Corrective Action Plans

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Finding Number: 2023-003 Condition: The Corporation reported the incorrect amount of lost revenues for the period 4 portal submission for MedFlight. Planned Corrective Action: Management agrees and ...
Finding Number: 2023-003 Condition: The Corporation reported the incorrect amount of lost revenues for the period 4 portal submission for MedFlight. Planned Corrective Action: Management agrees and has revised existing internal control processes and policies to implement review and approval procedures to ensure data uploaded into the portal agrees to underlying supporting documentation. Contact person responsible for corrective action: Joe Abel, Chief Financial Officer Anticipated Completion Date: 4/30/2023
We recommend that the City develop and maintain policies and procedures regarding loan monitoring and ensure that all documentation of loan monitoring be maintained on an annual basis. Management's Response: The City concurs with the finding. Responsible Individual: Marti Brown, City Manager. Co...
We recommend that the City develop and maintain policies and procedures regarding loan monitoring and ensure that all documentation of loan monitoring be maintained on an annual basis. Management's Response: The City concurs with the finding. Responsible Individual: Marti Brown, City Manager. Corrective Action Plan: Given the strain on resource available among City staff, the City is working to hire an outside consulting firm to assure a consisten loan monitoring program is in place. Anticipated Completion Date: June 2024
Recommendation: We recommend that the University implement processes and/or internal controls that ensure that a student has completed entrance counseling prior to disbursing Direct Loans proceeds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Acti...
Recommendation: We recommend that the University implement processes and/or internal controls that ensure that a student has completed entrance counseling prior to disbursing Direct Loans proceeds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The error was caused by an abrupt resignation of loan processing staff and a lack of redundancy in critical processing areas. A staff member who was new to loan administration originated a loan then disbursed it to the student the moment it returned from COD. This rapid processing was in response to the student’s dire need for housing funding; however, the expedited process inadvertently circumvented the Banner system’s safeguards. This previously unknown issue has been resolved with the following systems updates: 1. Improved training and documentation 2. The previous system relied on RRAAREQ to prevent disbursement; however, the new system has a secondary and tertiary check that prevents disbursement. Both the entrance counseling tick box on RLADLOR and a positive indicator on the table that captures raw entrance counseling data (RPILECS) must align for a loan disbursement. Name of the contact person responsible for corrective action: Elijah Herr, Director of Financial Aid Planned completion date for corrective action plan: March 2024
View Audit 300906 Questioned Costs: $1
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates reported to NSLDS agree to the enrollment effective dates per the University’s records. Explanation of disagreement with audi...
Recommendation: We recommend that the University strengthen its internal controls over reporting student enrollment changes to NSLDS to ensure that enrollment effective dates reported to NSLDS agree to the enrollment effective dates per the University’s records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: It appears that the erroneous enrollment status effective date reported is equal to the certification date for the enrollment file that was sent to the National Student Clearinghouse (NSC). We are researching how the certification date may have been substituted as the enrollment status effective date. Name of the contact person responsible for corrective action: Nicolle DuPont, Associate Registrar Planned completion date for corrective action plan: April 2024
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the student for...
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A loan disbursement notification was sent to the student for both the fall 2022 and spring 2023 semesters. We can document the spring 2023 loan disbursement notification was sent but are unable to document the date. Our internal processes dictate that the notification would normally be sent on the date of disbursement. We will develop and implement additional controls to effectively capture a student’s disbursement notification to ensure that both a record of the notification and the date are maintained. Anticipated Completion Date: August 15, 2024
Individual Responsible for Corrective Action: Linda Fleischman, Registrar Corrective Action: The Registrar’s Office will reach out to Jenzabar to determine what is triggering the incorrect program start date. Beginning with the summer 2024 students, each new student record will be reviewed prior to...
Individual Responsible for Corrective Action: Linda Fleischman, Registrar Corrective Action: The Registrar’s Office will reach out to Jenzabar to determine what is triggering the incorrect program start date. Beginning with the summer 2024 students, each new student record will be reviewed prior to the initial National Student Clearinghouse submission to ensure that the start date is being reported correctly. Anticipated Completion Date: August 15, 2024
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to...
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. The break days for fall 2022 were not properly calculated to include a break of 5 days. We will develop and implement a process within Student Financial Services to audit all R2T4 records for accuracy, completeness, and consistency regarding length of academic periods. Anticipated Completion Date: August 15, 2024
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student...
