Corrective Action Plans

Finding 389526 (2023-106)

Significant Deficiency 2023

WI

Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting Auditor Recommendation: We recommend the Wisconsin Department of Administration:  alter its approach to report only the amount of the subaward modifications into ...

Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting Auditor Recommendation: We recommend the Wisconsin Department of Administration:  alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;  update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;  provide training to all state agencies to ensure consistent reporting across state agencies; and  maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively. Planned Corrective Action: The Wisconsin Department of Administration (Department) is committed to accountability and transparency in federal award administration, as is the objective of Federal Funding Accountability and Transparency Act (FFATA) reporting under 2 CFR s. 170. The Department’s Division of Executive Budget and Finance (DEBF) uploads required reporting information to the FFATA Subaward Reporting System (FSRS) on behalf of most state agencies, based on information reported by those agencies that had identified subaward data subject to FFATA reporting. Specific to subaward modifications, the auditors indicate the approach used by DEBF that reports in FSRS the cumulative amount of the subaward rather than the modification amount, is incorrect as is evidenced by the subaward results that appear on USASpending.gov when all entries are considered. The Department shares the auditor’s observations relative to the amounts appearing on USASpending.gov though believes FSRS.gov to contain contradictory guidance relative to subaward modification, including guidance referenced by the auditors.The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Accordingly, DEBF has sought guidance from the Office of Management and Budget (OMB) about how changes to subawards are to be reported in FSRS in order that it may modify, as necessary, its approach to report only the amount of the subaward modifications into FSRS, update existing Department of Administration guidance being used by state agencies to provide subaward modifications to DEBF for submission to FSRS, and provide training to all state agencies to ensure consistent reporting across state agencies. DEBF will maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from OMB indicating that it should report subaward modifications cumulatively. Anticipated Completion Date: June 30, 2024 Person responsible for corrective action: Dustin Trickle, Executive Policy & Budget Manager State Budget Office Division of Executive Budget & Finance dustin.trickle1@wisconsin.gov

View Audit 300490

Finding 389524 (2023-003)

Significant Deficiency 2023

Widener University

PA

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

2023-003 Federal Perkins Loan Program – Federal Assistance Listing Number 84.038 Recommendation: The University implement a procedure with the third-party servicer to ensure that reporting is completed timely so that the University can perform the necessary due diligence we need to perform. Expla...

2023-003 Federal Perkins Loan Program – Federal Assistance Listing Number 84.038 Recommendation: The University implement a procedure with the third-party servicer to ensure that reporting is completed timely so that the University can perform the necessary due diligence we need to perform. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Widener University will work directly with our third-party service provider to gain comfort over compliance controls. In the event of unexpected delays in procuring future years’ compliance audit reports, Widener University will undertake additional testing to ensure proper controls exist in a timely manner. William Lockard, Associate Vice President of Fiscal Operations & Risk Management is the person responsible for corrective action. Planned completion date for corrective action plan: June 30, 2024

View Audit 300486

Finding 389521 (2023-001)

Significant Deficiency 2023

Widener University

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

2023-001 Student Financial Assistance Cluster – Federal Assistance Listing Number 84.063, 84.268 – Enrollment Reporting Recommendation: The University review policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to...

2023-001 Student Financial Assistance Cluster – Federal Assistance Listing Number 84.063, 84.268 – Enrollment Reporting Recommendation: The University review policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Widener University is committed to ensuring timely and accurate enrollment reporting. We will conduct a comprehensive review of the NSLDS Enrollment Reporting Guide to establish policies that comply with the enrollment reporting requirements. Colleen Shinkle, Director of Financial Aid Services, is the person responsible for corrective action. Planned completion date for corrective action plan: June 1, 2024

View Audit 300486

Finding 389516 (2023-001)

None 2023

Gannon University

PA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Finding 2023-001 Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 3 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: • Documen...

