Corrective Action Plans

Finding 526901 (2024-003)

Material Weakness 2024

Clark-Pleasant Community School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Summary of Finding: The non-public proportionate share expenditures for the preschool grant was not spent in full. Additionally, the corporation had not filed a waiver to move the funds to the corporation program. Contact Person Resp...

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Summary of Finding: The non-public proportionate share expenditures for the preschool grant was not spent in full. Additionally, the corporation had not filed a waiver to move the funds to the corporation program. Contact Person Responsible for Corrective Action: Austin Fruits Contact Phone Number and Email Address: 317-535-7579; afruits@cpcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: We have formulated a plan to include the business office in Non-pub meetings moving forward so that open funds are being clearly communicated with the Non-public schools. If the funds are not spent, we will apply for the waiver to move the budget to the corporation. Anticipated Completion Date: March 1, 2025

View Audit 346022

Finding 526895 (2024-003)

Material Weakness 2024

Southwestern Jefferson County Consolidated School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: Finding 2024-003 indicates a failure to design, nor implemented, a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data collection repor...

FINDING 2024-003 Finding Subject: Education Stabilization Fund – Reporting Summary of Finding: Finding 2024-003 indicates a failure to design, nor implemented, a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual data collection reports were completely and accurately submitted. As a result of these inadequate internal control systems, the corporation did not prevent, detect, and/or correct errors prior to submission. It has been recommended that a system of internal control be implemented which would include multiple individuals with a segregation of duties. This system should include signatures of each person involved along with their role in the internal control system process. Contact Person Responsible for Corrective Action: Jason R. Watson, Assistant Superintendent Contact Phone Number and Email Address: 812-866-6244 (o), 812-599-0627 (c), jwatson@swjcs.us Views of Responsible Officials: We concur with this audit finding. Description of Corrective Action Plan: Action taken to remedy finding 2024-003 includes, but is not limited to, the following: 􀁸 Beginning immediately, the grant coordinator will prepare the reports for any future ESSER reports. 􀁸 The reports prepared will be shared with Assistant Treasurer 1 for the initial review. Assistant Treasurer 1 will complete his/her review, adding comments and suggestions as needed. 􀁸 If corrections to the report are required: o Assistant Treasurer 1 and/or Assistant Treasurer 2 will decline to sign and discuss the changes needed with the grant coordinator. o The Grant Coordinator will then create a second DocuSign Envelope, with the needed corrections and begin the process again. 􀁸 If no corrections are needed, the Chief Financial Officer, designated as monitor, will confirm that both the Food Service Director and Assistant Treasurer reviews have been completed and indicates as such via eSignatures. 􀁸 Anticipated Completion Date: March 1, 2025􀀃

View Audit 345996

Finding 526891 (2024-002)

Material Weakness 2024

Southwestern Jefferson County Consolidated School Corporation

IN

School Nutrition Programs Allowable Costs / Cost Principles Cash Management § 200.303

FINDING 2024-002 Finding Subject: Child Nutrition Cluster- Special Tests and Provisions-Non-Profit School Food Service Accounts Summary of Finding: Finding 2024-002 indicates a failure to maintain adequate internal control systems with regards to requirements related to the grant agreement and the S...

