implement the following actions: 1. College Financing Plan Notification: The college will incorporate the College Financing Plan notification into the packaging checklist, ensuring that it is completed when a student's financial aid package is finalized. 2. Updated College Financing Plan: A new College Financing Plan will be provided to students whenever there is an addition or adjustment to their awards. 3. Loan Disbursement Notification: Loan notification letters will be sent to students each time a Direct Loan is disbursed to their account, informing them of their right to cancel the loan if desired. 4. Quarterly Review: The Assistant Director of Financial Aid will conduct a quarterly review to ensure compliance with these procedures and verify that all necessary notifications are being issued as required.

View Audit 331080

Finding 513101 (2024-001)

Significant Deficiency 2024

Southwestern Law School

CA

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Southwestern Law School provides the following corrective action plan for the finding Moss Adams, LLP identified during the Southwestern's federal awards audit for the year ending June 30, 2024. Southwestern acknowledges the finding and recommendation from Moss Adams. Finding 2024-001 - Special Te...

Southwestern Law School provides the following corrective action plan for the finding Moss Adams, LLP identified during the Southwestern's federal awards audit for the year ending June 30, 2024. Southwestern acknowledges the finding and recommendation from Moss Adams. Finding 2024-001 - Special Tests and Provisions - Enrollment Reporting: Significant Deficiency in Internal Control over Compliance. Responsible Offices and Individuals: Improving procedures around enrollment reporting is the joint responsibility of the Registrar's Office and the Information Office. Eileen Zwiers, Registrar, and Sean Murphy, Chief Information Officer, are responsible for implementing the corrective action plan. Corrective Action Plan: Southwestern has prepared and implemented a new Enrollment Reporting Policy to ensure Title IV compliance when reporting changes in student enrollment status to the National Student Loan Data System. The policy outlines Southwestern's procedures for timely, accurate and complete through the National Student Clearinghouse. Additionally, the Financial Aid Office will conduct monthly audits of reported submissions directly from the National Student Loan Data System portal to ensure accuracy. The Financial Aid Office documents and securely stores these verified submissions to support the federal audit, in compliance with federal retention and data management policies. Anticipated Completion Date: Southwestern took immediate action to improve the policies and procedures around enrollment reporting. The remediation was appropriately completed September 2024. Sincerely, Eileen Zwiers Registrar Sean Murphy Chief Information Officer

View Audit 331074

Finding 513090 (2024-001)

None 2024

Mid-State Technical College

WI

Student Financial Aid Matching / Level of Effort / Earmarking

It is our understanding that the issue is occurring for many instituations and appears to be due to changes in processes at the National Clearinghouse. We will monitor steps taken and updates made to maintain awareness of any resolution to the issue made at the Clearinghouse. We will also develop ...

It is our understanding that the issue is occurring for many instituations and appears to be due to changes in processes at the National Clearinghouse. We will monitor steps taken and updates made to maintain awareness of any resolution to the issue made at the Clearinghouse. We will also develop an internal process to review student status effective dates as reflected in NSLDS and make updates as needed.

View Audit 331030

Finding 513088 (2024-003)

Material Weakness 2024

Village of Lexington

MI

Questioned Costs Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment § 200.317 § 200.318 § 200.319 § 200.327

The Village of Lexington hired, through a bid process, Townley Engineering to design needed water and sewer expansion and upgrades for the purpose of submitting to USDA for Water and waste disposal systems for rural communities grants in 2017. The Village was awarded funding and hos worked closely w...

The Village of Lexington hired, through a bid process, Townley Engineering to design needed water and sewer expansion and upgrades for the purpose of submitting to USDA for Water and waste disposal systems for rural communities grants in 2017. The Village was awarded funding and hos worked closely with USDA representatives as we have moved through the program. A budget for all costs was approved as part of the grant award. All invoices, including all engineering fees, are approved directly by our assigned Area Specialist. The project costs are currently all within budget. The Village of Lexington will ensure that engineering services follow correct procurement procedures in any future grant program it is awarded.