Finding 2023-001 Condition The University did not notify the National Student Loan Data System (NSLDS) in a timely manner for 3 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: • Documentation will be updated to include the following: o Adjustment to the frequency by which reports are run. o How to handle students with a G Not Applied error from the National Student Clearinghouse. o Implications for not fixing G Not Applied records with the 60-day requirement window. • Monthly reports of graduates will be run and submitted to the National Student Clearinghouse unless there are no graduates for the reporting period. • Existing G Not applied records will be assessed and corrected as needed. • Individuals will be designated as back-ups; they will review all documentation and be trained on the procedures to ensure the appropriate actions can be sustained by the departments should there be turnover in key positions. Name(s) of Contact Person(s) Responsible for Corrective Action: 1. Megan Loibl, Registrar 2. Zachary Hopkins, Director of Institutional Research Assessment and Analytics Anticipated Completion Date: Corrective action with associated documentation will be created, tested, and confirmed that it resolves the root cause of the finding by Friday, May 31st, 2024.

View Audit 300471

Finding 389483 (2023-003)

Significant Deficiency 2023

Homeless and Hunger Coalition of Northwest Florida, Inc.

FL

Matching / Level of Effort / Earmarking

The Coalition shall maintain ongoing and updated guidance compliance requirements regarding the deliverables and administrative fees on each individual funding source as stated in grant documents and amendments from private, state, and federal sources. It will be the responsibility of executive staf...

The Coalition shall maintain ongoing and updated guidance compliance requirements regarding the deliverables and administrative fees on each individual funding source as stated in grant documents and amendments from private, state, and federal sources. It will be the responsibility of executive staff to review on a monthly basis to make sure current guidance is followed.

View Audit 300452

Finding 389481 (2023-002)

Significant Deficiency 2023

Endicott College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding Reference 2023-002 Finding: In testing the Campus-Level enrollment reporting data elements as reported to NSLDS, key items to test are: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. In testing the Program-Level enrollment reporting data elements, key it...

Finding Reference 2023-002 Finding: In testing the Campus-Level enrollment reporting data elements as reported to NSLDS, key items to test are: OPEID Number, Enrollment Effective Date, Enrollment Status, and Certification Date. In testing the Program-Level enrollment reporting data elements, key items to test, if applicable, are: OPEID Number, CIP Code, CIP Year, Credential Level, Published Program Length Measurement, Published Program Length, Program Begin Date, Program Enrollment Status, and Program Enrollment Effective Date. Of the 40 students with enrollment changes that we selected for testwork, we identified 13 students whose changes in enrollment status were not timely or accurately transmitted to NSLDS, as follows: • KPMG identified that 9 students had enrollment statuses that did not agree between campus-level and program-level NSLDS data. • KPMG identified that 2 students had Program Enrollment Effective Dates that did not agree the College’s records. • KPMG identified that 2 students had status changes that were reported to NSLDS more than 60 days after the date that the College became aware of the changes. None of the items that were exceptions described above resulted in changes to the amounts awarded or disbursed to students by the College for the current fiscal year. Endicott College Responsible Contact: Karen Loomer, Registrar, Corrective Action Plan: The issues caused by the current processes and the following action has been taken to improve the situation. Endicott will review and enhance its process related to enrollment reporting. To that end, the Registrar’s Office has reviewed all reports being used to gather enrollment reporting information and has created new reports to ensure that both the campus level and program level data are being reported correctly and within appropriate time controls. Anticipated Completion Date: February 2024

View Audit 300451

Finding 389480 (2023-001)

Significant Deficiency 2023

Endicott College

MA

Matching / Level of Effort / Earmarking Student Financial Aid Allowable Costs / Cost Principles

Finding Reference: 2023-001 Finding: During testing of student loan notifications, it was identified that one of forty students selected for test work did not receive a notification for three loan disbursements during the year. The item that was an exception described above did not result in changes...