FINDING 2024-002 Finding Subject: Child Nutrition Cluster- Special Tests and Provisions-Non-Profit School Food Service Accounts Summary of Finding: Finding 2024-002 indicates a failure to maintain adequate internal control systems with regards to requirements related to the grant agreement and the Special Tests and Provisions-Non-Profit School Food Service Accounts compliance requirement. As a result of these inadequate internal control systems, the corporation did not prevent, detect, and/or correct errors prior to submission. It has been recommended that a system of internal control be implemented which would include multiple individuals with a segregation of duties. This system should include signatures of each person involved along with their role in the internal control system process. Contact Person Responsible for Corrective Action: Katie King, Food Services Director Contact Phone Number and Email Address: 812-866-6254, kking@swjcs.us Views of Responsible Officials: We concur with this audit finding. Description of Corrective Action Plan: Action taken to remedy finding 2024-002 includes, but is not limited to, the following: 􀁸 Beginning immediately, Assistant Treasurer 1 will prepare a DocuSign envelope monthly with the following financial reports to be reviewed: o Appropriation Report o Expenditure Report o Revenue Report o Fund Detail Report o Fund Report 􀁸 The DocuSign Envelope will be routed to the Food Services Director, for the initial review. 􀁸 The Food Service Director will complete his/her review, adding comments and suggestions as needed. An eSignature will confirm that the data appears accurate. 􀁸 The DocuSign Envelope will then be routed to Assistant Treasurer 2 for an additional review. 􀁸 Assistant Treasurer 2 will complete his/her review, adding comments and suggestions as needed. An eSignature will confirm that the data appears accurate. 􀁸 If corrections to the report are required: o The Food Service Director and/or Assistant Treasurer 2 will decline to sign and discuss the changes needed with Assistant Treasurer 1. o Assistant Treasurer 1 will then create a second DocuSign Envelope, with the needed corrections and begin the process again. 􀁸 If no corrections are needed, the Chief Financial Officer, designated as monitor, will confirm that both the Food Service Director and Assistant Treasurer 2 reviews have been completed and indicates as such via eSignatures. 􀁸 After the above steps have been taken, the report will be submitted 􀁸 The Grant Coordinator indicates its completion by eSignature in the appropriate location. INDIANA STATE BOARD OF ACCOUNTS 33 􀀃 􀀃 Anticipated Completion Date: March 1, 2025

View Audit 345996

Finding 526882 (2024-001)

Significant Deficiency 2024

Westfield State University

MA

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

Corrective Action Plan: The Registrar’s Office will conduct a comprehensive review of the scheduled enrollment reporting dates currently listed in the National Student Clearinghouse (NSC). This review will focus specifically on calculating a fifty-day schedule of enrollment reporting to ensure enrol...

Corrective Action Plan: The Registrar’s Office will conduct a comprehensive review of the scheduled enrollment reporting dates currently listed in the National Student Clearinghouse (NSC). This review will focus specifically on calculating a fifty-day schedule of enrollment reporting to ensure enrollment reports are submitted within the required time frame as mandated by the National Student Loan Data System (NSLDS). The reporting date adjustment will allow additional days for NSC to report to NSLDS within the required sixty-day reporting period to maintain compliance. NSC emails a “Delivery Receipt” each time an enrollment report is submitted to the Registrar, Associate Registrar and Technology Support Specialist in the Registrar’s Office. The Executive Director of Institutional Research and Assessment will be added to the email notification and will have access to review enrollment report submissions. The Registrar will also be creating a calendar with a schedule of when the NSLDS enrollment files will be sent to help ensure the files are submitted on-time. Timeline for Implementation of Corrective Action Plan: The review of scheduled enrollment dates will begin immediately. Adjustments to the dates will be made as needed to ensure adherence to the sixtyday reporting requirement. Contact Person: Monique Lopez, Registrar and Simone Backstedt, Director, Financial Aid

View Audit 345977

Finding 526875 (2024-001)

Significant Deficiency 2024

Sweet Briar Institute

VA

Student Financial Aid Special Tests & Provisions Reporting

Individual/s Responsible for Corrective Action Plan: Susan Kennon, Registrar Corrective Action Plan: The Institute agrees with the finding. The sudden departure of the former registrar in early September 2023 placed a gap in services and processes on the newly appointed registrar that took severa...