Individual Responsible for Corrective Action: Everett Jeter, Director of Compliance Corrective Action: The error falls into the category of human oversight rather than fundamental misunderstanding of the regulation or timing of processes. A transfer monitoring record was originated for this student approximately six weeks prior to the spring 2023 semester. We did not receive a transfer monitoring response from NSLDS and therefore student was awarded aid as a non-transfer student. We recognized the oversight and the student’s award amount was updated to maintain appropriate annual limit during the spring 2023 semester. We will develop and implement additional controls to effectively capture transfer students for monitoring when a response from NSLDS is not received to ensure award accuracy. Anticipated Completion Date: August 15, 2024
We recently completed the transition and onboarding of departmental staff which would allow the University to fully enact its plan to ensure both the financial aid and the Registrar's office will perform prompt review of processing University withdrawals. The Registrar's office will develop process ...
We recently completed the transition and onboarding of departmental staff which would allow the University to fully enact its plan to ensure both the financial aid and the Registrar's office will perform prompt review of processing University withdrawals. The Registrar's office will develop process and procedures documentation as an internal control measuring tool to ensure that Administrative Withdrawals (AW) and Withdrawals for lack of attendance (WA) that affect student emollment are identified immediately. Staff in the Financial Aid and the Registrar's office will actively take part in training workshops and webinars provided by the Depatiment of Education and NASF AA for continuing education to stay abreast of new developments and best practices in the industry.
View Audit 300889 Questioned Costs: $1
Beginning immediately the District will develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and frin...
Beginning immediately the District will develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. The District will also ensure that all items are posted at the work site to ensure compliance.
The party that was making sure of signatures and signatures of changes ended up in a backlog and lost time cards. If time cards are sent back for signatures a copy of the original will be kept until the signed ones come back, and follow up will be made on a timely basis.
The party that was making sure of signatures and signatures of changes ended up in a backlog and lost time cards. If time cards are sent back for signatures a copy of the original will be kept until the signed ones come back, and follow up will be made on a timely basis.
View Audit 300786 Questioned Costs: $1
Finding 389879 (2023-003)
Significant Deficiency 2023
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Name of Contact Person Casey Reagan, Registrar, is responsible ...
2023-003 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) (Repeat finding of 2022-001) Name of Contact Person Casey Reagan, Registrar, is responsible for ensuring student enrollment status for changes in enrollment are correct. Melissa White, Director of Financial Aid, is responsible for uploading the enrollment status reports to clearinghouse. Corrective Action Planned During the audit, it was noted that Tusculum reported student enrollment status at changes in enrollment incorrectly. The Registrar and the Director of Financial Aid will work in conjecture to determine why the report that is pulled to upload to clearinghouse is not pulling accurate student enrollment status changes in enrollment. Once the error is identified and fixed, financial aid will pull the report and check to ensure everything is pulling correctly. Then, each month as the report is pulled, a random sampling of students will be pulled out of the report to be checked against the enrollment records to ensure that the report continues to pull correctly. Anticipated Completion Date The Registrar and Director of Financial Aid still needs to identify where the error is occurring. It is the goal to have this issue resolved before the end of the spring 2024 semester.
2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the Designated Employees in charge of overseeing the GLBA polic...
2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the Designated Employees in charge of overseeing the GLBA policy. Corrective Action Planned During the audit, it was noted that Tusculum did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. In fall 2023, IT, the Registrar, and the Director of Financial Aid met to discuss making sure that all of the new pieces of the GLBA policy were being implemented properly. In December of 2023, IT began the latest vulnerability scan and risk assessment to be in compliance with the risk assessment requirements of the GLBA Policy. This assessment should be completed by the end of spring 2024. The University is also working on updating its GLBA policies and procedures to align with the GLBA Policy. Anticipated Completion Date This process is currently ongoing and it is the University's goal to have ongoing GLBA policies updated and the risk assessment completed before the end of the 2023-2024 academic year.
Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2023 Corrective Action Plan: The Registrar’s Office is responsible for enrollment reporting to the National Student Clearinghouse. Af...
Finding number: 2023-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2023 Corrective Action Plan: The Registrar’s Office is responsible for enrollment reporting to the National Student Clearinghouse. After consulting with the Interim Registrar, it was determined that the two students in question were manually updated in the National Student Clearinghouse. There was no recollection regarding why the particular effective dates were used. The two student records have been corrected both in the National Student Clearinghouse and the National Student Loan Data System. Going forward, the Registrar’s Office will diligently ensure that the proper reporting of effective dates is submitted to the National Student Clearinghouse. We do not foresee any future issues. Timeline for Implementation of Corrective Action Plan: The corrective action plan has been implemented as of March 2024. Contact Person Despina Lambropoulos, Director of Financial Aid Shawna Lind, Interim Registrar
Finding 389851 (2023-001)
Significant Deficiency 2023
FINDING NUMBER I: 2023-001-Compliancc over Matching-(Significant Deficiency) Federal Program Information: Funding Agency: Title: Assistance Listing Number: Compliance Requirement: Award Year: Housing and Urban Development Continuum of Care 14.267 Matching July 1, 2022 to June 30, 2023 Condition: Dur...