Finding Reference: 2023-001 Finding: During testing of student loan notifications, it was identified that one of forty students selected for test work did not receive a notification for three loan disbursements during the year. The item that was an exception described above did not result in changes to the amounts awarded or disbursed to students by the College for the current fiscal year. The condition identified was the result of a student that selected to opt-out of College email notifications, which resulted in federal loan notifications to not be delivered. The College did not have adequate processes in place to ensure appropriately notification in accordance with federal regulations when a student selected to opt-out of receiving College communications. Endicott College Responsible Contact: Bryan Cain, Senior VP for Student and External Engagement Corrective Action Plan: This finding was the result of students being allowed to opt out of all notifications from Endicott College, which are initiated thru a notification system called EMMA. EMMA is the system of record used for notifying students of loan disbursements and as a result of students being able to opt out of all EMMA notifications this student was not notified of their loan disbursements. As a result of this finding the college has disabled the ability for students to be able to opt out of all EMMA notifications and thus being unable to opt out of student financial notifications such as loan disbursements. Anticipated Completion Date: February 2024

View Audit 300451

Finding 389459 (2023-001)

Significant Deficiency 2023

Baptist Homes Society

PA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties HUD Housing Programs § 200.303

Finding 2023-001 Condition The Corporation lacks proper segregation of duties with respect to the calculation of lost revenue. Proper segregation of duties is necessary to prevent a situation where one individual handles a transaction from beginning to end in order to reduce the potential for nonc...

Finding 2023-001 Condition The Corporation lacks proper segregation of duties with respect to the calculation of lost revenue. Proper segregation of duties is necessary to prevent a situation where one individual handles a transaction from beginning to end in order to reduce the potential for noncompliance due to error or fraud. During the audit of the lost revenue calculation, six months out of fifty-six were input incorrectly into the calculation from the source documents in error. Using the correct revenue amounts for those six months results in a higher total of lost revenue for the period. As a result of the lack of proper segregation of duties, noncompliance due to error or fraud could occur without being detected and corrected, timely. Corrective Action Plan Corrective Action Planned: The Corporation will have more than one person complete a full review of the lost revenue calculation for each report submission. After the information is gathered and reported by the Chief Financial Officer (CFO) but before the information is submitted, the Controller will be asked to review the data. After review and documentation that there has been a review, the reporting will be submitted. Name(s) of Contact Person(s) Responsible for Corrective Action: Brent Foster, Chief Financial Officer Anticipated Completion Date: Review process will be implemented immediately.

View Audit 300422

Finding 389458 (2023-002)

Material Weakness 2023

Seaman Usd #345

KS

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking

We are in agreement and have educated staff by reviewing the “Time and Effort” information provided by KSDE along with the “Time and Effort Clarification Enclosure C”. The Executive Director of Teaching & Learning will review the positions being paid from federal funds to determine if the position i...

We are in agreement and have educated staff by reviewing the “Time and Effort” information provided by KSDE along with the “Time and Effort Clarification Enclosure C”. The Executive Director of Teaching & Learning will review the positions being paid from federal funds to determine if the position is considered a “single cost objective”. Once this is determined, the business office (or assigned staff) will move forward with collecting the Certification of Time or Personnel Activity Report (PAR). These forms will be available to the auditor during the annual fiscal audit.

View Audit 300417

Finding 389389 (2023-008)

Significant Deficiency 2023

Urshan College

MO

Special Tests & Provisions Subrecipient Monitoring Reporting § 200.303

2023-008 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagr...

2023-008 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has engaged a firm for GLBA Risk Assessments, has formed a review committee, and prepared a corrective action plan. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

View Audit 300370

Finding 389385 (2023-006)

Significant Deficiency 2023

Urshan College

MO

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

2023-006 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagr...

2023-006 Special Tests and Provisions – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate and timely enrollment updates to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

View Audit 300370

Finding 389382 (2023-004)

Significant Deficiency 2023

Urshan College

MO

Student Financial Aid Eligibility Reporting

2023-004 Eligibility – Assistance Listing No. 84.063 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findi...

2023-004 Eligibility – Assistance Listing No. 84.063 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The director of financial aid works with the third-party servicer to ensure accurate and timely disbursement dates to COD. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025.