Individual/s Responsible for Corrective Action Plan: Susan Kennon, Registrar Corrective Action Plan: The Institute agrees with the finding. The sudden departure of the former registrar in early September 2023 placed a gap in services and processes on the newly appointed registrar that took several months to resolve. There was a lack of continuity in reporting due to technological deficiencies that required a team of resources beyond the one office. Once technological deficiencies were addressed, reporting had not been performed since September 2023 and the first enrollment report submitted under the new registrar caused data issues as it was for a new semester (Spring 2024). The corrective action plan includes: • Continued student information system (“SIS”) training with Ellucian-Banner software personnel to include permissions-based access to data and software upgrades. o Access to data is permissions-based and our IT department monitors this to make sure registrar staff has the correct access. • Sweet Briar has authorized additional training for Registrar staff who are not familiar with the Banner SIS to ensure proper coding of student records. • Working with the National Student Clearinghouse (“NSC”) to resolve issues with data uploads and training on how to resolve errors. • Consistent reporting per the NSC transmission schedule so data is reported correctly and timely. • Consistent reporting of separated students (withdrawn and graduated) within 30 days of departure. • The registrar has conducted several reviews of SIS databases and tables to ensure the data is consistent with the Crosswalk provided by the National Student Clearinghouse, especially in enrollment status based on hours taken in a semester. • Creation of a manual with step-by-step directions on how to generate a report, submit the data to the NSC, and how to resolve errors on the NSC portal so the loss of a key person in the registrar’s office assures compliance with reporting and continuity. Anticipated Completion Date: Several training sessions have been completed by the Registrar since February 2024. Additional training on reporting was completed on March 4, 2025, and another training is scheduled for late March 2025. The assistant registrar has been trained on how to generate a report and resolve issues to allow for continuity in reporting. A recent review of processes (February 2025) helped us discover that there was a coding issue that was incorrectly reporting graduated students as withdrawn in subsequent reports. At least one student in this audit had this finding. Training and review of records is ongoing.

View Audit 345973

Finding 526872 (2024-002)

Material Weakness 2024

South Montgomery Community School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.303

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kristin Charles, CFO and HR Director Contact Phone Number and Email Address: (765) 866-0203 and Kristin.charles@southmont.k12.in.us Views of Responsible Officials: We...

FINDING 2024-002 Finding Subject: COVID-19 Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kristin Charles, CFO and HR Director Contact Phone Number and Email Address: (765) 866-0203 and Kristin.charles@southmont.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: ESSER Yearly Reports to be completed by CFO and printed and will review with the superintendent. Anticipated Completion Date: ESSER III Annual Report due April 2025

View Audit 345971

Finding 526869 (2024-002)

Significant Deficiency 2024

National Museum of Women in the Arts

DC

Questioned Costs Subrecipient Monitoring Reporting § 200.328

Views of Responsible Officials: The delay in submitting the report was primarily due to oversight. To ensure that similar delays do not occur in the future, we are implementing the following measures: 1. Improved Project Management: We will review our internal processes and set clearer timelines for...

Views of Responsible Officials: The delay in submitting the report was primarily due to oversight. To ensure that similar delays do not occur in the future, we are implementing the following measures: 1. Improved Project Management: We will review our internal processes and set clearer timelines for report preparation. We will assign specific personnel responsible for ensuring that all required reports are submitted on time. 2. Enhanced Communication: We will improve communication with all departments involved in the report preparation process to ensure that necessary information is gathered and validated promptly. 3. Monitoring Progress: We will establish a more robust internal monitoring process to track the progress of report preparation and ensure timely submission.

View Audit 345969

Finding 526865 (2024-001)

Significant Deficiency 2024

Bentley University

MA

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

The finding has been remediated concerning status changes during required academic periods as of June 30, 2024. The University has improved staff access for enrollment reporting to the National Student Clearinghouse (NSC) to meet the compliance requirements of NSLDS for status changes reported durin...

The finding has been remediated concerning status changes during required academic periods as of June 30, 2024. The University has improved staff access for enrollment reporting to the National Student Clearinghouse (NSC) to meet the compliance requirements of NSLDS for status changes reported during the semester the student is enrolled. The University continues to adjust reporting timelines to ensure accurate and timely reporting of status changes to NSLDS for status changes reported outside of required academic periods in which the student is enrolled.

View Audit 345963

Finding 526863 (2024-002)

Significant Deficiency 2024

King's College

PA

Student Financial Aid Reporting Significant Deficiency

Views of Responsible Officials and Planned Corrective Actions: The College agrees to the finding. An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis. The College has reviewed its polic...