View Audit 331022 Questioned Costs: $1

Finding 513087 (2024-002)

Material Weakness 2024

Village of Lexington

MI

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Allowable Costs / Cost Principles

While the Village of Lexington followed current internal controls for all aspects of the federal awards granted, we did not adopt a document that covered all five compliance areas as outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. A wr...

While the Village of Lexington followed current internal controls for all aspects of the federal awards granted, we did not adopt a document that covered all five compliance areas as outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. A written policy and procedure document will be adopted by the Council by December 31, 2024.

View Audit 331022

Finding 513073 (2024-003)

Significant Deficiency 2024

Lincoln University

MO

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

Finding 2024-003 A plan has been developed to take corrective action regarding finding 2024-003 in our audit for the year ended June 30, 2024. Condition: Return of Title IV funds calculations were incorrectly performed during the year. Cause: The Financial Aid department does not have adequate proce...

Finding 2024-003 A plan has been developed to take corrective action regarding finding 2024-003 in our audit for the year ended June 30, 2024. Condition: Return of Title IV funds calculations were incorrectly performed during the year. Cause: The Financial Aid department does not have adequate processes and controls around return of funds to ensure calculations are accurate and return of funds are timely. Effect: Refund calculations completed were not correct and funds were not remitted to the Department of Education properly. Corrective Action Plan (CAP) and Anticipated Completion Date: This is the result of dates being entered into multiple departmental screens and a mismatch occurred. With the recent reorganization of the Registrar and Student Financial Services now combined with Admissions into a new Enrollment Management unit, greater coordination and control is gained and will improve reporting. The Registrar and Director of Student Financial Aid will oversee these changes under the direction of the Executive Director for Enrollment Management. This will be completed asap during Fiscal Year 2025 but no later than June 30, 2025. Responsible Party for Implementing CAP: Executive Director for Enrollment Management

View Audit 330993

Finding 513072 (2024-002)

Significant Deficiency 2024

Lincoln University

MO

Student Financial Aid Matching / Level of Effort / Earmarking Period of Performance

Finding 2024-002 A plan has been developed to take corrective action regarding finding 2024-002 in our audit for the year ended June 30, 2024. Condition: Out of 25 students tested, there were 16 students with Pell and Direct Loan attributes incorrectly reported to COD. Cause: The Financial Aid depar...

Finding 2024-002 A plan has been developed to take corrective action regarding finding 2024-002 in our audit for the year ended June 30, 2024. Condition: Out of 25 students tested, there were 16 students with Pell and Direct Loan attributes incorrectly reported to COD. Cause: The Financial Aid department does not have adequate processes and controls around return of funds to ensure reporting to COD is accurate. Effect: COD reporting was not properly completed for Direct Loan and Pell Grant recipients. Corrective Action Plan (CAP) and Anticipated Completion Date: The Colleague system uses the dates that are entered into parameter screens when the academic year is set up. Those dates from the setup screen are used in setting up the information per student to be sent to COD. It is likely that these preliminary dates were updated as they became more fixed. This would result in differences in individual record dates based on timing of data entry. With the gathering of offices under the Enrollment Management umbrella this fiscal year, greater coordination and control is gained and will control entry and maintenance of system dates. The Registrar will also look at creating a centralized change log for term dates for reference between the two staff areas. The Registrar and Director of Student Financial Aid will oversee these changes under the direction of the Executive Director of Enrollment Management. This will be completed asap during Fiscal Year 2025 but no later than June 30, 2025. Responsible Party for Implementing CAP: Executive Director of Enrollment Management

View Audit 330993

Finding 513071 (2024-001)

Significant Deficiency 2024

Lincoln University

MO

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding 2024-001 A plan has been developed to take corrective action regarding finding 2024-001 in our audit for theyear ended June 30, 2024. Condition: Out of 40 students tested, there were 39 students with enrollment status changes during the year that were not communicated to the National Student...

