Corrective Action Plans

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Management Agrees with the findings. The managing agent has begun to repay the loan by depositing an extra $10,000 into the account. Management will continue to deposit an additional monthly amount of $5,00 until the loan is paid back.
Management Agrees with the findings. The managing agent has begun to repay the loan by depositing an extra $10,000 into the account. Management will continue to deposit an additional monthly amount of $5,00 until the loan is paid back.
Finding 503946 (2024-001)
Significant Deficiency 2024
The Payroll Department has taken immediate action to develop additional safeguards to avoid duplicate pay. When Central Payroll adds to a payline, we will notify the requestor to inform them of this action and ask that they review their payline for accuracy. This should trigger a response from the r...
The Payroll Department has taken immediate action to develop additional safeguards to avoid duplicate pay. When Central Payroll adds to a payline, we will notify the requestor to inform them of this action and ask that they review their payline for accuracy. This should trigger a response from the requestor if they had also added the missing hours via a CU Special Pay. Additionally, as of 06/21/2024, the Late Timesheet option was turned off on CU Special Pay to strengthen controls. Individuals now contact payroll@clemson.edu for assistance. Once contacted the payroll/timekeeping team will update the timecard and ensure the missed pay is added to the next payroll cycle, assuming an emergency/off-cycle check is not needed. The College of Engineering and Applied Sciences (CECAS) will take action to strengthen internal controls to ensure accuracy and compliance. We will establish clear procedures to verify employee payroll data via paylines, as well as cross checking with CU Payroll to ensure changes are properly documented and authorized. We will provide ongoing training for departmental payroll staff on best practices and compliance requirements. Anticipated Completion Date: September 17, 2024 Person Responsible: Central Payroll – Ami Hood, Payroll Director; CECAS – Keri Cortese, Director of Procurement and Payroll Operations Contact/Responsible Party: Ami Hood, Payroll Director Contact Information: hooda@clemson.edu
View Audit 326225 Questioned Costs: $1
Management agrees with the finding and recommendation and has reviewed the HUD requirement for loans. Funds have been transferred and loans will not be permitted based on HUD requirements going forward.
Management agrees with the finding and recommendation and has reviewed the HUD requirement for loans. Funds have been transferred and loans will not be permitted based on HUD requirements going forward.
View Audit 326222 Questioned Costs: $1
Management agrees with the finding and recommendation and has reviewed the HUD requirement for loans. Funds have been transferred and will maintain HUD policy of no unauthorized loans between affiliates.
Management agrees with the finding and recommendation and has reviewed the HUD requirement for loans. Funds have been transferred and will maintain HUD policy of no unauthorized loans between affiliates.
View Audit 326221 Questioned Costs: $1
Management agrees with the finding and recommendation and has reviewed the HUD requirement for funding. Funds have been transferred and will maintain HUD policy of no unauthorized loans between affiliates.
Management agrees with the finding and recommendation and has reviewed the HUD requirement for funding. Funds have been transferred and will maintain HUD policy of no unauthorized loans between affiliates.
View Audit 326219 Questioned Costs: $1
Management agrees with the finding and will ensure payroll is allocated correctly going forward. Funds have been transferred to correct the affiliate.
Management agrees with the finding and will ensure payroll is allocated correctly going forward. Funds have been transferred to correct the affiliate.
View Audit 326216 Questioned Costs: $1
Management agrees with the finding and is working with ownership on reimbursements to the property. Management will collect in accordance with HUD going forward.
Management agrees with the finding and is working with ownership on reimbursements to the property. Management will collect in accordance with HUD going forward.
View Audit 326215 Questioned Costs: $1
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: Ther...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since uncovering this concern, the College is actively working with our third-party vendor (NSC) and our reporting team to resolve the technical issues that caused the errors. We have corrected the dates in NSLDS for the affected students. We have added an additional audit of data submitted to NSC and in NSLDS to rectify any technical errors within the required timeframe. Name of the contact person responsible for corrective action: Jaz Hofbauer, Registrar Planned completion date for corrective action plan: This process is in place for the 2024-2025 academic year.