Views of Responsible Officials and Planned Corrective Actions: The College agrees to the finding. An error report from the Clearinghouse had been sent to the College with respect to the affected students' enrollment statuses and was not addressed on a timely basis. The College has reviewed its policy and will add a secondary review process to its enrollment reporting to address all received error reports. The Assistant Registrar will address all error reports timely and make the appropriate corrections to the enrollment reporting. Since the NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients, as the independent check and balance, the Financial Aid Office will review the NSLDS error reports for enrollment discrepancies and collaborate with the Registrar's office for their timely correction in the Clearinghouse.

View Audit 345962

Finding 526862 (2024-001)

Significant Deficiency 2024

King's College

PA

Questioned Costs Student Financial Aid Subrecipient Monitoring § 200.303

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. A corrected ISIR came in after verification was complete and instead of going through the normal process of being reviewed and repackaged by the director, the student record was accidentally filed awa...

Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. A corrected ISIR came in after verification was complete and instead of going through the normal process of being reviewed and repackaged by the director, the student record was accidentally filed away. This happened due to human error. We have a process in place to monitor corrected ISIR transactions to ensure that the EFC (SAI effective for award year 2024-25 and later) agrees with our documentation. The student record is then given to the director for final review and repackaging. We have added an additional step now whereby the Pell Grant administrator also reviews the output report for ISIR imports on a weekly basis.

View Audit 345962 Questioned Costs: $1

Finding 526847 (2024-003)

Material Weakness 2024

North Central Behavioral Health Systems, Inc.

IL

Cash Management Matching / Level of Effort / Earmarking § 200.303

Identifying Number: 2024-003 Finding: NCBHS management stated that cash reimbursement requests were reviewed prior to submission to the grantor, but there was no verifiable evidence that reviews took place until March 2024. Internal controls over Federal awards that are not properly designed increas...

Identifying Number: 2024-003 Finding: NCBHS management stated that cash reimbursement requests were reviewed prior to submission to the grantor, but there was no verifiable evidence that reviews took place until March 2024. Internal controls over Federal awards that are not properly designed increases the risk of noncompliance with the types of compliance requirements identified as subject to audit in the OMB Compliance Supplement. Corrective Actions Taken or Planned: This issue is related to the previous year finding 2023-003. The monthly reimbursement requests were not being reviewed by the CEO or CFO before being sent to the State of Illinois. This process changed in March 2024 when it was brought to our attention by RSM. Since that time all reimbursement requests for both State of Illinois and federal grants are reviewed and approved by the CEO or CFO before they are sent to the appropriate parties for payment. In addition, NCBHS will review the “Compliance Supplement” issued by the Office of Management and Budget to help in the guidance of the requirements for the single audit.

View Audit 345941

Finding 526832 (2024-008)

Material Weakness 2024

New Prairie United School Corporation

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

FINDING 2024‐008 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Wage Rate Requirements Summary of Finding: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests ...

FINDING 2024‐008 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Wage Rate Requirements Summary of Finding: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions ‐ Wage Rate Requirements compliance requirement. The School Corporation did not ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. One construction contract was paid from the COVID‐19 ‐ Education Stabilization Fund grant funds, totaling $1,278,001, during the audit period. This construction contract was subject to the wage rate requirements; however, the contract did not have the required prevailing wage rate clause included in the contract, nor were certified payrolls submitted by the contractor timely. Contact Person Responsible for Corrective Action: Jackie Conley Contact Phone Number and Email Address: 574‐654‐7273 jaclynconley@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Grants Manager will ensure future projects with construction contracts will have a prevailing wage clause while also monitoring payroll to verify compliance. Anticipated Completion Date: March 2025

View Audit 345909

Finding 526827 (2024-007)

Material Weakness 2024

New Prairie United School Corporation

IN

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2024‐007 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School...