Finding 2024-001 A plan has been developed to take corrective action regarding finding 2024-001 in our audit for theyear ended June 30, 2024. Condition: Out of 40 students tested, there were 39 students with enrollment status changes during the year that were not communicated to the National Student Loan Data System (NSLDS) or were incorrectly reported. Cause: The Registrar’s Office and the Enrollment Services Technical Coordinator do not have adequate processes and controls around enrollment reporting to ensure reporting is accurate and timely. Effect: NSLDS was not properly notified of student enrollment status changes of Direct Loan and Pell Grant recipients. Corrective Action Plan (CAP) and Anticipated Completion Date: The Registrar's Office reports student enrollment status to the National Student Clearinghouse according to the predetermined reporting schedule. As of this fiscal year, the financial aid and registrar offices have been placed under a new Enrollment Management umbrella that will allow and require careful coordination of term, enrollment, and financial aid issues. The Registrar's Office has created and made available a procedural guide for running and submitting reports to make sure program length and other data submitted is accurate and timely. The Registrar will oversee these changes under the direction of the Executive Director of Enrollment Management. This will be completed asap during Fiscal Year 2025 but no later than June 30, 2025. Responsible Party for Implementing CAP: Executive Director of Enrollment Management

View Audit 330993

Finding 513063 (2024-001)

Significant Deficiency 2024

Tahquamenon Area Schools

MI

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.326

Corrective Action: The District will be proactive with adherence to all federal requirements, including, but not limited to prevailing wage rate provisions with any contracts moving forward. Additionally, the district will be aware of the need to adhere to these federal requirements when funding str...

Corrective Action: The District will be proactive with adherence to all federal requirements, including, but not limited to prevailing wage rate provisions with any contracts moving forward. Additionally, the district will be aware of the need to adhere to these federal requirements when funding streams are blended. The district has already started communication to relay that federal prevailing wage rates should have been utilized. Responsible Person: Nicole Eilola, Shared Services Business Manager & Stacy Price, Superintendent. Anticipated Completion Date: Immediate

View Audit 330975

Finding 513041 (2024-002)

Significant Deficiency 2024

Nba/gpva Accessible Housing II Inc.

MO

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking

Statement of condition 2024-002: The Corporation did not make the required monthly deposits to the reserve for replacements account and did not repay the full PRAC loan. The reserve for replacements fund is underfunded by $15,598 as of June 30, 2024. Recommendation: Management should deposit $15,59...

Statement of condition 2024-002: The Corporation did not make the required monthly deposits to the reserve for replacements account and did not repay the full PRAC loan. The reserve for replacements fund is underfunded by $15,598 as of June 30, 2024. Recommendation: Management should deposit $15,598 into the reserve for replacements. Action(s) taken or planned on the finding: Agree. On September 11, 2024, management transferred $598 to the reserve for replacements. As of the report date, the remaining PRAC loan of $15,000 has not been repaid.

View Audit 330935 Questioned Costs: $1

Finding 513006 (2024-001)

Significant Deficiency 2024

City of High Point, North Carolina

NC

Subrecipient Monitoring Period of Performance Reporting

Finding 2024-001, Significant Deficiency - Reporting In Fiscal Year 2023-24, the Transportation Department submitted reports for the RAISE grant to the NCDOT for four quarters without prior review from the Finance Department. This was corrected with the June 2024 quarterly report, and the grant liai...

Finding 2024-001, Significant Deficiency - Reporting In Fiscal Year 2023-24, the Transportation Department submitted reports for the RAISE grant to the NCDOT for four quarters without prior review from the Finance Department. This was corrected with the June 2024 quarterly report, and the grant liaison is now following the City's policy. The liaison prepares the report and sends it to his manager for review and approval. Then it is routed to the Senior Financial Grants Analyst for review. The Accounting Manager reviews and approves the report before it is submitted to the NCDOT. The Transportation Department has been made aware that the City needs to follow the grants policy with all grants. Implemented prior to report date. Greg Venable, Transportation Director, Responsible Person 11/26/24 Bobby Fitzjohn, Financial Services Director 11/26/24

View Audit 330903

Finding 513001 (2024-004)

Significant Deficiency 2024

Universidad Carlos Albizu, Inc.

PR

Student Financial Aid Eligibility Reporting

Finding No. 2024-004 Delay in Direct Loan Adjustment After Enrollment Cancellation Condition Found During our eligibility test, we identified a situation in which a student's enrollment was canceled after Pell and Direct Loan funds had already been credited to the student's account. Even though the ...