View Audit 300370

Finding 389377 (2023-005)

Significant Deficiency 2023

South Carolina State University

SC

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. The University’s inability to provide evidence that a student’s Perkins Loan repayment schedule and another student’s Perkins Loan file were retained as required will be assessed by the new internal audit team. Corrective procedures and additional internal controls to ensure compliance with the special reporting requirements will be developed. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls to ensure compliance with the special reporting requirements. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389367 (2023-002)

Significant Deficiency 2023

South Carolina State University

SC

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. Management and implementation of current corrective plans are critical to the compliance efforts of the University: As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team. As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389363 (2023-001)

Significant Deficiency 2023

South Carolina State University

SC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies. In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department. Management and implementation of current corrective plans are critical to the compliance efforts of the University: The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle. In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389359 (2023-001)

Significant Deficiency 2023

Molloy College

NY

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management; lalbanese@molloy.edu; 516-323-4025 Molloy University u...

Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management; lalbanese@molloy.edu; 516-323-4025 Molloy University understands the finding and has devised a process to ensure students who submit a request to withdraw which is effective after the completion of the current semester get processed manually in NSLDS once the semester has ended. To aid in this updated practice, a documented procedure has been established that provides a checklist of steps and collection of internal signatures to be completed for each student who indicates they wish to withdraw from the University. Additionally, we will be engaging a consultant to perform a compliance review with the US Department of Education for Enrollment Reporting. This will ensure that the withdrawal status is promptly provided within the required timeframe. Proposed completion date: February 20, 2024

View Audit 300357

Finding 389356 (2023-002)

Significant Deficiency 2023

Antioch University

OH

Special Tests & Provisions Student Financial Aid Period of Performance

Corrective Action Taken or Planned: The University has experienced changes in staffing for personnel involved in enrollment reporting and system irregularities with multiple programs with the National Clearing House. These inconsistencies have caused delays in processing and response to enrollment r...

Corrective Action Taken or Planned: The University has experienced changes in staffing for personnel involved in enrollment reporting and system irregularities with multiple programs with the National Clearing House. These inconsistencies have caused delays in processing and response to enrollment reporting changes. Antioch University has hired a new Director of Records Administration with a primary responsibility for NSLDS reporting. The University will implement a comprehensive training plan for new individuals and teams, including improved documentation of procedures, increased clarity regarding the process for the necessity of error resolution, and a review of system processing to help reduce errors in reporting and increase efficiency. In addition, internal reviews and control audits will be performed throughout the year to ensure accuracy in NSLDS reporting and alignment with the National Clearing House guidance. Person Responsible for Corrective Action: Maureen Heacock, the Registrar and Katy Stahl, Executive Director of Financial Aid & Scholarships are responsible for executing the corrective action plan. Anticipated Completion Date: Fiscal year 2024

View Audit 300356

Finding 389355 (2023-001)

Significant Deficiency 2023

Antioch University

OH

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Taken or Planned: Starting with the 2024-2025 Award year, the Office of Financial Aid and Scholarships is undergoing an internal reorganization. The purpose of this is to provide a broader depth of knowledge and better dual control and compliance functions within the Office of Fina...

Corrective Action Taken or Planned: Starting with the 2024-2025 Award year, the Office of Financial Aid and Scholarships is undergoing an internal reorganization. The purpose of this is to provide a broader depth of knowledge and better dual control and compliance functions within the Office of Financial Aid and Scholarships. In the new reorganization structure, the FA Specialist will be responsible for performing the R2T4 Calculations, with their Supervisor, the Assistant Director of Financial Aid Operations, reviewing and approving the calculation. Once the calculation is completed, and signed off on by the Assistant Director, the FA Specialist will will complete and send the Financial Aid Transmittal Register (FATR) report and notify the Student Accounts Office so they can process the return of funds on through the Financial Aid Posting Register (FATP). Review of the Financial Aid Posting Register will be done by the FA Specialist to ensure the internal process to return funds is timely and posted to the Common Origination and Disbursement system accurately. A quarterly review and internal control audit of Title IV refund calculations will also be completed to ensure accuracy in system processing, days and break calculations, and adherence to Title IV regulations. In addition, the staff will have additional training throughout the year on Title IV compliance and refunds to ensure the University is compliant with all regulations. Person Responsible for Corrective Action: Katy Stahl, the Executive Director of Financial Aid & Scholarships, is responsible for the execution of the corrective action plan. Anticipated Completion Date: Fiscal year 2024