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College evaluate the transfer students’ status each semester. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: T...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College evaluate the transfer students’ status each semester. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The student affected by this deficiency gave erroneous information about attendance at another college in the same year as their intent to begin at Dunwoody. The processor failed to follow protocol to check for a transcript in NSLDS. The student had only used some of their loan eligibility at the previous institution in the fall semester, so we returned $5,250 in direct loan funds for this student. The student correctly retained the remaining $4,250 for the spring semester at Dunwoody. The total over award was not $9,500 but $5,250. Going forward, the financial aid counselors will be vigilant to search out every student in NSLDS before issuing the student any additional funding. There is now a check and balance in place that will catch anything the financial aid counselor might miss. Name of the contact person responsible for corrective action: Margaret Price, Director of Financial Aid Planned completion date for corrective action plan: This process is in place for the 2024-2025 academic year.
View Audit 325860 Questioned Costs: $1
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audi...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College correct there mistake and review the amount of days scheduled in each break for next fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was caused by incorrectly calculating the Spring Break dates in the academic calendar. The former Director of Financial Aid accounted for the weekdays of break (M-F=5 days) instead of the required full week plus shouldering weekend dates (9 calendar days) as it should have been entered. This erroneous entry was not noticed or caught in a self-audit process. We have completed a 100% file review of withdrawn students and updated the break calculation to correct the error for this year, and moving forward we will conduct two levels of review when entering calculation parameters to ensure accuracy of break calculation. We have updated the affected students’ R2T4 calculations and sent the fund updates to COD on September 20th. The corrective action taken by the current Director of Financial Aid is to ensure there are two extra reviewers added to each future parameter rollover to make sure all dates are accurate in our processing software, as well as a second review of each completed R2T4. Name of the contact person responsible for corrective action: Margaret Price, Director of Financial Aid Planned completion date for corrective action plan: This new process is already in place for the 2024-2025 academic year.
View Audit 325860 Questioned Costs: $1
College Corrective Action Plan: ...
College Corrective Action Plan: Every 30 days, Ringling College of Art and Design reports updated student enrollment activity, encompassing attendance levels, graduation status, withdrawals, dropouts, and enrollment changes, to the National Student Loan Database System via the National Student Clearinghouse. Regrettably, during the 2023-24 academic year, an unforeseen error from the Clearinghouse resulted in the dissemination of incorrect enrollment statuses for a subset of our students. This oversight was beyond the Registrar's Office's knowledge, leading to an unintended delay in rectifying the reported statuses. We believe this Clearinghouse error was an isolated incident, having never occurred in any preceding academic year. The issue has been effectively resolved and should not recur in the future. Nevertheless, as a proactive measure, commencing with the 2024-25 academic year, the Financial Aid Office will collaborate with the Registrar's Office to review a representative sample of at least 10% of student records transmitted to the Clearinghouse. This review process will serve as an additional safeguard, ensuring the accuracy and timeliness of our reporting requirements. Lee Harrell Director of Financial Aid, Office: 941-359-7532, Cell: 941-928-9413
Finding 503585 (2024-001)
Significant Deficiency 2024
Auditor Description of Condition and Effect: Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ens...
Auditor Description of Condition and Effect: Of the five vendors tested for compliance with procurement requirements, the District could not provide documentation of compliance with procurement standards for one of the vendors tested. While the District appears to have made an informal effort to ensure that costs were reasonable by contacting its group purchasing vendor, the District did not issue or document price and/or rate quotations as required. The District could not properly document compliance with federal requirements for informal procurement methods as required under Uniform Guidance. Auditor Recommendation: We recommend that the District reviews its policies and procedures to ensure that applicable procurement requirements are followed and documented when the District enters into new contracts or procurement arrangements with vendors for goods and/or services on federal programs. Corrective Action: The District identified the omitted prior year capital asset additions and has reconciled their UAAL expenditures and benefits accruals to agree with the required audit adjustments. The District will work to ensure the proper year end reconciliations are put into place to avoid future reporting errors. Responsible Person: Chad Baas, Business Manager. Anticipated Completion Date: June 30, 2025.