Finding No. 2024-004 Delay in Direct Loan Adjustment After Enrollment Cancellation Condition Found During our eligibility test, we identified a situation in which a student's enrollment was canceled after Pell and Direct Loan funds had already been credited to the student's account. Even though the Pell Grant adjustment and return to COD were completed promptly, the adjustment for the Direct Loan was only made after the auditor discovered that the loan had not been properly adjusted and returned to the Department of Education. Corrective Action Plan We will thoroughly explore system capabilities, and a targeted training session in the Ellucian software will be developed and scheduled to directly address the identified deficiency. All Student Financial Aid Officers will be required to complete this mandatory training. Additionally, comprehensive internal monitoring exercises will be conducted for all R2T4 events to ensure full compliance and process integrity. Name(s) of the Contact Person(s) Responsible for Corrective Action Doris Quero, Senior Financial Aid director Carmen Rivera Laboy, Title IV Compliance Coordinator Eliezer Rodriguez, Ellucian Specialist Anticipated Completion Date Will be completed on or before December 15, 2024.

View Audit 330883

Finding 513000 (2024-003)

Significant Deficiency 2024

Universidad Carlos Albizu, Inc.

PR

Student Financial Aid Subrecipient Monitoring Reporting

Finding No. 2024-003 Late R2T4 reimbursement to ED Condition Found In testing compliance with the return of Title IV funds requirement, we noted three (3) cases, or eight percent (8%), of the sample selected, in which the University failed to return the total corresponding refund within 45 days from...

Finding No. 2024-003 Late R2T4 reimbursement to ED Condition Found In testing compliance with the return of Title IV funds requirement, we noted three (3) cases, or eight percent (8%), of the sample selected, in which the University failed to return the total corresponding refund within 45 days from the date the University determined that the student withdrew, dropped-out, or failed to attend to the University. Corrective Action Plan The institution will enhance the total withdrawal process by assigning a dedicated financial aid officer to each campus, responsible for overseeing all funds. This officer will be solely accountable for determining whether a withdrawal is official or unofficial, executing the Return of Title IV (R2T4) process, and coordinating with the fiscal department to ensure timely completion of refunds. As a further safeguard, the Title IV Compliance Coordinator will rigorously monitor the effectiveness of this corrective action plan and ensure ongoing compliance. Name(s) of the Contact Person(s) Responsible for Corrective Action Doris Quero, Senior Financial Aid Director Carmen Rivera Laboy, Title IV Compliance Coordinator Anticipated Completion Date Will be completed on or before January 15, 2025.

View Audit 330883

Finding 512999 (2024-002)

Significant Deficiency 2024

Universidad Carlos Albizu, Inc.

PR

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

Finding No. 2024-002 Late Refund Issuance Condition Found During our evaluation of compliance with these requirements, we noted one (1) instance, or six percent (6%) of the sample selected, in which the University failed to return the corresponding refund within 14 days’ time frame from the date the...

Finding No. 2024-002 Late Refund Issuance Condition Found During our evaluation of compliance with these requirements, we noted one (1) instance, or six percent (6%) of the sample selected, in which the University failed to return the corresponding refund within 14 days’ time frame from the date the University determined that the student had a Federal Student Aid (FSA) credit balance. Forty-one (41) days passed between the date the University identified an FSA credit balance for the student and the actual refund to the student. Corrective Action Plan We will aggressively pursue systems automation alternatives to streamline operations and enforce interdepartmental collaboration to ensure strict compliance with deadlines. Additionally, we will deliver targeted cash management training, with a strong focus on rigorously reviewing and optimizing refund processing procedures. Name(s) of the Contact Person(s) Responsible for Corrective Action Héctor L. Peña, Director of Finance Ramón L. Menéndez, CFO Dr. Antonio Llorens, CIO Anticipated Completion Date Will be completed on or before January 15, 2025.