FINDING 2024‐007 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I report, two ESSER II reports, and two ESSER III reports, for a total of five reports. The School Corporation did not have a documented review of any of the annual reports submitted to the Indiana Department of Education. Contact Person Responsible for Corrective Action: Jackie Conley Contact Phone Number and Email Address: 574‐654‐7273 jaclynconley@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Future reporting will be prepared by the Grants Manager but reviewed by the Corporation Treasurer or Curriculum Director before submission. Anticipated Completion Date: March 2025

View Audit 345909

Finding 526817 (2024-004)

Significant Deficiency 2024

New Prairie United School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2024‐004 Finding Subject: Special education Cluster (IDEA) ‐ Earmarking Summary of Finding: Due to the timing of the Cooperative’s corrective action, the non‐public expenditures spent did not meet the earmarking requirements for grant award number 22611‐053‐PN01. From the beginning of the gr...

FINDING 2024‐004 Finding Subject: Special education Cluster (IDEA) ‐ Earmarking Summary of Finding: Due to the timing of the Cooperative’s corrective action, the non‐public expenditures spent did not meet the earmarking requirements for grant award number 22611‐053‐PN01. From the beginning of the grant awards until March 2023, total grant expenditures were posted as expended. The non‐public proportionate share expenditures were determined by applying a percentage to the non‐public school budgeted expenditures. Beginning in March 2023, the Cooperative began tracking expenditures by member school for the non‐public services. As such, we were unable to identify if the minimum amount per the grant award was expended and properly reported to IDOE from the beginning of the grant awards through March 2023, as required. Contact Person Responsible for Corrective Action: Tim Scott Contact Phone Number and Email Address: 574‐654‐7273 tscott@npusc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Beginning in March 2023, the Cooperative began tracking expenditures by member school for the nonpublic services instead of applying a percentage. The minimum amount per the grant award will be expended and properly report to the IDOE. New Prairie also plans on requesting biannual reports from the Cooperative on expenditures for nonpublic services. Anticipated Completion Date: March 2023

View Audit 345909

Finding 526815 (2024-001)

None 2024

Midway University, Inc.

KY

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

Management acknowledges this finding and will change the procedure to verify enrollment status changes to ensure that there are no issues of files not transferring from the National Student Clearinghouse (NSC) to the National Student Loan Data System (NSLDS). Currently, the Financial Aid Director co...

Management acknowledges this finding and will change the procedure to verify enrollment status changes to ensure that there are no issues of files not transferring from the National Student Clearinghouse (NSC) to the National Student Loan Data System (NSLDS). Currently, the Financial Aid Director confirms status changes in NSLDS at day 50, and as part of the process change a second status check will occur with a separate Financial Aid staff member before the 60 day timeframe has passed to ensure that no students were missed in the file transfer or that status changes occurred after the initial check. This plan will be overseen by Erin Teves, Director of Financial Aid, and will be implemented immediately.

View Audit 345905

Finding 526814 (2024-002)

Significant Deficiency 2024

Columbia College

MO

Student Financial Aid Reporting Special Tests & Provisions

2024‐002 – Reporting Student Withdrawal Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordan...

2024‐002 – Reporting Student Withdrawal Date in the National Student Loan Data System (NSLDS) (Significant Deficiency) Criteria: The College is responsible for submitting timely, accurate and complete responses to Enrollment Reporting roster files and for maintaining proper documentation in accordance with 34 CFR Section 685.309(a)(2). Condition: From a population of 208 students that withdrew officially or unofficially during the fiscal year, we tested 22 and noted that withdrawal dates were submitted untimely for all 22 students and the incorrect date was reported for six students. Action Taken: We concur with this finding. The Office of the Registrar reports the withdrawal date via Clearing House. However, the withdrawal date is overridden by any subsequent enrollment updates. Moving forward, the Office of Financial Aid will ensure that withdrawal dates for R2T4 calculations are accurately reported. The updated enrollment information will be saved in the student’s electronic file to maintain proper documentation and compliance. Responsible Party: Sharon Murphy, Registrar Point of Contact: Sharon Murphy, Registrar (smurphy@columbiasc.edu) Expected date of correction: January 2025

View Audit 345900

Finding 526788 (2024-004)

Significant Deficiency 2024

Municipality of Cayey

PR

Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 ...