FINDING NUMBER I: 2023-001-Compliancc over Matching-(Significant Deficiency) Federal Program Information: Funding Agency: Title: Assistance Listing Number: Compliance Requirement: Award Year: Housing and Urban Development Continuum of Care 14.267 Matching July 1, 2022 to June 30, 2023 Condition: During our audit, we noted that Barrett Foundation only matched 7 .34% of the total applicable expenses for the year which was less than the required 25%. Criteria: Barrett Foundation must match all applicable grant funds, with no less than 25 percent of cash or in-kind contributions from other sources (24 CFR section 578.73(a)). Effect: Barrett Foundation under matched the required amount for the Continuum of Care program. Questioned Costs: None Cause: Barrett Foundation did not establish a sufficient system of internal control to ensure that they were in compliance with the required match for the fiscal year. Auditors' Recommendation: We recommend that Barrett Foundation establish a system of internal controls to ensure that they provide at least 25% of both cash and in-kind contributions for all applicable programs under the Continuum of Care program. Management's Response: In FY23, Barrett Foundation transitioned from in-house financial services to an outside accounting firm. The transition allowed Barrett Foundation to create an internal structure to meet the needs of new programs. We recognize that while progress has been made, some issues continue to need attention. We arc working diligently with our community partners to meet their matching requirements and expect to not experience this issue in FY24. Additionally, we arc currently updating Barrett Foundation's Finance Policies in which we arc establishing policies to address contracts that require match.
Name of Responsible Individual: Montague Blount Corrective Action: The University Registrar will develop a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions in the Registrar's O...
Name of Responsible Individual: Montague Blount Corrective Action: The University Registrar will develop a plan to ensure appropriate cross-training, position backup, and a system of proper checks and balances to improve quality control and continuity in executing core functions in the Registrar's Office. Enrollment reporting is a critical function that will be prioritized in the implementation of the referenced plan. Anticipated Completion Date: June 30, 2024
Names of Responsible Individuals: Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The Financial Aid office made several staffing changes in 2022-2023. The newly hired staff did not receive the proper training to perform their roles effectively. ...
Names of Responsible Individuals: Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The Financial Aid office made several staffing changes in 2022-2023. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors identifying and calculating the unearned amount of Title IV assistance to be returned. The previous Financial Aid Director was terminated before the prior corrective action plan could be fully completed. New leadership, in collaboration with the Office of Information Technology, has developed an automated weekly report confirming student withdrawal dates. The report is scheduled to be emailed to Financial Aid office every Friday. The Financial Aid Director reviews the report and identifies Title IV recipients. The return of title IV funds calculation would be performed for those students. Any funds required to be disbursed or returned would then be processed. Anticipated Completion Date: February 28, 2024
View Audit 300714 Questioned Costs: $1
Names of Responsible Individuals: Brandon Rhone, Analyst, Financial Aid Systems, Chad Wick, Director Financial Aid, and Mark Hergan, VP Enrollment Management Corrective Action: The Financial Aid office made several staffing changes in 2022-2023. The loan coordinator left the institution. Newly hire...
Names of Responsible Individuals: Brandon Rhone, Analyst, Financial Aid Systems, Chad Wick, Director Financial Aid, and Mark Hergan, VP Enrollment Management Corrective Action: The Financial Aid office made several staffing changes in 2022-2023. The loan coordinator left the institution. Newly hired staff were not properly trained, resulting in the failure to carry out loan notification as required. The VP of Enrollment created a process, implemented in the Spring of 2023, that automated the student loan disbursement notifications with-in the required 30 days of student accounts transmitting their loans. Anticipated Completion Date: February 28, 2024
Names of Responsible Individuals: Brian Emery, Associate Director Financial Aid and Chad Wick, Director Financial Aid Corrective Action: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The ...
Names of Responsible Individuals: Brian Emery, Associate Director Financial Aid and Chad Wick, Director Financial Aid Corrective Action: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023- 2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed. Anticipated Completion Date: June 30, 2024.
View Audit 300714 Questioned Costs: $1
Names of Responsible Individuals: Brandon Rhone, Analyst Financial Aid Systems, Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual to an automated review process. The COA data that was inputted at the be...