View Audit 300356

Finding 389354 (2023-002)

Significant Deficiency 2023

Economic Development and Industrial Corporation of Boston

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

EDIC will update its current internal controls for submitting subaward information to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and will create a new submission into FSRS each month to report any required subaward information in accordance with the prog...

EDIC will update its current internal controls for submitting subaward information to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and will create a new submission into FSRS each month to report any required subaward information in accordance with the program requirements.

View Audit 300355

Finding 389350 (2023-001)

None 2023

South Boston Community Health Center, Inc.

MA

Cash Management Period of Performance Matching / Level of Effort / Earmarking

Finding: 2023-001 Condition: The Organization drew down the FY 2023 Bridge Access Program grant funds in full upon receipt of the award in the amount of $19,507 in advance of incurring federal expenses. The Organization identified allowable expenses which were incurred prior to receipt of the grant...

Finding: 2023-001 Condition: The Organization drew down the FY 2023 Bridge Access Program grant funds in full upon receipt of the award in the amount of $19,507 in advance of incurring federal expenses. The Organization identified allowable expenses which were incurred prior to receipt of the grant award and during 2024, management worked with HRSA to submit and obtain approval for a budget revision, enabling the Organization to apply the funds to the pre-award costs. lndividual(s) Responsible for Corrective Action: Kim Harrison, Chief Financial Officer Planned Corrective Action: 1. For any grant award, the person developing the budget, most often the CFO, will refer to the Grant Allocation file and ensure that any salaries charged to the grant are not covered by another grant for that same time period. 2. The CFO will review the budget with the Controller and Senior Accountant together and ensure the expenses to be charged to the grant and the time period for the grant is clear. 3. Prior to any HRSA drawdown, the CFO will request a list of expenses charged to the grant in question to ensure the money has been expended. 4. The CFO will share the drawdown data with the Controller. Anticipated Completion Date: Some of this is already occurring but the entirety of this will go into effect immediately.

View Audit 300352

Finding 389334 (2023-001)

Significant Deficiency 2023

Lake County Crisis Center D/b/a A Safe Place

IL

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Finding 2023-001 – Significant Deficiency: Reporting - Compliance Finding Personnel Responsible for Corrective Action: CFO and Accounting department staff Anticipated Completion Date: Completed September 2023 Corrective Action Plan: A Safe Place will implement internal control procedures to ensure t...

Finding 2023-001 – Significant Deficiency: Reporting - Compliance Finding Personnel Responsible for Corrective Action: CFO and Accounting department staff Anticipated Completion Date: Completed September 2023 Corrective Action Plan: A Safe Place will implement internal control procedures to ensure timely submission of all future reports. The CFO will review financial reporting prior to submission. Update: A Safe Place developed an infrastructure and implemented internal control procedures to ensure timely submission of all future reports. The CFO will review financial reporting prior to submission. The Program Administrative Manager will ensure all program performance reports (PPR) will be reviewed and submitted timely.

View Audit 300326

Finding 389330 (2023-001)

Material Weakness 2023

Trihealth

OH

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking

Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF), Assistance Listing No. 93.498 Federal Agency: U.S. Department of Health and Human Services (HHS) Planned Responsible Officials: Mike Crofton, VP of Finance and Interim Chief Financial Officer C...

Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF), Assistance Listing No. 93.498 Federal Agency: U.S. Department of Health and Human Services (HHS) Planned Responsible Officials: Mike Crofton, VP of Finance and Interim Chief Financial Officer Corrective Action: TriHealth is committed to ensuring internal controls are implemented to ensure compliance with Section 200.303 of the Uniform Guidance. In response to the findings, TriHealth has or will implement the following policies and procedures: 1. Design and implement controls over our any future PRF reporting, including both General Distributions and Targeted or Rural Distributions, to ensure the necessary documentation is submitted in the HHS Reporting Portal and that the information submitted is complete and accurate based on accounting records and other data. This will include retention of necessary documentation to support reported expenditures and lost revenues and that such documentation is reviewed by TriHealth’s Controller and VP of Finance and Interim Chief Financial Officer. 2. Utilize Internal Audit to perform detail review and testing over the PRF program reporting, as applicable. This will include the use of Internal Audit to review PRF reporting prior to submission to the HHS Portal, as well as appropriateness of lost revenue and allowability of healthcare related expenses. 3. Prior to submission, the Controller and the Executive Director of Internal Audit will review the draft reporting submissions with the Executive Director of Decision Support and Reimbursement prior to submitting the reports in the HHS Portal. As TriHealth and its affiliates did not receive PRF General Distributions in excess of $10,000, individually or in the aggregate, during PRF Reporting Period 6 (payments received from July 1, 2022 to December 31, 2022), TriHealth will not be required to submit any future reporting in the HHS Portal for PRF General Distributions. However, TriHealth will ensure appropriate levels of review occur for any future reporting of PRF or similar federal funding, including PRF Targeted or Rural Distributions.

View Audit 300321

Finding 389281 (2023-001)

Significant Deficiency 2023

Hagerstown Community College

MD

Matching / Level of Effort / Earmarking Student Financial Aid Subrecipient Monitoring § 200.303

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the num...

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS- FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2023-001 NSLDS Enrollment Reporting Student Financial Aid Cluster-Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported to NSLDS. Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Cause-Enrollment Status Reporting: Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely and correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses in NSLDS. No review was completed to ensure the upload was completed in NSLDS. Cause for Effective Date Reporting - Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student effective date corrections were uploaded to NSC correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate update of the status effective date NSLDS. No review was completed to ensure the upload was completed in NSLDS. The following actions have been implemented to resolve the deficiencies: The Director of Financial Aid has reached out to NSC to determine the errors in the file transmissions. NSC responded back with the issues that need to be research by HCC's Student Financial Aid Office and Registrar's office. Both offices will collaborate to identify the error and develop procedures to minimize the error from happening again. HCC plans to review the reporting procedures for withdrawn and graduating students. NSC sent HCC a detailed explanation of what needs to be reviewed to make sure the correct information is transmitted. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: Summer 2024

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Finding 389279 (2023-003)

Material Weakness 2023

Saint Louis University

MO

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

Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust...

Based on the recommendations outlined in this report, we are committed to enhancing our internal control process to ensure timely submission of Direct Loan and Pell Grant disbursement records to COD. This includes allocating necessary resources, providing additional training, and implementing robust monitoring and oversight mechanisms to address capacity constraints effectively and prevent future instances of noncompliance. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above items by June 2024.

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Finding 388940 (2023-002)

Material Weakness 2023

Saint Louis University

MO

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303 § 200.419

The University updated its DS-2 form and submitted it electronically to the U.S. Department of Health and Human Services on December 4, 2023. The Controller’s Office implemented an annual review of the DS-2 to identify factors that may require amendments to our next filing. In addition, prior to our...

The University updated its DS-2 form and submitted it electronically to the U.S. Department of Health and Human Services on December 4, 2023. The Controller’s Office implemented an annual review of the DS-2 to identify factors that may require amendments to our next filing. In addition, prior to our submission of any DS-2 amendments, University staff other than the initial preparer will re-confirm the accuracy of changes to the DS-2. Tara Thomason, Controller and Assistance Vice President, was responsible for addressing the above.

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Corrective Action Plans

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