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Rolando Ortiz Velázquez, Mayor Contact Person: Mrs. Eunice Diaz, Finance and Budget Director Phone: (787) 738-3211 Original Finding Number: 2024-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action : In this case, for the year 2024-2025, it has already been verified that ACUDEN complies with the provisions of the contract. As an internal control and prevention measure, the budget sent by the Agency will be verified with the percentages (%) established in the contract. If they do not match, ACUDEN will be asked to amend the budget. Implementation Date: During fiscal year 2024-2025. Responsible Person: Mrs. Natasha Vásquez Federal Programs Director

View Audit 345831

Finding 526763 (2024-006)

Significant Deficiency 2024

Safford Unified School District No. 1

AZ

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

2024-006: PROVISIONS OF THE DAVIS-BACON ACT Program: Education Stabilization Fund Federal Assistance Listing Number: 84.425U Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESIII-111217-01A Questioned Costs: $-0- Type of Finding: N...

2024-006: PROVISIONS OF THE DAVIS-BACON ACT Program: Education Stabilization Fund Federal Assistance Listing Number: 84.425U Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESIII-111217-01A Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Repeat Finding: This is not a repeat finding. Condition/Context: During our testing of two of 2 contractors, we noted the District did not have adequate internal controls designed to ensure contractors were in compliance with applicable Davis-Bacon Wage Rate requirements. The District did not retain documentation supporting indication of certified payrolls being submitted in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Corrective Action: The District will review its process for retaining wage rate requirements and ensure all minor construction projects are having these wage rate requirements maintained. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Frank Gutierrez, Director of Support Operations

View Audit 345765

Finding 526757 (2024-001)

None 2024

Washington University

MO

Student Financial Aid Special Tests & Provisions Reporting

Management concurs with the finding and is implementing the following corrective actions: -Disbursements to or on behalf of students: Student Financial Services (SFS) has updated the Financial Assistance Terms and Conditions, which is required to be certified annually by all students receiving aid,...

Management concurs with the finding and is implementing the following corrective actions: -Disbursements to or on behalf of students: Student Financial Services (SFS) has updated the Financial Assistance Terms and Conditions, which is required to be certified annually by all students receiving aid, to include consent to receive electronic communications. In accordance with the requirements of the Clery Act, the Annual Campus Security and Fire Safety Report (ASFSR) is posted and available on the WU Police Department website. The WU Police Department has partnered with the Office of the Executive Vice Chancellor for Administration and the Office of Information Technology to establish responsibilities and timelines that will ensure students, faculty, and staff are notified, prior to October 1 of each year, that the most recent ASFSR is available on the website. Additionally, the University's Internal Audit Department will follow-up quarterly to ensure implementation of this action plan. Student award notifications are delivered to students electronically through an automated process that identifies aid awarded but not yet disbursed. For the rare occasions that a student may have aid awarded and disbursed in the same day, therefore bypassing the overnight award notification process, SFS has implemented the review of a pre-disbursement daily report to identify students who have an aid offer but were not provided an aid notification. -Enrollment reporting: The Office of the Registrar has updated its procedures to include off-schedule enrollment submissions through NSLDS. On the completion of the National Student Clearinghouse graduate-only file and corrections, an ad-hoc enrollment submission request will be completed. -Return of Title IV funds: To ensure compliance with its internal policy, SFS has updated procedures to complete a formal R2T4 calculation within the student aid system on all withdrawing Title IV students. To monitor that no students are missed as part of the routine procedures, a new report has been created to identify withdrawn Title IV students. This report will be compared bi-weekly to the student aid system to confirm that R2T4 calculations have been completed. -Additional: SFS depends on multiple departments across campus to compliantly deliver federal Title IV aid. SFS will develop an annual training plan for campus partners to ensure they have the knowledge and resources to administer federal aid in compliance with federal regulations. SFS has hired an Associate Director of Operations and Training who will develop this training during calendar year 2025. The University's Internal Audit Department will follow-up quarterly to ensure implementation of this action plan. Completion Date: June 30, 2025 University Contact and Responsible Party: Michael Runiewicz, Assistant Vice Provost & Director of Student Financial Services, (314) 935-5900