Finding: Management did not remit payment to HUD for the amount in excess of $250 per unit for their fifteen units. Management was aware the funds needed to be remitted back to HUD in the time frame noted however management has had ongoing communication with HUD over the past year in an effort to k...
Finding: Management did not remit payment to HUD for the amount in excess of $250 per unit for their fifteen units. Management was aware the funds needed to be remitted back to HUD in the time frame noted however management has had ongoing communication with HUD over the past year in an effort to keep the funds and therefore have not yet been remitted. We recommend management review their processes and controls surrounding residual receipts to ensure amounts due to HUD are properly remitted. Corrective Action: In December of 2023, management had a meeting with with HUD to discuss using the residual receipts funds to benefit the Project. At the meeting, HUD agreed to allow the funds to be used as a loan to the operating account until subsidy payments for the Project resumed at which point the funds were to be transferred back to the residual receipts account. The next step that was agreed on was to transfer the funds to the reserve for replacement to be used for necessary repairs and upgrades to the Project. All steps were followed and the transfer request to move the funds to the reserve for replacement was made in May 2024 with no response from HUD. Subsequent follow up inquiries were made with no response from HUD. In August of 2024, management received a recoupment notice from HUD requesting the funds to be returned. Funds were returned to HUD on September 13, 2024.
View Audit 325713 Questioned Costs: $1
2024-001: Errors Relating to Return of Title IV Financial Aid - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264 Grant Period - Year Ended May 31, 2024 Condition Found During our return of Title IV Fund testing we noted that the Universit...
2024-001: Errors Relating to Return of Title IV Financial Aid - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264 Grant Period - Year Ended May 31, 2024 Condition Found During our return of Title IV Fund testing we noted that the University did not calculate or return Title IV for students who ceased attendance correctly for two students out of eleven. The University used the incorrect number of days for the total days in the period of enrollment when calculating the return of Title IV.We consider this to be an instance of non-compliance relating to the Special Tests and ProvisionsCompliance Requirement. Corrective Action Plan Moving forward, the financial aid team will implement internal controls: Marlon Jones, Director of Financial Aid will process the R2T4 using COD instead of Banner. So, Marlon will ensure that the dates for fall break (fall term)/spring break (spring term) are properly utilized within the R2T4 calculations, prior to the start of the terms. After Marlon’s initial process of completing the R2T4 calculation in COD, Erika Guzman, Associate Director, will check the completed R2T4 to ensure precise calculations. This new addition will ensure that two people are determining the accuracy of the R2T4’s, as well as ensuring that the breaks during the terms, are included. Responsible Person for Corrective Action Plan Marlon Jones Jr and Erika Guzman Implementation Date of Corrective Action Plan 9/23/2024
View Audit 325664 Questioned Costs: $1
Re: Response to References Number 2024-001 Student Financial Aid Cluster View of Responsible Officials: Comments on Finding and Recommendation The University agrees that the department did not accurately report the dates of two students' tested enrollment status changes. One date was off by two days...
Re: Response to References Number 2024-001 Student Financial Aid Cluster View of Responsible Officials: Comments on Finding and Recommendation The University agrees that the department did not accurately report the dates of two students' tested enrollment status changes. One date was off by two days, and the second one was off by ten days. This was caused by human error when updating the National Student Clearinghouse error report. Corrective Action Plan for References Number 2024-001 Student Financial Aid Cluster: The University Registrar provided additional training to the staff on the proper way to report status changes when a student withdraws to ensure the actual date of the withdrawal request is used instead of the final date of the term. This training occurred on 9.3.24 before the September National Student Clearing House (NSCH) was submitted. The University Registrar will review the error reports with the staff to ensure the dates are entered correctly before submission. Mid-America Christian University’s University Registrar, Stephanie Davidson, will be responsible for ensuring this corrective action plan is followed as outlined. Stephanie can be reached at stephanie.davidson@macu.edu or 405-692-3241
Finding 503499 (2024-002)
Significant Deficiency 2024
Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...
Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Starting in 2025-26 the College is transitioning to a new ERP, a more robust software system, that will correct this issue. However, in the meantime, the financial aid office will not rely on our current software to automatically match COD Disbursement dates with student account posting dates. The financial aid and business offices will communicate to ensure posting to student accounts are done on the same day as aid is disbursed. In addition, the financial aid and business offices will add a new process to compare COD reports with current software reports on a regular basis to look for any discrepancies. Any discrepancies found will be manually corrected on a timely basis. Name(s) of the contact person(s) responsible for corrective action: Eric Anderson, Director of Financial Aid Planned completion date for corrective action plan: June 30, 2025
Finding 503492 (2024-001)
Significant Deficiency 2024
Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement wit...
Recommendation: We recommend the College reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The 2022-23 audit identified similar issues regarding NSLDS enrollment reporting. Following the 2022-23 audit, the College changed the submission dates to the NSC to allow more time for the NSC to timely report to the NSLDS. Upon further research following the 2023-24 audit, the College learned that this finding relates to manually reported graduates and withdrawn students. Graduates reported during the automated file submittal process were reported as graduating at end of term, while graduates reported manually were reported as graduating on the College’s actual commencement date (one day different than end of term). Going forward the Registrar will be consistent in reporting graduation dates using the end of term for all graduating students. As for the reporting of withdrawals, the Registrar will manually update the enrollment status and effective dates in NSLDS to ensure accurate and timely reporting in the 2024-25 fiscal year. Starting in 2025-26 the College is transitioning to a new ERP, a more robust software system, that will correct this issue. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2025
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the cam...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the enrollment effective date reported to NSLDS on the campus and program level is aligning with the University. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Training on National Student Clearinghouse reporting steps when a non-returning student is processed after the first of term report has been submitted to National Student Clearinghouse. Review process for using end of term date, not Commencement ceremony date as award date. Name(s) of the contact person(s) responsible for corrective action: David L Kumm, Executive VP CFO/COO Planned completion date for corrective action plan: 10/31/2024
Name of Contact Person: Carrie Tripp, Superintendent. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations guidelines. Corrective Action: We agree with the finding and the Data Collectio...
Name of Contact Person: Carrie Tripp, Superintendent. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations guidelines. Corrective Action: We agree with the finding and the Data Collection Form will be filed in a timely manner. Proposed Completion Date: Immediately.
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements and is formally implemented. Explanation of disagreement with audit finding: There is no di...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements and is formally implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The currently-implemented IT procedures were documented in a written information security program (WISP). However, they had not been reviewed and approved during the year of the audit. A penetration test was completed in the Spring of 2024. The penetration testers were unable to gain access to any of the University’s information systems. A risk assessment and vulnerability assessment are scheduled to be completed before April 30, 2025. These actions should correct all significant deficiencies identified in section 2024-001. Name of the contact person responsible for corrective action: Douglas Wade, Executive Vice President and CFO Warner Pacific University 2219 SE 68th Ave Portland OR 97215 dswade@warnerpacific.edu Office Phone 503-517-1043 Cell Phone 661-706-8379 Planned completion date for corrective action plan: April 30, 2025
FINDING 2024-1 UNTIMELY RECONCILIATIONS Comments on Findings and Recommendations The management agent concurs with the auditor’s findings and recommendations. Actions Taken or Planned Management has assigned individuals responsible for performing monthly reconciliations.
FINDING 2024-1 UNTIMELY RECONCILIATIONS Comments on Findings and Recommendations The management agent concurs with the auditor’s findings and recommendations. Actions Taken or Planned Management has assigned individuals responsible for performing monthly reconciliations.
COMPLIANCE FINDING 2024-001 Disbursements to or on behalf of Students September 25, 2024 Criteria: Before an institution disburses title IV, HEA 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 receiv...