View Audit 330883

Finding 512997 (2024-001)

Significant Deficiency 2024

Grand Traverse Academy

MI

Internal Control / Segregation of Duties Special Tests & Provisions Procurement, Suspension & Debarment

Findings and Recommendations: 2024 – 001: Finding Type: Noncompliance and significant weakness in internal control over compliance. Condition: The Academy’s existing internal controls did not prevent or detect the noncompliance with provisions of the Davis-Bacon Act for construction contracts in exc...

Findings and Recommendations: 2024 – 001: Finding Type: Noncompliance and significant weakness in internal control over compliance. Condition: The Academy’s existing internal controls did not prevent or detect the noncompliance with provisions of the Davis-Bacon Act for construction contracts in excess of $2,000. Recommendation: The Academy should review and revise its internal controls and procedures to ensure prevention and detection of future noncompliance when entering into construction contracts that utilize federal funding of which 2 CFR Part 176 Subpart C applies. Corrective Action Plan: The Academy is aware of the finding and is implementing procedures to prevent further noncompliance in the future. More effective internal control procedures surrounding the bid process are being put into place. Additionally, the Academy will revise bid documents to ensure all applicable provisions of the Davis-Bacon Act are met. Responsible Department: Business department and superintendent. Responsible Person: Michelle Floering, Superintendent Planned Completion Date (TBD or Date): January 1, 2025.

View Audit 330877

Finding 512979 (2024-001)

None 2024

Certell, INC

IN

Questioned Costs Student Financial Aid Special Tests & Provisions

Finding 2024-001: Unpaid Credit Balance – As the funds were used to pay prior academic year tuition, it is recommended the Institution increase controls over credit balances. Comments on Finding and Recommendation(s): HJC concurs with the finding. Student had requested funds be used to pay prior y...

Finding 2024-001: Unpaid Credit Balance – As the funds were used to pay prior academic year tuition, it is recommended the Institution increase controls over credit balances. Comments on Finding and Recommendation(s): HJC concurs with the finding. Student had requested funds be used to pay prior year balance, but we should not have exceeded the $200 maximum allowed by regulation. Actions Taken or Planned: FA staff has reviewed the regulatory restrictions on prior-year payments to ensure that, even at a student's request, we do not exceed the $200 maximum allowed. Excess funds retained have been returned to the student.

View Audit 330798 Questioned Costs: $1

Finding 512976 (2024-003)

None 2024

Certell, INC

IN

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Finding 2024-003: Incorrect Refund Calculation – It is recommended the Institution refund $50 to the Department of Education and increase controls over refund calculations. Comments on Finding and Recommendation(s): HJC concurs with the finding of the audit team. Actions Taken or Planned: The $5...

Finding 2024-003: Incorrect Refund Calculation – It is recommended the Institution refund $50 to the Department of Education and increase controls over refund calculations. Comments on Finding and Recommendation(s): HJC concurs with the finding of the audit team. Actions Taken or Planned: The $50 will be returned to the Department of Education. The refund was calculated correctly but posted incorrectly. HJC will be responsible for processing R2T4 calculations for aid packaged prior to the engagement of GFAS, and GFAS will process HJC R2T4 refunds required going forward.

View Audit 330798 Questioned Costs: $1

Finding 512974 (2024-005)

Significant Deficiency 2024

Certell, INC

IN

Student Financial Aid Reporting Significant Deficiency

Finding 2024-005: Untimely Enrollment Status Reporting – It is recommended the Institution increase controls over enrollment reporting. Comments on Finding and Recommendation(s): After the transition to Campus Cafe had begun, it was determined that they did not have the capability of importing NSL...

Finding 2024-005: Untimely Enrollment Status Reporting – It is recommended the Institution increase controls over enrollment reporting. Comments on Finding and Recommendation(s): After the transition to Campus Cafe had begun, it was determined that they did not have the capability of importing NSLDS enrollment reporting reports as our previous system had, so FA staff has been updating enrollment information manually. Actions Taken or Planned: HJC has initiated discussions with the Clearinghouse for NSLDS reporting purposes. As a recent ECAR is required to complete the contract, we are currently waiting on an updated EApp to be processed to complete the process.

View Audit 330798

Corrective Action Plans

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