View Audit 345761

Finding 526752 (2024-003)

Significant Deficiency 2024

Grossmont-Cuyamaca Community College District

CA

Student Financial Aid Matching / Level of Effort / Earmarking Significant Deficiency § 200.303

Corrective Action Plan: These initial Pell overpayments were incurred in the “early” Pell disbursements that occurred a week before the semester started and the first two weeks of the semester. The enrollment was reported correctly, but part of the issue was the current FA system (SAM) was not progr...

Corrective Action Plan: These initial Pell overpayments were incurred in the “early” Pell disbursements that occurred a week before the semester started and the first two weeks of the semester. The enrollment was reported correctly, but part of the issue was the current FA system (SAM) was not programmed to adjust the amount disbursed based on the student’s current enrollment at the time of disbursement. For the Spring 2024 semester, testing was done on SAM to disburse aid based on current enrollment for the early Spring 2024 disbursements. This change reduced the amount in overpayments if students drop below ½ time for the semester, or withdrew completely. In addition, the Financial Aid Office transitioned from SAM to the Colleague Financial Aid System (starting in 2024-25). Colleague is already programmed to disburse aid based on current enrollment status, so this will not be a recurring issue in the future. Early Disbursement and Overpayment Notes: • For Fall 2023 semester, the first early Pell disbursement was based on 25% of a student’s semester award based on full-time enrollment. If a student is currently enrolled ½-time or higher when this disbursement is processed, they will receive the 25% award amount. If a student is enrolled in less than ½-time status (.5 units to 5.5 units), they will receive a $500 Pell disbursement to account for the lower Pell grant award for less than ½-time students. • For Spring 2024 semester, after testing in SAM, we were able to disburse the early disbursements based on the current enrollment before Census which lowered the overpayment amount significantly. • We understand students add/drop courses through the first two weeks of the semester. The final Pell grant award for the semester is adjusted to the student’s enrollment status on Census day. Students who are ½-time or higher at Census will not be a Pell overpayment for the semester since their Pell grant award will be at 50% or higher. • For students who were enrolled at ½-time or higher at the time the early disbursement was processed, but then dropped to less than ½-time or withdrew completely by Census day, they will be considered a Pell overpayment. o These types of overpayments are unavoidable. o Example: Currently, if a student is scheduled a $500 disbursement for the early 25% disbursement, and is enrolled ½ time, they will receive $500. With the change to actual enrollment (1/2 time for this case), the student will receive $250 instead of $500. If the student drops below 1/2-time or withdraws completely by census, the highest overpayment amount will be $250 instead of $500.

View Audit 345754

Finding 526745 (2024-004)

Significant Deficiency 2024

Central Consolidated School District

NM

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Corrective Action for audit finding 2024-004 [2023-003] – Unallowable Expenditures Impact Aid (Significant Deficiency) Repeated and Modified Condition: During our review of information provided in the Impact Aid application we identified the following issue: • The District used Impact Aid special ed...

Corrective Action for audit finding 2024-004 [2023-003] – Unallowable Expenditures Impact Aid (Significant Deficiency) Repeated and Modified Condition: During our review of information provided in the Impact Aid application we identified the following issue: • The District used Impact Aid special education funds to pay 85% of the salary of the District Safety Coordinator through mid-December 2023 after which it was changed to 15% of the salary from the special education funds. • There was no justification in the files reviewed that identified why the individual’s responsibilities related to special education funding. Response: The following is the corrective actions that have been implemented to address the finding: The Special Education Department Director Mr. Joel Balasuit reviews expenditures to determine allowable criteria are met during the request process. The salary funding source was changed July 1, 2024, and is no longer charged to Fund 25145. Additionally, the approval routing was updated to include the Mr, Balasuit’s approval.