COMPLIANCE FINDING 2024-001 Disbursements to or on behalf of Students September 25, 2024 Criteria: Before an institution disburses title IV, HEA 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, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loan program funds, the notice must indicate which funds are from subsidized loans, which are from unsubsidized loans, and which are from PLUS loans (34 CRF 668.165(a)(1). Except in the case of a post-withdrawal disbursement made in accordance with § 668.22(a)(5), if an institution credits a student ledger account with Direct Loan, Federal Perkins Loan, or TEACH Grant program funds, the institution must notify the student or parent of (34 CFR 668.165(a)(2)) – (i)The anticipated date and amount of the disbursement; (ii)The student's or parent's right to cancel all or a portion of that loan, loan disbursement, TEACH Grant, or TEACHGrant disbursement and have the loan proceeds or TEACH Grant proceeds returned to the Secretary; and (iii)The procedures and time by which the student or parent must notify the institution that he or she wishes to cancelthe loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement. The institution must provide the notice described in paragraph (a)(2) of this section in writing (34 CFR 668.165(a)(3)) (i)No earlier than 30 days before, and no later than 30 days after, crediting the student's ledger account at theinstitution, if the institution obtains affirmative confirmation from the student under paragraph (a)(6)(i) of this section;or (ii)No earlier than 30 days before, and no later than seven days after, crediting the student's ledger account at theinstitution, if the institution does not obtain affirmative confirmation from the student under paragraph (a)(6)(i) of Effect: Noncompliance with certain requirements under 34 CFR 668.165(a). Corrective Action: The Office of Financial Assistance has established and implemented procedures that ensure students and parents receive the notifications relating to certain federal loans as required under 34 CFR 668.165(a). Specifically, the notifications will be made via electronic mail and include the anticipated date and amount of the disbursement; the recipients' right to cancel the loan or disbursement; and the procedures and time relating to the recipients' notification of cancellation. These notifications will occur within the required time frame resulting from the type of confirmation received from the student. This procedure will adequately address these requirements. Contact Person: Ashley Owens
Management agrees with the finding. Management will ensure that HUD's approval is obtained in the future.
Management agrees with the finding. Management will ensure that HUD's approval is obtained in the future.
View Audit 325281 Questioned Costs: $1
Finding 2024-003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans andGrants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Gerry Le...
Finding 2024-003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans andGrants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Gerry Leadbetter, Administrator Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the program's reserve fund is completed with formal documentation noting the review. The Business Office Manager will reconcile the bank statement and will sign off on the bank statement, along with the Administrator for the USDA Loan Reserve Bank Account. Anticipated Completion Date: Ongoing
Correction action University personnel corrected the records in NSLDS and Clearinghouse on July 26, 2024 that were identified in Finding 2024-001. Additionally, university personnel conducted a thorough review of all students to ensure the records in NSLDS properly reflected an accurate enrollment s...
Correction action University personnel corrected the records in NSLDS and Clearinghouse on July 26, 2024 that were identified in Finding 2024-001. Additionally, university personnel conducted a thorough review of all students to ensure the records in NSLDS properly reflected an accurate enrollment status. The university immediately (August 2024) implemented training for the newly appointed Interim Registrar on the importance of timely and accurate reporting of enrollment status changes and graduation status. This training was conducted in coordination with the Vice President of Student Services, the Director of Financial Aid, the Controller, and the Director of Information Technology. In addition to hands-on training provided by university personnel, online resources were utilized from NSLDS, Clearinghouse, and the United States Department of Education. The policies and procedures for enrollment reporting has been strengthened, and includes the following reporting schedule: a student roster schedule will be submitted every 30 days. The exceptions report will be reviewed immediately and will be corrected within 10 days. Within 15 days of the end of each semester, a list of graduated students will be submitted to NSLDS. Exceptions will be corrected immediately to ensure all records in NSLDS match the student’s record. The university is confident that the finding related to enrollment reporting has been resolved. Enrollment files are being submitted every 30 days. Summer 2024 completers graduated on August 9, 2024. These students were reported through Clearinghouse, exceptions were addressed, and enrollment statuses of “Graduated” show on NSLDS as certified on September 13, 2024. The schedule of enrollment and reporting and graduation reporting will ensure that the statuses will be accurate in NSLDS. Responsible Person Rose Mulkey, Interim Registrar Anticipated completion date Completed as of July 26, 2024.
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