Names of Responsible Individuals: Brandon Rhone, Analyst Financial Aid Systems, Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual to an automated review process. The COA data that was inputted at the beginning of the award year did not match all budget components causing inaccuracies. The Financial Aid office was adjusting the budget components of the COA manually, which resulted in miscalculations. When these calculations were performed COD might not have been updated and therefore the COA could be inaccurately reported. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes. The Financial Aid office will review all student COA calculations to ensure that the COA used for originating and disbursing funds is correct. The Financial Aid office will set up automatic processing of key reports to identify rejected origination records. The Financial Aid office will set up the Direct Loan COD Reject Report (DCRR) and the Pell COD Reject Report (PCRR) to run Sunday night and be available Monday morning to be reviewed by the Financial Aid Advisors. The Financial Aid office will make the necessary corrections and update by the end of the week. The Financial Aid office will run Batch FA Transmittal Register (FATR) to confirm that all anticipated awards have passed all rules and are ready to transmit. Those that don’t pass will be reviewed and students will be contacted for updated/corrected information. COD records will be exported nightly through an automated process to ensure all deadlines are met and that we are not exceeding the 15 calendar day limit. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which will eliminate the need for any manual calculations of COA. This automated process should eliminate improperly calculated COAs. Anticipated Completion Date: June 30, 2024
Names of Responsible Individuals: Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes wh...
Names of Responsible Individuals: Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs. Anticipated Completion Date: June 30, 2024
View Audit 300714 Questioned Costs: $1
Finding Number: 2023-002 Planned Corrective Action: Cleveland Play House had extensive turnover during the 2022 and 2023 fiscal years which resulted in several vacancies, including the Director of Finance position, for a significant portion of the year. As a result, many of the reports that are stan...
Finding Number: 2023-002 Planned Corrective Action: Cleveland Play House had extensive turnover during the 2022 and 2023 fiscal years which resulted in several vacancies, including the Director of Finance position, for a significant portion of the year. As a result, many of the reports that are standard practice in our organization were not being completed. In addition, the filing of certain documentation to support expenditures was not being done consistently. The Director of Finance position was not filled until November 2022. As a result, documentation of allowable expenditures is being addressed for the fiscal 2023 audit. In addition to turnover, the organization transitioned to a new general ledger system with a new chart of accounts in fiscal year 2022. As a result of this transition and the vacancies mentioned above, certain data pertaining to the federal programs was not being captured. Management has informed all staff of the requirements to track federal programs within the general ledger accounts. Anticipated Completion Date: September 30, 2024 Responsible Contact Person: Erica Tkachyk, Director of Finance
View Audit 300711 Questioned Costs: $1
Views of responsible officials and planned corrective action: The Authority acknowledges that this error occurred. When we identified this issue, we contacted the grantor agency for guidance. They explained how to submit a refund and acknowledged that since the grant was still open, we had the ab...
Views of responsible officials and planned corrective action: The Authority acknowledges that this error occurred. When we identified this issue, we contacted the grantor agency for guidance. They explained how to submit a refund and acknowledged that since the grant was still open, we had the ability to correct an incorrect draw. This refund has been processed and the Authority has put additional internal controls in place to ensure the proper match is calculated for each grant draw in the future. Additionally, upon final grant closeout, all the numbers are verified and reconciled back to the grant agreement, including the match.
Finding 2023-002 - Material Weakness - Borrowings from Endowment Fund Condition Found The College has borrowed from its endowment funds for campus renovations and to cover certain operating expenses of the College prior to and following its accreditation and approval to participate in federal studen...
Finding 2023-002 - Material Weakness - Borrowings from Endowment Fund Condition Found The College has borrowed from its endowment funds for campus renovations and to cover certain operating expenses of the College prior to and following its accreditation and approval to participate in federal student financial aid programs. As such, the fair value of assets associated with the donor-restricted endowment funds has fallen below the level that the donor or UPMIFA requires the College to retain as a fund of perpetual duration. Corrective Action Plan The College obtained guidance from legal counsel regarding the appropriateness of borrowing from the endowment fund under Ohio UPMIFA. The College has developed long-term plans for maintaining and sustaining its financial stability, including restoration of the endowment, through the following strategies outlined in the board-approved Social Enterprise and Enrollment Plan: ● Grow advancement-derived revenue ● Implement core college footprint ● Align student-derived revenue ● Activate learning hubs ● Explore potential game changers, such as the College’s recent Federal Work College designation ● Assess non-payroll cost reduction strategies ● Invest in additional capacity incrementally ● Monitor performance, evaluate results, and course-correct as needed Responsible Person for Corrective Action Plan Jane Fernandes, President
The University verified the internal processes related to this report and verified the operating system manual used by the University since the repo1t is sent electronically. In addition, the University continues with the process of continuous training for the Register Office, Academic Office and Fi...
The University verified the internal processes related to this report and verified the operating system manual used by the University since the repo1t is sent electronically. In addition, the University continues with the process of continuous training for the Register Office, Academic Office and Financial Aid Office with the purpose of sending this report in the time required according to regulations
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