View Audit 345751 Questioned Costs: $1

Finding 526742 (2024-004)

Significant Deficiency 2024

Northeastern State University

OK

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

The Registrar’s Office has already conducted an audit of the NSU Graduate programs to determine the length of each program. The Registrar (Amy Dunn) will provide the Assistant Director of Institutional Effectiveness (Morgan Grovenburg) with a spreadsheet of programs with their program length by Febr...

The Registrar’s Office has already conducted an audit of the NSU Graduate programs to determine the length of each program. The Registrar (Amy Dunn) will provide the Assistant Director of Institutional Effectiveness (Morgan Grovenburg) with a spreadsheet of programs with their program length by February 14, 2025, and the Assistant Director of Institutional Effectiveness (Morgan Grovenburg) will make sure future submissions to the Student Clearinghouse match. The Registrar (Amy Dunn) and her team will input the correct program lengths in Banner (SFACPLR) by March 14, 2025.

View Audit 345743

Finding 526740 (2024-003)

Significant Deficiency 2024

Northeastern State University

OK

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

Instructions for preparing R2T4 records include the appropriate steps for calculating institutional charges. A clerical error transpired and boxes that should have been unchecked were not. We have conducted training with Student Financial Services staff (Counselors: Katie Spencer, Isaac Palmer, Trac...

Instructions for preparing R2T4 records include the appropriate steps for calculating institutional charges. A clerical error transpired and boxes that should have been unchecked were not. We have conducted training with Student Financial Services staff (Counselors: Katie Spencer, Isaac Palmer, Trace Taylor) or management (Director, Cindy Bendabout and Assistant Director, Kriston Gerler) who will be checking for accuracy of records prior to preparing letters for students. Title IV Reporting Specialist (Heather McWilliams) will audit previous week R2T4 records using the automated WD report that is generated weekly on Monday evening. This will ensure that withdrawn students are identified, R2T4 calculations are performed, and funds are returned in a timely manner.

View Audit 345743

Finding 526738 (2024-002)

Significant Deficiency 2024

Northeastern State University

OK

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

Northeastern State University will make changes to our information security policy during the Spring 2025 semester to reflect all 14 elements of the GLBA standard. While there is a GLBA policy pending in the policy committee for campus approval, there is a desire to keep the information security po...

Northeastern State University will make changes to our information security policy during the Spring 2025 semester to reflect all 14 elements of the GLBA standard. While there is a GLBA policy pending in the policy committee for campus approval, there is a desire to keep the information security policy as the central document for NSU's cybersecurity policy. The current information security policy is being worked on by NSU's ITS department in conjunction with an external vendor who is supplying our virtual Chief Information Security Officer. This work is expected to be completed by the end of March and will be submitted to our campus policy committee in April for approval of the modified document which will contain all 14 of the elements as specified in the GLBA standard and brought to our attention during the annual audit.

View Audit 345743

Finding 526736 (2024-001)

Significant Deficiency 2024

Northeastern State University

OK

Questioned Costs Student Financial Aid Reporting

Banner aid year is set up prior to academic year schedule dates being available. Default dates associated with terms on STVTERM are used prior to official dates being established for the upcoming academic/aid year. Once dates are established by the institution, Student Financial Services staff (Func...

Banner aid year is set up prior to academic year schedule dates being available. Default dates associated with terms on STVTERM are used prior to official dates being established for the upcoming academic/aid year. Once dates are established by the institution, Student Financial Services staff (Functional Technologist, Vicki Ryals and Title IV Reporting Specialist, Heather McWilliams) and management (Director, Cindy Bendabout and Assistant Director, Kriston Gerler) will audit the following forms for accurate SAY/ AY periods: • RORTPRD • RORSAYR • RFRDEFA • RPRLOPT • RPROPTS • RORPRDS • RPRLPRD Audit of dates in Banner will be performed prior to originations being established for aid year. This will ensure accurate information is reported in Banner and COD for student records.

View Audit 345743

Corrective Action Plans

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